5

Implications of Contamination Remaining in Place

Despite the ability of some remedial technologies to remove substantial amounts of mass, at most complex sites contamination will remain in place at levels above those allowing for unlimited use and unrestricted exposure (see Chapter 4). This chapter discusses the potential technical, legal, economic, and other practical implications of this finding.

First, contamination from these sources must be contained on-site, by using either hydraulic or physical containment systems combined with institutional controls. Indeed, 65 percent of source control RODs from FY 1998–2008 included containment, and institutional controls are used at the vast majority of CERCLA source control remedial actions to enhance and ensure their effectiveness and protectiveness (EPA, 2010a). Because the failure of these systems could create new exposures, potentially responsible parties (PRPs) should weigh the robustness and potential for failure during remedy selection and implementation. Second, our understanding of the risk posed by contaminated groundwater is inherently dynamic. For example, toxicity information is regularly updated, and contaminants that were previously unregulated may become so, changing the drivers for risk assessment and cleanup decisions. In addition, pathways of exposure that were not previously under consideration can be found to be important, such as has happened with the vapor intrusion pathway over the past decade. Consideration of these new factors can change the overall protectiveness of a remedy that leaves contamination in place. Third, residual contamination necessarily reduces the amount of groundwater available for unrestricted use. Treating groundwater for drinking water purposes is very costly and, for some contaminants (e.g., 1,4-dioxane), technically challenging. Finally,



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5 Implications of Contamination Remaining in Place Despite the ability of some remedial technologies to remove substantial amounts of mass, at most complex sites contamination will remain in place at levels above those allowing for unlimited use and unrestricted exposure (see Chapter 4). This chapter discusses the potential technical, legal, eco- nomic, and other practical implications of this finding. First, contamination from these sources must be contained on-site, by using either hydraulic or physical containment systems combined with institutional controls. Indeed, 65 percent of source control RODs from FY 1998–2008 included containment, and institutional controls are used at the vast majority of CERCLA source control remedial actions to enhance and ensure their effectiveness and protectiveness (EPA, 2010a). Because the failure of these systems could create new exposures, potentially responsible parties (PRPs) should weigh the robustness and potential for failure dur- ing remedy selection and implementation. Second, our understanding of the risk posed by contaminated groundwater is inherently dynamic. For example, toxicity information is regularly updated, and contaminants that were previously unregulated may become so, changing the drivers for risk assessment and cleanup decisions. In addition, pathways of exposure that were not previously under consideration can be found to be important, such as has happened with the vapor intrusion pathway over the past decade. Consideration of these new factors can change the overall protectiveness of a remedy that leaves contamination in place. Third, residual contamination necessarily reduces the amount of groundwater available for unrestricted use. Treating groundwater for drinking water purposes is very costly and, for some contaminants (e.g., 1,4-dioxane), technically challenging. Finally, 161

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162 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES leaving contamination in the subsurface may expose the landowner, prop- erty manager, or original disposer to complications that would not exist in the absence of the contamination. PRPs may be sued for natural resource damages by the resource trustee (if the underlying groundwater is no lon- ger potable without treatment because of remaining contamination) or for personal injury and/or property damages pursuant to common law by local residents or others (if the contamination crosses property boundaries and causes injury or property damage). At any given site, the risks and the technical, economic, and legal com- plications associated with residual contamination need to be compared to the time, cost, and feasibility involved in removing contamination outright. As a practical matter, the Committee did not seek to estimate the relative scope of the nontechnical impacts of leaving contamination in place, and it is probably not feasible to do so. Whether these potential consequences are likely to occur is site specific, and some implications may not materialize at some sites. POTENTIAL FOR FAILURE OF REMEDIES AND ENGINEERED CONTROLS The long-term management strategies for many complex sites include leaving significant amounts of contamination in place. At such sites the achievement of risk-based goals is based on a reduction of the contaminant flux (e.g., reduction in source strength) between the zone of residual con- tamination and the point(s) of compliance. Such flux reduction is generally accomplished by one of four approaches, possibly coupled with partial removal of source zone contamination: (1) hydraulic containment, (2) physical containment, (3) reduction of contaminant concentrations through natural processes (monitored natural attenuation), and/or (4) reduction of contaminant concentrations through an engineered reaction zone, most commonly in the form of a downgradient permeable reactive barrier (PRB) (see Chapter 4 for descriptions of these technologies). This section summa- rizes key concepts and tools for assessing the likelihood and consequences of failure for these approaches. Each of the remedial strategies listed above is well established and is unlikely to exhibit “complete” failure in any meaningful sense. Rather, some degree of contaminant flux reduction is likely to be realized, even if the overall magnitude and/or spatial extent of the reduction is less than ex- pected from design calculations. The consequences of such “partial failure” would depend both on the measures used to monitor performance and the corrective actions that are triggered by inadequate performance. There are few reports in the peer-reviewed literature that document both the failure of a long-term remedial strategy and the resulting response (although these

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IMPLICATIONS OF CONTAMINATION REMAINING IN PLACE 163 issues should be addressed in the five-year review process for sites regulated under CERCLA). This lack of focused literature on the failure of remedia- tion systems designed for long-term management may be due, in part, to the likelihood that system failure would generate incremental, rather than sharp, increases in operation costs, as discussed below for each of the four strategies. Hydraulic Containment Pump and treat (P&T) has increasingly been implemented as a long- term management strategy, with the primary goal of hydraulic containment to prevent further spreading of contamination. In a general sense, “failure” of hydraulic containment occurs when groundwater that originates from within the target capture zone is not completely captured by extraction wells, but instead is allowed to migrate downgradient beyond property boundaries and toward a receptor. Such failure could occur as a direct consequence of inadequate well placement and/or underspecified pumping rate(s) due to a misunderstanding of the governing hydrogeology (e.g., an incorrect or incomplete groundwater model). Even for a properly designed extraction system, containment failure could occur after startup because of temporal changes in hydrologic conditions such as recharge or regional flow conditions. To assist with identifying potential P&T failure, the U.S. Environmen- tal Protection Agency (EPA) has recently developed a six-step procedure for evaluating the hydraulic containment of target capture zones, with an emphasis on comparing measured water levels and concentrations against model predictions (EPA, 2008a). While establishing a formal comparison between measured and predicted capture zones still requires considerable site-specific judgment, the availability of established guidance (and an on- going process to refine it and expand its applicability) is an important development. As discussed in Chapter 4, EPA has applied the Remedial System Evalu- ation (RSE) process to more than 60 operating P&T systems at Superfund facilities. At many of these, field observations were unable to establish the success of hydraulic containment at the desired level of confidence. In some cases, additional monitoring was recommended to clarify the evaluation. However, for other sites, adjustment to the locations and/or operation of extraction wells was recommended. Although such midcourse corrections typically increase the cost of P&T system operation, pumping rates, moni- toring programs, or even extraction wells can also be reduced if the system is overdesigned for current conditions. In general, actions to improve P&T performance are straightforward to implement and normally generate an incremental, rather than drastic change in the life-cycle cost of site manage-

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164 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES ment. In this regard, hydraulic containment may be regarded as an adaptive strategy that can readily be updated in response to new information about the site. Physical Containment Barriers are frequently used to influence groundwater flow in combined remedies that also use extraction wells and/or engineered reaction zones. From a containment standpoint, the overall remediation goal is similar to hydraulic containment: maintain control of groundwater within a target capture zone. Thus, similar monitoring and analytical approaches might be used to assess performance. Failures in physical containment may occur due to incorrect design or construction of barriers, poor seals between sec- tions (in the case of sheet pile barriers or geomembranes), holes/defects in materials, physical or chemical damage, poor connection between a verti- cal barrier and underlying confining bed, and lack of control of recharge inside the contained area. These and similar expressions of “failure” are likely to occur locally at small defects in vertical walls, rather than across the full extent of the barrier system. Because the flow influence of a barrier irregularity will likely be distributed across a large area, detecting such lo- cal failure through routine groundwater monitoring is likely to be difficult. A recent NRC review concluded, in part, that available field data are insufficient to provide a robust assessment of the potential for or actual occurrence of failure in vertical barriers (NRC, 2007), particularly over long decision horizons. However, reports from site-specific remedial system evaluations and CERCLA five-year reviews have identified instances where hydraulic monitoring indicated that physical containment systems may have “failed” (e.g., EPA, 1999; Northgate Environmental Management, 2008), although specific mechanisms are typically not identified. Even if the precise location of a barrier defect could be identified through field monitoring, effective measures for the direct repair of a flawed or cracked vertical barrier have not been developed. Instead, adjustments to other aspects of the remedial system would likely be needed. For both of the above CERCLA examples, the vertical barriers functioned as components of combined remedies that also included extraction wells, which resulted in straightforward adjustments to system operation that maintained a high degree of confidence in successful hydraulic containment. In additional to the possibility of hydraulic failure, earthen barriers can also release contaminants by molecular diffusion. Because chemicals in most barrier materials have diffusion coefficients that are similar to those in aquifer material, and the diffusion path length is relatively short (typically one meter or less), the time for a solute to diffuse across the barrier could be relatively short, on the order of years rather than decades (e.g., Mott and

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IMPLICATIONS OF CONTAMINATION REMAINING IN PLACE 165 Weber, 1991; Khandelwal et al., 1998; Krol and Rowe, 2004). Although the potential for diffusion across slurry walls has been long recognized by scholars, field studies to assess this scenario have not been performed. However, even if elevated contaminant concentrations are present in the immediate vicinity of a vertical barrier, diffusive contaminant fluxes are typically several orders of magnitude less than advective fluxes, and it is plausible that molecular diffusion would constitute a significant concern at only a very small number sites (e.g., sites with both large concentrations within a containment zone and a receptor located in close proximity to a vertical barrier). Permeable Reactive Barriers To function successfully, a permeable reactive barrier (PRB) must pro- vide hydraulic control of the upgradient target capture zone, such that all contaminated water flows through the PRB rather than around or below it. In addition the PRB must have sufficient reaction capacity to sustain the necessary reduction in contaminant concentrations over the appropriate design time frame. Failure to achieve either or both objectives can occur because of inadequate design (e.g., improper wall placement or reaction zone thickness) or because of changes within the PRB that occur over time (loss of permeability and/or reactivity). In addition, if a PRB was placed downgradient of a source zone but within a region that previously con- tained dissolved contamination, it is possible that measurable downgradient concentrations will persist due to back-diffusion, even if the PRB is func- tioning as designed (Sale and Newell, 2010). The vast majority of installed PRBs are constructed of zero-valent iron, which produces redox conditions and results in pH changes that are likely to promote precipitation of groundwater minerals. This phenomenon has long been recognized as a potential problem, and numerous laboratory and modeling studies have explored the potential consequences of these processes for PRB longevity (e.g., Yabusaki et al., 2001; Kohn et al., 2005; Johnson et al., 2008; Wilkin and Puls, 2003; Sass et al., 2002; Phillips et al., 2010). However, as noted by ITRC (2005a, 2011), no PRB has “failed” due to loss of permeability or reactivity. In the most detailed published evalu- ation of iron-based PRB performance (Henderson and Demond, 2007), a handful of active PRB projects reported situations where improper design (insufficient depth or width) resulted in incomplete hydraulic capture. Of the 40 projects, only three exhibited post-installation performance degrada- tion involving the loss of permeability due to precipitation and/or deceased reactivity. As with low-permeability barrier systems, the failure of a PRB system is likely to occur locally rather than across the entire plane of interest, and it is

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166 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES plausible that repair, rather than replacement, could be the appropriate re- sponse action. At the time of this writing, reports where installed PRBs were repaired or replaced were not located in the literature. As with the other long-term management strategies, the operating history of PRB technology is simply too short to support a robust assessment of the potential long- term management costs. However, concerns related to back-diffusion could potentially limit the application of PRB systems to sites where substantial contamination is not initially present downgradient of the installed PRB. Monitored Natural Attenuation Monitored natural attenuation (MNA) is most often used in conjunc- tion with other active or engineering remedial components and is seldom employed as a stand-alone measure (EPA, 2010a). The success of natural attenuation as a remedy depends on the site-specific ability to predict the evolution of complex biogeochemical processes over an extended period of time. Because of uncertainties in long-term predictions, natural attenuation requires confirmatory monitoring, such that MNA remedies are accompa- nied by a detailed program of monitoring (e.g., NRC, 2000; EPA, 2004a). Numerous protocols exist for evaluating MNA performance including a recently proposed decision framework for evaluating MNA for inorganic or radionuclide contamination (e.g., ITRC, 2010). Although focused on inorganic contaminants, the ITRC protocol contains many elements ap- propriate for sites with organic contaminants. In particular, the need for a contingency plan was emphasized, which provides a cleanup approach that will be implemented if “the selected remedy fails to perform as antici- pated” (EPA, 2007). For MNA remedies, a suitable contingency plan might include optimization of source or plume treatments, implementation of an enhanced attenuation (EA) technology, pursuit of a technical impracticabil- ity waiver, or the use of institutional controls. MNA systems could fail for many reasons, including temporal changes in site-specific hydrologic or geochemical conditions, the depletion of natu- ral sources of nutrients or electron acceptors/donors, and lower-than-antic- ipated transformation rates. Further, the regulators may believe that there is insufficient evidence that MNA is occurring in the intended fashion. For example, it may be difficult to verify that the presence of daughter products is due to parent compound degradation and not co-contamination. It is difficult to generalize regarding the potential cost of MNA failure, which will depend on site-specific conditions, the nature of the contingency actions, and the degree of conservatism built into the monitoring program. A properly designed monitoring program should provide “early detection” that allows for the implementation of a contingency plan prior to the point when a migrating plume would present elevated risks to receptors.

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IMPLICATIONS OF CONTAMINATION REMAINING IN PLACE 167 However, if contaminant migration and/or plume expansion occurs prior to the detection of failure, additional costs may be incurred. In certain cir- cumstances, the combined cost of failed MNA and implementation of an additional remedy may exceed the cost that would have accrued had the remedy originally been put in place instead of MNA. To avoid such occur- rences, the monitoring program should be directed at providing confirma- tion of the assumptions used to extrapolate the performance of MNA, in an adaptive management mode. *** Common to all the remedies discussed above are unplanned and cata- strophic events that may lead to failure of the proposed containment/treat- ment techniques, potentially for long periods of time. For example, natural disasters (e.g., earthquakes, floods, or other events) could cause changes in local hydrology, damage the remediation/containment system, or cause a loss of power to an active containment process. Flooding or other events could spread contamination to new areas and/or create new exposure path- ways (e.g., vapor intrusion). Because contaminant migration from source zones or the plume is often slow, none of these events is likely to lead to catastrophic failure of the remedial system, but such events could lead to contaminant releases from the target capture zone if the failure is not iden- tified and remedied. In summary, at sites where contamination remains in place, an evaluation of potential events that could lead to a failure of the long-term management approach should be performed and contingency plans developed. IMPLICATIONS OF THE LONG-TERM NEED FOR INSTITUTIONAL CONTROLS At every site where contaminants will be left in place (for any sig- nificant length of time), institutional controls are necessary to prevent the exposure of local residents to chemicals in groundwater and soil. At groundwater sites, institutional controls play three roles. First, they can restrict the use of contaminated groundwater. Second, they can protect the occupants of overlying buildings (or proposed buildings) from exposure to chemicals from contaminated groundwater through vapor intrusion (e.g., by requiring systems and barriers to prevent vapor from entering buildings). And third, they can prevent activities that might compromise remedies, such as penetration of landfill caps where the landfill is a source of groundwater contamination or pumping that is likely to spread contami- nation. If properly implemented and enforced, institutional controls allow a groundwater remedy to be protective in cases where residual contamination

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168 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES remains above unrestricted use level. From 1986 to 1996, 3 to 20 percent of groundwater remedies at Superfund facilities had institutional controls. However, by 2008, 93 percent of the groundwater remedies selected that year included institutional controls (EPA, 2010a) and current guidance is likely to require such controls at every groundwater contamination site. Types of Institutional Controls Institutional controls (ICs) are administrative and/or legal controls that minimize the potential for human exposure to contamination and/or protect the integrity of a remedy, generally by attempting to modify human behavior. For example, proprietary controls represent a private agreement between the current property owner and, in this situation, EPA, a state, or a federal agency that has transferred or plans to transfer property that has use restrictions. The control is generally authorized by state law. An easement or restrictive covenant prohibiting the extraction of groundwater for drinking water on property containing the contaminated groundwater plume is an example of this type of instrument. There are also direct governmental controls on the use of property, such as zoning laws, building codes, or state, tribal, or local groundwater use regulations. Federal agencies such as the Army may possess the authority to enforce institutional controls on their property, e.g., in Base Master Plans, facility construction review processes, facility digging permit systems, and/ or the facility well permitting systems. The third category of institutional controls are components of enforce- ment instruments or permits issued by federal or state regulators to private or federal PRPs (e.g., administrative orders, permits, Federal Facility Agree- ments, and judicial consent decrees). These legally enforceable instruments may limit site activities or require the performance of specific activities like the monitoring of IC effectiveness. Finally, there are informational devices such as recording site cleanup documents in property records and providing advisories to local communi- ties, tourists, recreational users, or other interested persons that residual contamination remains on-site. Although informational devices are not enforceable, they may be required by an enforceable consent decree or other enforceable instrument. Each type of institutional control has advantages and disadvantages, which revolve around, for example, how the control enables or restricts future economic development, whether the control is enforceable, and at which level of government it is enforced (e.g., zoning is traditionally a function of local government and generally, EPA and federal agencies have little or no direct role in local zoning). Different institutional controls differ with respect to who pays to maintain and enforce the control. At CERCLA-

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IMPLICATIONS OF CONTAMINATION REMAINING IN PLACE 169 funded cleanups, EPA does not pay for monitoring or enforcing institu- tional controls because the statute requires states to ensure the payment of all future routine operations and monitoring following CERCLA-financed remedial actions. However, at sites where private companies or other fed- eral agencies perform the cleanup, they, not the states, pay for monitoring or enforcing institutional controls (see discussion below). The degree to which the public is involved in establishing, monitoring, and ensuring that institutional controls are enforced differs by type (EPA, 2010b), as does the length of time over which the institutional control must be maintained. Past Experience with Institutional Controls Not surprisingly, past experience suggests that institutional controls have been effective at some sites and have failed other sites (ELI, 1999, and see Box 5-1 for three prominent failures). Institutional controls “rely heavily on humans to implement, oversee, and administer them” and it is human “to ignore tasks that no one else seems to care about or where the purpose is not readily apparent and indeed is often buried underground” (ELI, 1999). A specific problem is the fact that zoning requirements can be modified by political bodies (ELI, 1999; Spina, 2008). Furthermore, environmental regulatory agencies may not be able to enforce restrictions on subsequent property owners (Spina, 2008; Probst, 2006), although in- creasingly states have adopted statutes that allow enforcement of land use restrictions on subsequent owners. Finally, where EPA does not regularly consult with local authorities about institutional controls, remedies may be selected, including a specific institutional control, without determining whether it can be implemented by the local government (ELI, 1999; Probst, 2006). The New Emphasis and Direction on Institutional Controls EPA has substantially improved its process of developing, implement- ing, and enforcing institutional controls. Each Superfund facility is sup- posed to have an Institutional Control Implementation and Assurance Plan (ICIAP) “prior to, or at the same time as, the remedial design phase under CERCLA and finalize it with the completion of the response action” (EPA, 2010b), and coordination between states, tribes, and local land use planning jurisdictions is required. Institutional controls at “construction- completion” sites have begun to be recorded within the Superfund Enter- prise Management System to help ensure the long-term effectiveness of the controls (EPA, 2011a). EPA has clarified that institutional control documents and instruments should clearly articulate the substantive restrictions that are needed at a

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170 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES BOX 5-1 Examples of the Failure of Institutional Controls At Love Canal (one the first hazardous waste sites of general public concern), the City of Niagara Falls built a school on a landfill in 1954, even though there was a 1953 deed from a chemical company to the city (i.e., both a proprietary and informational IC) disclosing that chemical production waste was buried on the property and disclaiming responsibility for any injuries that might result (Technical Review Committee, 1988). In the mid-1970s after residential housing was built around the landfill, heavy rain caused the groundwater to mobilize and release the chemicals onto residential properties and into local storm sewers, resulting in the first Presidential Declaration of a man-made national disaster (Technical Review Committee, 1988). At the Cannons Engineering Corporation Superfund facility in Bridgewater, MA, the ROD required that a Declaration of Restrictions (i.e., a proprietary IC) be recorded with the deeds to the affected properties, along with zoning ordinances (a direct governmental control) and public education programs (an informational IC) (ELI, 1999). In 1998, a company, without prior approval of the environmental agencies, excavated soil below the water table, dewatered the excavation, and discharged the water on the property while erecting a telecommunications relay tower, in violation of the Declaration of Restrictions (EPA, 2010c). EPA issued a written notice of violation of the deed restriction to the property owner, lessee, and the Town of Bridgewater. In response, the leases and subleases have been modified (EPA, 2010c). In addition, the Town of Bridgewater has incorporated the deed restriction and the requirement to notify EPA prior to work at the tower into its site plan approval process. The deed restriction currently remains in place and there have been no additional violations. The education program apparently was never carried out because of lack of public interest (ELI, 1999). At the Sharon Steel Superfund facility in Midvale, Utah, the ICs included (1) regulations governing excavations on private property within a residential area where some contaminated soils were left in place (a governmental control) and (2) education programs (ELI, 1999). The education programs were not successful, in large part due to lack of cooperation between the city, state, and EPA (ELI, 1999). As a result, one property owner who did not know about the ordinance began unpermitted construction of a new sewer line, another property owner removed his patio exposing unremediated soils for a day and half until the City learned of the activity, and another property owner and the state Department of Transportation failed to coordinate with state environmental regulators concerning the excavation of a city right of way (ELI, 1999). property to ensure that the land use assumptions that were made as part of the remedy decision continue to remain accurate (EPA, 2011b). Where resi- dential properties are located over a contaminated groundwater plume and the properties are not the source of contamination, well drilling restrictions

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IMPLICATIONS OF CONTAMINATION REMAINING IN PLACE 171 may be put in place to limit the use of groundwater rather than negotiat- ing covenants or easements with a large number of parties (EPA, 2010b). EPA (2010b, 2011b) requires that each institutional control instrument be reviewed annually to consider such things as their long-term effectiveness and enforceability, and whether the property owner/lessee is aware of and complying with the institutional controls when they change land uses, per- form new construction, or transfer the property. Costs EPA recognizes that institutional controls, maintenance, and enforce- ment costs “may extend beyond the 30-year period traditionally used in many response cost calculations,” and that these continuing costs should be acknowledged when developing response cost estimates because they “can be important in evaluating long-term effectiveness” (EPA, 2010b). Indeed, the IC development process should begin with estimating the cost for monitoring and reporting activities over the full life cycle of the control. At Superfund-financed sites (i.e., those without viable PRPs), EPA does not pay for monitoring or enforcing institutional controls because CERCLA Section 104(c)(3) requires states to ensure the payment of all future routine operations and monitoring following remedial actions. At sites where there are viable PRPs or federal RPs, EPA has long negotiated settlement agree- ments or consent orders with such parties, and where necessary obtained a court order, to require a PRP to perform work necessary to achieve and maintain performance standards or the effectiveness of the remedy (e.g., five-year review, additional remedy work, and/or new information or unknown condition reopener consent decree) (EPA, 2006). Recent EPA guidance explicitly directs EPA staff to have the settling parties in such settlement agreements or consent orders gather and submit data and analy- ses about institutional controls in conjunction with requests for monitoring data (EPA, 2011b). Additionally, EPA now recommends the use of direct payments from PRPs, settling party trust funds, surety bonds, letters of credit, insurance, and settlement proceeds to fund site-specific accounts for institutional controls (EPA, 2010b). Federal agencies, including DoD, gen- erally pay for long-term monitoring and perform oversight of institutional controls at their sites (DoD, 2001). *** EPA has improved its institutional control program so that it encour- ages cooperation among federal, state, and local governments; incorporates independent oversight of the entities that implement institutional controls; includes redundancy; mandates monitoring; and increases the amount of

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208 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES por intrusion exposure. In most cases, the cost of building mitigation into new construction is significantly less than the cost of repetitive sampling. Furthermore, such systems reduce exposure to naturally occurring radon. As a precautionary measure, vapor mitigation could be built into all new construction on or near known VOC groundwater plumes; this could be imposed proactively as part of local or state building codes or other re- quirements or imposed as institutional controls at regulated sites. In either situation, vapor mitigation systems require monitoring over the long-term to ensure that they are operating properly. As populations increase and industrial demands for high-quality water also increase, the demands placed on groundwater supplies will increase. Contaminated aquifers have been and may well be used more extensively in the future to augment supplies of uncontaminated water. Wellhead treat- ment may be an optimal remedy for low concentrations of contaminants in potential water supplies. Current wellhead treatment technologies are ma- terials intensive and are not energy efficient. Improved and efficient water treatment technologies should be developed both for more cost-effectively destroying VOCs and recalcitrant organic compounds as well as for remov- ing toxic metals. An emphasis should be placed on technologies that treat a broad spectrum of chemicals. REFERENCES Aitchison, E. W., S. L. Kelley, J. J. Pedro-Alvarez, and J. L. Schnoor. 2000. Phytoremediation of 1,4-dioxane by hybrid poplar trees. Water Environment Research 72(3):313-321. Ando, A. W., M. Khanna, A. Wildermuth, and S. Vig. 2004. Natural Resource Damage Assess- ment: Methods and Cases. Waste Management and Resource Center, Illinois Department of Natural Resources. http://www.istc.illinois.edu/info/library_docs/RR/RR-108.pdf. Army. 2011. Environmental Liabilities. http://aec.army.mil/usaec/cleanup/e100.html. ASTM (American Society for Testing and Materials). 2006. ASTM Standards on Environ- mental Site Assessments For Commercial Real Estate, 5th Edition, which includes ASTM E 1527–00, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, ASTM E1903-11 Standard Practice for Environmental Site As- sessments: Phase II Environmental Site Assessment Process, and ASTM E 1528 Transac- tion Screen Process. ASTM. 2010. ASTM Standard Classification of Environmental Condition of Property Area Types for Defense Base Closure and Realignment Facilities. ATSDR (Agency for Toxic Substances and Disease Registry). 1989. Public Health Statement for n-Nitrosodimethylamine. CAS 62-75-0. Altanta, GA: ATSDR. ATSDR. 2005. Toxicological Profile for Naphthalene, 1-Methylnaphthalene, and 2-Methyl- naphthalene. http://www.atsdr.cdc.gov/toxprofiles/tp67.pdf. ATSDR. 2008. Draft Toxicological Profile for Chromium. http://www.atsdr.cdc.gov/toxpro- files/tp7.pdf.

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