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3
Remedial Objectives, Remedy
Selection, and Site Closure
The issue of setting remedial objectives touches upon every aspect and
phase of soil and groundwater cleanup, but none perhaps as important as
defining the conditions for “site closure.” Whether a site can be “closed”
depends largely on whether remediation has met its stated objectives, usu-
ally stated as “remedial action objectives.” Such determinations can be
very difficult to make when objectives are stated in such ill-defined terms as
removal of mass “to the maximum extent practicable.” More importantly,
there are debates at hazardous waste sites across the country about whether
or not to alter long-standing cleanup objectives when they are unobtainable
in a reasonable time frame. For example, the state of California is closing a
large number of petroleum underground storage tank sites that are deemed
to present a low threat to the public, despite the affected groundwater not
meeting cleanup objectives (California State Water Quality Control Board,
2010; Doyle et al., 2012). In other words, some residual contamination
remains in the subsurface, but this residual contamination is deemed not to
pose unacceptable future risks to human health and the environment. Other
states have pursued similar pragmatic approaches to low-risk sites where
the residual contaminants are known to biodegrade over time, as is the
case for most petroleum-based chemicals of concern (e.g., benzene, naph-
thalene). Many of these efforts appear to be in response to the slow pace of
cleanup of contaminated groundwater; the inability of many technologies
to meet drinking water-based cleanup goals in a reasonable period of time,
particularly at sites with dense nonaqueous phase liquids (DNAPLs) and
complicated hydrogeology like fractured rock; and the limited resources
available to fund site remediation.
75
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76 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES
This chapter focuses on the remedial objectives dictated by the common
regulatory frameworks under which groundwater cleanup generally occurs.
It first describes the phases of cleanup for the primary federal programs and
their milestones, the gaining of which is often used as a metric of progress
and ultimately success. The Comprehensive Environmental Response, Com-
pensation, and Liability Act (CERCLA) and the Resource Conservation
and Recovery Act (RCRA) guidance outline criteria for setting remedial
objectives and points of compliance, and for selecting remedies to meet
them. The chapter closes with a discussion of alternative strategies to ad-
dress the current limitations on achieving groundwater restoration, such as
CERCLA Technical Impracticability waivers for some portion of the site.
This includes sustainability concepts that have become relevant to decision
making regarding remedy selection and modification in the past few years.
The topic of setting cleanup objectives has a long history and was a
significant component of the debates in the 1980s during the passage of
the Superfund Amendments and Reauthorization Act (SARA) in 1986 and
the establishment of the ARAR process in Section 121 of SARA. Several
National Research Council (NRC) reports (1994, 2005) have provided
insights and recommendations on improving the process of establishing
objectives for groundwater cleanup. The DoD has also provided recom-
mendations for setting objectives through reports published through the
Environmental Security Technology Certification Program (e.g., Sale and
Newell, 2011). Recently the Interstate Technology and Regulatory Council
(ITRC) provided a comprehensive guidance document on setting objec-
tives for remediation at DNAPL sites (ITRC, 2011). All these efforts have
informed this overview of the objective setting process, which considers
how that process might evolve in light of advances in our understanding of
technical limitations to aquifer restoration.
THE CLEANUP PROCESS AND ASSOCIATED OBJECTIVES
The current regulatory framework for remediation of hazardous waste
sites evolved from a complex collection of federal, state, tribal, and even
local statutes, regulations, and policies. CERCLA and RCRA are the two
federal programs that govern most subsurface cleanup efforts, and most
state programs are similar to or even authorized under these federal models.
CERCLA
CERCLA provides federal authority for cleanup of sites with hazardous
substances, usually excluding petroleum-only sites. At sites with no viable
responsible party, EPA can fund remedial activities from the Superfund—a
special account initially funded by a tax on petroleum and chemical compa-
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REMEDIAL OBJECTIVES, REMEDY SELECTION, AND SITE CLOSURE 77
nies, but presently derived from general tax revenues. However, at a major-
ity of sites, the response is funded by private parties, either through a legally
binding agreement to perform the remedy (e.g., an Administrative Order of
Consent) or by reimbursing EPA for its remedial costs. At federal facilities
cleanup is funded by the agency responsible for releasing contamination.
Initial Phases
A site regulated through CERCLA generally progresses through the
Preliminary Assessment/Site Inspection, listing on the National Priorities
List (NPL), site investigation (Remedial Investigation), remedial alternative
assessment (Feasibility Study), remedy selection (Record of Decision), re-
mediation implementation (remedial design followed by construction), and
long-term monitoring and institutional controls until the site media con-
centrations are at or below unrestricted use levels (see Table 2-3). If there is
an immediate threat to human health or the environment (“imminent and
substantial endangerment”), the Preliminary Assessment/Site Inspection
may trigger an interim emergency response.
The Remedial Investigation consists of detailed site characterization,
while the Feasibility Study incorporates the evaluation of remedial alterna-
tives that might meet remedial action objectives. The Remedial Investiga-
tion and Feasibility Study may be conducted concurrently, and, in any case,
they influence each other. The Remedial Investigation generally includes a
human health risk assessment and the determination of site-specific reme-
dial action objectives. The Feasibility Study develops a series of remedial al-
ternatives that describe the placement, timing, and remedial technology for
cleanup activities, and it includes a detailed comparison of these alternatives
with respect to criteria established under CERCLA regulations (see below).
Setting of Cleanup Goals and Selection of Remedies
CERCLA’s overarching groundwater remediation goal is to restore
groundwater to its “beneficial use” “wherever practicable” (EPA, 2009a).
A common beneficial use of groundwater, if conditions are appropriate, is
that it be a source of drinking water. In addition, the groundwater plume
“should not be allowed to migrate and further contaminate the aquifer or
other media (e.g., vapor intrusion into buildings; sediment; surface water;
or wetland)” (EPA, 2009a).
The alternative remedial strategies in the Feasability Study are evalu-
ated based on a balancing of the nine criteria of the National Oil and Haz-
ardous Substances Pollution Contingency Plan, usually called the National
Contingency Plan (EPA, 1990):
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78 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES
1. Overall protection of human health and the environment (a thresh-
old criterion that must be met by the chosen remedy)
2. Compliance with applicable or relevant and appropriate require-
ments (ARARs) (also a threshold criterion)
3. Long-term effectiveness and permanence (a balancing criterion)
4. Reduction of toxicity, mobility, or volume (a balancing criterion)
5. Short-term effectiveness (a balancing criterion)
6. Implementability (a balancing criterion)
7. Cost (a balancing criterion)
8. State acceptance (modifying criterion that is considered but not re-
quired to be met or balanced)
9. Community acceptance (modifying criterion)
Threshold Criteria. The first two criteria, called threshold criteria,
must be met by the chosen remedy. The criterion “protective of human
health” is sometimes embodied in a quantitative risk assessment and has
been interpreted as having a calculated excess lifetime cancer risk between
10–6 and 10–4 or a hazard index < 1.0.1 “Protective of the environment” is
less clearly defined.
At most Superfund facilities with groundwater contamination, federal
and state drinking water standards (such as maximum contaminant levels,
MCLs, and non-zero maximum contaminant level goals) are established
as ARARs and hence the groundwater cleanup goals. The designation of a
drinking water standard as an ARAR is often independent of whether the
particular groundwater is, in fact, currently used as a source of drinking
water or is likely to be so used in the future, as long as it is capable of being
used as a source of drinking water.
There is considerable variability in how EPA and the states consider
groundwater as a potential source of drinking water. EPA has defined
groundwater as not capable of being used as a source of drinking water if
(1) the available quantity is too low (e.g., less than 150 gallons per day can
be extracted), (2) the groundwater quality is unacceptable (e.g., greater than
10,000 ppm total dissolved solids, TDS), (3) background levels of metals or
radioactivity are too high, or (4) the groundwater is already contaminated
by manmade chemicals (EPA, 1986, cited in EPA, 2009a). California, on the
other hand, establishes the TDS criteria at less than 3,000 ppm to define a
“potential” source of drinking water. And in Florida, cleanup target levels
1 The hazard index (HI) is “the sum of more than one hazard quotient for multiple sub-
stances and/or multiple exposure pathways. The HI is calculated separately for chronic, sub-
chronic, and shorter-duration exposures.” The hazard quotient is “the ratio of an exposure
level to a substance to a toxicity value selected for the risk assessment for that substance (e.g.,
LOAEL or NOAEL)” http://www.epa.gov/oswer/riskassessment/glossary.htm.
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REMEDIAL OBJECTIVES, REMEDY SELECTION, AND SITE CLOSURE 79
for groundwater of low yield and/or poor quality can be ten times higher
than the drinking water standard (see Florida Administrative Code Chapter
62-520 Ground Water Classes, Standards, and Exemptions). Some states
designate all groundwater as a current or future source of drinking water
(GAO, 2011). Although EPA generally defers to state or local groundwater
classifications on these issues (EPA, 2009a), EPA policy recognizes that less
stringent cleanup levels may be appropriate for groundwater that is not
a current or reasonably expected future source of drinking water (GAO,
2011).
In addition to federal ARARs, states may propose requirements as
state ARARs, subject to EPA acceptance. There is considerable variability
between federal and some state ARARs, even for the same chemicals or
situation, as described in Box 3-1. Table 3-1 demonstrates that the MCL
for an individual compound can range over more than an order of mag-
nitude, with some states being much more stringent than EPA. There are
multiple reasons for these differences including differences in risk targets,
different interpretations of technical feasibility, and different interpretations
of toxicological findings.
Another example of variability among EPA and the states concerns the
point of compliance. EPA has long directed that the point of compliance
monitoring of the final cleanup levels for contaminated groundwater can
apply “at and beyond the edge of the waste management area when waste
is left in place” (EPA, 1988a, 1990, 1991a). (Note that the drinking water
standard in this situation still defines whether the groundwater within the
source area may be subject to unrestricted use.) At landfills the application
of this policy is relatively straightforward, while at sites where DNAPL has
migrated from the original area of release the application of this strategy
may be more uncertain.2 On the other hand, some states require that all
points within a contaminated aquifer meet the state ARAR. All this vari-
ability can lead to different remedial objectives, different decisions about
the chosen remedy, and different long-term outcomes.
Although the most commonly used ARAR, it is noteworthy that MCLs
are not based on consideration of the vapor intrusion pathway, suggesting
that there can be limitations to relying on ARARs based solely on drinking
water ingestion in making decisions regarding remediation of groundwater
contamination. Vapor intrusion is discussed further in Chapters 5 and 6.
Balancing Criteria. On a case-by-case basis, the remedy selection crite-
ria (particularly the balancing criteria) are “balanced in a risk management
2 DNAPL may migrate within the area of waste management. At some CERCLA sites, the
edge of the waste management area has been “flexibly applied,” while at others the edge of
the waste management area has been “rigorously applied.”
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80 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES
BOX 3-1
State/Federal Differences in Goals for Groundwater Restoration
The differences between state and federal goals for groundwater restoration
often hinge on the present and expected future use of the groundwater in ques-
tion. However, even if the defined use of the groundwater is for drinking, there can
still be differences in the actual numeric goals. This is because states have the
option of developing their own, more restrictive MCLs that will replace the EPA’s
MCL as the enforceable limit. Examples for different chemicals are given in Table
3-1, which provides a sense of the potential magnitude of state/federal differences
but is not meant to be comprehensive.
In some cases, the difference between the federal MCL and the state MCL
is more than an order of magnitude. For example, the federal drinking water limit
for cis-1,2-dichloroethene (cis-1,2-DCE) is 70 ppb (1 ppb = 1 μg/L), whereas the
California standard is 6 ppb. Both values are based on non-cancer liver toxicity in
animals, with the differences mainly due to varying interpretations of toxicological
findings. As another example, the federal MCL for carbon tetrachloride is 5 ppb,
whereas the California standard is 0.5 ppb. Both carbon tetrachloride standards
had similar conclusions regarding liver cancer in rodents as the critical endpoint.
The differences for carbon tetrachloride are related to measurement feasibility and
determination of the practical quantitation limit, rather than to differences in the
underlying risk assessment (CalEPA, 2000).
In some cases, there are chemicals for which there are state standards but no
federal standards. One example is perchlorate, where the Massachusetts standard
is 2 ppb and the California standard is 6 ppb. Although both states chose the
same toxicological study as the basis for establishing these limits, Massachusetts
adopted a more conservative approach, both with respect to interpretation of the
underlying human exposure study by Greer and coworkers (Zewdie et al., 2010),
as well as with application of uncertainty factors to derive the non-cancer toxic-
ity criterion (i.e., the reference dose or RfD). In addition, Massachusetts applied
different assumptions regarding drinking water intake and other sources of per-
chlorate. Although the calculated health-based value for Massachusetts was 0.49
ppb, the state chose 2 ppb for risk management purposes to minimize compliance
issues. In contrast, the California health-based value of 6 ppb is the same as the
standard.
The reasons for differences in drinking water limits are varied and include the
application of different toxicity studies to establish underlying health-based values,
differences in application of uncertainty factors, variations in selection of exposure
assumptions, and differences in risk management considerations. In some cases,
the differences reflect the date when a standard was set, and does not always
incorporate the new information that has become available for the more recent
standard.1 State/federal differences in drinking water limits may result in different
levels of cost effectiveness and health protectiveness of remedial decisions across
sites, as well as present risk communication challenges.
1 Dueto lack of consideration of technical feasibility, advisory values can lower than mandated
values, but they are not mandatory.
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REMEDIAL OBJECTIVES, REMEDY SELECTION, AND SITE CLOSURE 81
judgment as to which alternative provides the most appropriate solution
for the site” (EPA, 1990). Under CERCLA, there is a preference for a
permanent solution; indeed, EPA “expects to use treatment to address the
principal threats3 posed by a site, wherever practicable” (EPA, 1996a).
However, there is “nothing in CERCLA §121 to suggest that selecting per-
manent remedies is more important than selecting cost-effective remedies”
(Ohio v. EPA, 997 F.2d 1520, 1533, D.C. Cir. 1993). Rather, the emphasis
on permanent solutions and treatment is balanced by the co-equal mandate
that remedies be cost-effective through the addition of the wording to the
maximum extent practicable (EPA, 1996a) (see Box 3-2). EPA believes
that “certain source materials are generally addressed best through treat-
ment because of technical uncertainties regarding the long-term reliability
of containment of these materials, and/or the consequences of exposure
should a release occur,” while other source materials generally can be reli-
ably contained (EPA, 1996a).
An issue discussed in Chapter 7 but introduced here is that of the dis-
count rate and its role in remedy selection in addressing one of the nine
NPL criteria, namely cost effectiveness. During the feasibility study, cost
estimates are developed for each remedial option to identify their relative
cost effectiveness. Once costs are identified and quantified for each remedial
option, they are discounted to a present value to adjust for differing annual
costs across options. For example, some remedies may have large costs in
the near future and other remedies may have large costs in the distant fu-
ture; discounting is a mechanism to compare the costs of remedial options
using a common dollar metric. The logic for discounting is that if firms
were able to invest these funds they would earn a positive rate of return in
the future, which means that expenditures in the present have a higher cost
than expenditures in the future.
Currently, the annual cost of each option in EPA feasibility studies for
private parties is discounted to present values using a presumptive value of
7 percent, which EPA argues reflects the long-term return to private capital
in the United States (OMB, 2003; EPA and USACE, 2000; EPA, 2010a).
Discount rates from Appendix C of OMB Circular A-94 (OMB, 2012),
which currently are significantly lower than 7 percent, are generally used
for all federal facilities.
Under the current approach to discounting, options with costs in the
distant future will have lower present values than options with front-loaded
costs. For example, with the discount rate of 7 percent, $1 next year is
worth about 94¢ today and $1 in 50 years is worth about 3¢ when dis-
3 In addition to drum wastes and other similar source material, principal threats are where
the toxicity and mobility of the source material combine to present an ingestion risk of greater
than 10–3 (EPA, 1991c).
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82 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES
TABLE 3-1 Examples of State versus Federal Maximum Contaminant
Levels
cis-1,2- 1,2,3-Trichloro-
Tetrachloroethene Trichlorethene Dichloroethene propane
Name (PCE) (TCE) (cis-1,2-DCE) (1,2,3-TCP)
U.S. EPA 5 ppb 5 ppb 70 ppb n/a
California 5 ppb 5 ppb 6 ppb n/a
(state MCL)
Florida 3 ppb 3 ppb 70 ppb n/a
(state MCL) (state MCL)
Massachusetts 5 ppb 5 ppb 70 ppb n/a
New Jersey 1 ppb 1 ppb 70 ppb n/a
(state MCL) (state MCL)
New York 5 ppb 5 ppb 5 ppb 5 ppb
(state MCL) (state MCL)
aEPA interim advisory level for perchlorate is 15 ppb.
bThe Massachusetts MCL “is directed at the sensitive subgroups of pregnant women,
infants, children up to the age of 12, and individuals with hypothyroidism. They should not
consume drinking water containing concentrations of perchlorate exceeding 2 ppb. MassDEP
[Massachusetts Department of Environmental Protection] recommends that no one consume
counted to the present. Thus, a cost-efficiency determination tends to favor
selection of options that have larger costs in the future and lower near-term
costs. Pump and treat, in particular, is an option that discounting favors
because the remedy might operate for decades and the present-value calcu-
lation indicates the costs of this operation beyond 50 years is $0. A lower
discount rate, such as the 3 percent social rate for public projects, would
increase the present value of $1 in 50 years to 23¢ today, but it is still likely
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REMEDIAL OBJECTIVES, REMEDY SELECTION, AND SITE CLOSURE 83
Carbon
Tetrachloride Perchlorate Source Internet URL
5 ppb n/aa National http://www.epa.gov/
Primary safewater/contaminants/
Drinking Water index.htm#listmcl
Regulations
0.5 ppb 6 ppb State Code of http://www.cdph.ca.gov/
(state MCL) (state MCL) Regulations certlic/drinkingwater/
(Chapter 15, Documents/Lawbook/dw-
Title 22, Articles regulations-01-01-2009.
4 and 5.5) pdf
3 ppb n/a State Code of http://www.dep.state.
(state MCL) Regulations fl.us/legal/Rules/
(Chapter drinkingwater/62-550.pdf
62-550)
5 ppb 2 ppb 2008 Standards http://www.mass.gov/dep/
(state MCL)b and Guidelines water/drinking/standards/
for Contaminant dwstand.htm
in Mass.
Drinking Water
2 ppb n/a State Code of http://www.state.
(state MCL) Regulations nj.us/dep/watersupply/
(N.J.A.C. 7:10) sdwarule.pdf
5 ppb n/a State Code of http://www.health.state.
Regulations ny.us/environmental/
(Part 5, Subpart water/drinking/part5/
5-1) tables.htm
water containing perchlorate concentration greater than 18 ppb” (http://www.mass.gov/dep/
water/drinking/standards/dwstand.htm).
SOURCE: Modified, with permission, from Julie Blue, Cadmus Group, Inc. (2009).
that the alternative with higher future costs would be selected over options
with high costs in the near future.
Most economists agree that discounting is necessary, because to not
discount would overlook the differential time paths of costs across rem-
edy options. There is a long-standing debate over what discount rate is
appropriate for use in environmental cases where the costs may be inter-
generational. While it is beyond the Committee’s charge to opine on the
appropriate discount rate, discounting should be considered very carefully
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84 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES
BOX 3-2
Guidance on Definition and Application of
“Maximum Extent Practicable”
The Committee was charged with answering the question: what should be
the definition of “to the extent practicable” when discussing contaminant mass
removal. Terms like “maximum extent practicable (MEP),” “to the extent practical,”
“practicability,” etc., are routinely heard when discussing what can be achieved
during groundwater remediation. For example, EPA groundwater remediation guid-
ance, which applies to all EPA non-UST cleanup programs, repeatedly states that
EPA’s goal is to attain drinking water standards “wherever practicable.” The UST
regulations 40 CFR 280.64, which apply only to light nonaqueous phase liquid
(LNAPL), requires removal of free product “to the maximum extent practicable”
as determined by the implementing agency at sites where free product is pres-
ent. These terms are not defined explicitly or quantitatively in the federal or state
statutes, regulations, or settlements and administrative orders that dictate reme-
diation requirements for soil and groundwater. That is, statements as explicit as
“70% reduction in concentration” or “removal of mobile DNAPL” are not provided
as definitions of “maximum extent practicable.”
The main statutory reference to the term “maximum extent practicable” is found
in CERCLA in reference to practicability during remedy selection, where practi-
cability reflects a balancing of the nine criteria specified in the NCP (EPA, 2009a,
p. 4, footnote 9). EPA guidance states that CERCLA’s emphasis on permanent so-
lutions and treatment should be balanced by “the co-equal mandate for remedies
to be cost-effective” through the addition of the wording “to the maximum extent
practicable” (EPA, 1996a). EPA considers cost to be relevant to technical imprac-
ticability because that term is “ultimately limited by cost,” although EPA policy is
that cost should generally play a subordinate role in a technical impracticability
determination unless compliance would be “inordinately costly” (EPA, 1996a).
For this limited use of the term “maximum extent practicable,” an explicit defini-
tion is already available. EPA has concluded that treatment is not practicable when
in the weighing of alternatives along with the other four National Contin-
gency Plan (NCP) balancing criteria listed above. Specifically for projects
whose duration exceeds 30 years, EPA and the Army Corps of Engineers
(2000) recommend that the present value analysis include a “no discount-
ing” scenario to demonstrate (for comparison purposes only) the impact
of the discount rate on the total present value cost of the remedy and the
relative amounts of future annual expenditures.
Modifying Criteria. Normally the lead agency evaluates a number of
remedial alternatives against the first seven criteria and presents that evalu-
ation, designating a preferred alternative to the public (i.e., community
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REMEDIAL OBJECTIVES, REMEDY SELECTION, AND SITE CLOSURE 85
(1) “treatment technologies are not technically feasible or are not available within
a reasonable time frame;” (2) “the extraordinary volume of materials or complex-
ity of the site may make implementation of the treatment technologies impracti-
cable;” (3) “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 be otherwise addressed through implementa-
tion measures);” or (4) “implementation of the treatment technology would have
severe effects across environmental media” (EPA, 1997a). As an example of the
second item above, the use of containment as a presumptive remedy for municipal
landfills (EPA, 1997b) means that removal of waste from source areas in those
situations can be interpreted as generally not practicable. This case-by-case ap-
plication of the concept of practicability has been upheld in several court cases
[State of Ohio v. U.S. Env’l’t Prot. Agency, 997 F.2d. at 1532 and U.S. v. Ottati &
Goss, Inc., 900 F.2d 429 (1st Cir. 1990) (opinion by now Supreme Court Justice
Breyer)]. Thus, as long as the remedy is chosen in accordance with the NCP and
is performing in accordance with reasonable environmental engineering practices,
that is the end of decision making with respect to what is practicable for remedy
selection.
The term “maximum extent practicable” is often used informally as a measure
of remediation progress even though it has no regulatory bearing in that context.
In Chapter 7, the Committee suggests that remedies at complex sites be regularly
assessed to determine whether they are being implemented in a manner consis-
tent with good environmental engineering practice and their resulting performance.
If a remedy reaches a point where continuing expenditures bring little or no reduc-
tion of risk prior to attaining drinking water standards, the Committee recommends
that there should be a reevaluation of the future approach to cleaning up the site
(called a Transition Assessment). When this point is reached, the chosen active
remedy can be said, de facto, to have been operated to the “maximum extent
practicable.”
stakeholders) in the form of a Proposed Plan. With regard to the two final,
modifying criteria, neither the state nor the community have the legal au-
thority to “veto” a remedy. The provision does mean that the lead agency
must engage in a formal community involvement process and, at each NPL
facility, provide a technical assistance grant to one eligible nongovernmen-
tal organization to hire an independent technical consultant to advise the
community. EPA recognizes about 70 Community Advisory Groups at NPL
facilities across the country. From 1988 to 2010, 323 technical advisory
grants have been awarded (205 providing $50,000 or less and 15 providing
a total of more than $250,000) (Catalogue of Federal Domestic Assistance,
2011). Following the public comment period, the lead agency selects a rem-
edy and memorializes it in a Record of Decision.
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102 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES
of the transaction costs associated with the process, or because of future
litigation risks should residual contamination persist (see Chapter 5).
Sustainability as a Cleanup Objective
The historic definition of sustainable is “[d]evelopment that meets the
needs of the present without compromising the ability of future generations
to meet their own needs” (Brundtland, 1987). According to the Bruntd-
land report (1987), the most “sustainable” policies address environmental,
economic, and social aspects of a problem (the so-called triple bottom-line
approach)—a definition much broader than that encompassed by the fed-
eral and state hazardous waste laws. If sustainability is to be a remedial
goal, this broad policy definition needs to be translated into concrete direc-
tion on how to clean up a site “sustainably.”
Incorporating sustainability concepts into remediation decision making
is a developing, but still incomplete, practice at EPA and other agencies.
EPA, DoD, the states, and others have “green” or sustainable remediation
policies (DoD, 2009; Army Corps of Engineers, 2010; EPA, 2008; ITRC,
2011). All ten EPA Regions have adopted Clean and Green policies for
contaminated sites, generally with green remediation goals including to
minimize total energy use and to reduce, reuse, and recycle materials and
wastes (EPA, 2011e). However, “green” remediation and even some of
these agency guidance documents that use the word “sustainability” do
not include all of the elements of sustainability found in the Brundtland
report. For example, EPA’s definition of green remediation is the “practice
of considering all environmental effects of remedy implementation and
incorporating options to minimize the environmental footprints of cleanup
actions” (EPA, 2011e). This is narrower than the concept of sustainable re-
mediation as “balance[ing] outcomes in terms of the environmental, social,
and economic elements of sustainable development” (see Table 3-3 below
and Bardos et al., 2011; NRC, 2011). In fact, some argue that sustainable
decisions should consider community improvements, jobs, and quality of
life, and the benefits to the surrounding community (NRC, 2011). Several
examples of sustainable remediation that illustrate the range of concepts
that can be incorporated are given in Box 3-3.
Each of the Sustainable Remedy Selection environmental factors listed
in Table 3-3 (i.e., column 1), and some of the social and economic factors
(columns 2 and 3), fit into the standard EPA and state remedy selection
criteria. For example, impacts on human health and safety (a social fac-
tor), impacts on various environmental media and natural resources, and
community involvement can be assessed under existing remedy selection
schemes. However, ethical and equity considerations, indirect economic
costs and benefits, and employment and capital gain (among others) are
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REMEDIAL OBJECTIVES, REMEDY SELECTION, AND SITE CLOSURE 103
TABLE 3-3 Sustainable Remedy Selection Factors
Environmental Social Economic
1. Impacts on air (including 1. Impacts on human health 1. Direct economic
climate change) and safety costs and benefits
2. Impacts on soil and 2. Ethics and equality 2. Indirect economic
ground condition 3. Impacts on neighborhood costs and benefits
3. Impacts on groundwater and locality 3. Employment and
and surface water 4. Communities and employment capital
4. Impacts on ecology community involvement 4. Induced economic
5. Use of natural resources 5. Uncertainty and evidence costs and benefits
and waste 5. Project lifespan and
flexibility
SOURCE: Adapted, with permission, from CL:AIRE (2011).
not explicitly provided for in any cleanup statute or existing programs.
Many of these broader societal factors could be taken into account at fed-
eral facilities if the government decided to expend its own funds, but they
are likely to be difficult to include as enforceable requirements on private
sector decision making without amendments to existing cleanup statutes.
Industry groups are currently driving sustainable remediation efforts.
For example, approximately 87 percent of the largest companies in the
Drugs and Biotechnology, Household and Personal Products, and Oil and
Gas Operations sectors have environmental sustainability programs, ac-
cording to a survey of the five largest U.S. companies in each of the 26
industrial sectors (Cowan et al., 2010). Most companies develop their own
sustainability policies based on their sector, stakeholder interests, products
or services, and business model. In the hazardous waste arena, the leader in
sustainability is the Sustainable Remediation Forum (or SURF, http://www.
sustainableremediation.org), which includes industry, government agencies,
environmental groups, consultants, and academia. The SURF approach,
described in greater detail below, advises that one “should balance the
level of sustainability analysis in accordance with the budget and available
resources” (Holland, 2011; Ellis and Hadley, 2009).
A Method for Estimating Sustainability
There are a variety of potential methods for including sustainability
factors in selecting a remedy, but none are generally accepted and no U.S.
regulatory agency has formally adopted a methodology. The SURF Frame-
work (Holland, 2011) “provides a systematic, process-based, holistic ap-
proach for: (1) performing a tiered sustainability evaluation, (2) updating
the conceptual site model (CSM) based on the results of the sustainability
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104 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES
BOX 3-3
Examples of Sustainability in Hazardous Waste Remediation
There are a number of clear examples of hazardous waste site remediation
where sustainability is being taken into consideration in the remedy selection
process.
One example is the Bell Landfill NPL site in northern Pennsylvania. Large
trucks were previous used to carry landfill leachate to a wastewater treatment
plant with the proper permit—a 640-km road trip. Chemical analysis of the leach-
ate showed that the only remaining components were dissolved iron and man-
ganese. Now, a spray irrigation system is used to distribute the leachate onto
the landfill cap, which is covered with grass. As a result, the grass on the cap no
longer dies during the summer, and the local unpaved roads are no longer im-
pacted by the heavy truck traffic during wet weather. Changing how the leachate
was disposed of also avoided the release of about 3,400 tons of CO2.
At the Brevard, NC, polymer recycling site, off-spec films were previously
disposed of in an industrial landfill that contains up to 80,000,000 pounds of PET.
They are now being excavated, inspected, and shipped to China where the mate-
rial is being recycled (the final use of the material is not known). Once the project
is complete, the landfill will be converted into parkland and deeded to the State
Forest. This is an example of resource recovery and recycling, leading to lower
greenhouse gas emissions (which could be as much as 100,000 tons of CO2).
Note that the life-cycle assessment for this project included all of the impacts as-
sociated with shipping the materials to China.
Another example of sustainability in site remediation is at DuPont’s Chambers
Works site—a 146-acre landfill with about 10 million tons of waste. Three remedia-
tion options were evaluated: excavation, stabilization, and bioremediation. Qualita-
tive consideration of a number of factors, including the amount of CO2 produced,
led to the choice of bioremediation. Using bioremediation instead of excavation
was predicted to reduce potential emissions by over 2,500,000 tons of CO2, avoid
odor problems in the adjacent community, and avoid the need for round-the-clock
intense lighting and heavy equipment operation, which would disturb nearby
residents.
At a Naval Air Station Superfund facility in Weymouth, Massachusetts, EPA
modified an excavation remedy to allow reuse of the soil as a subgrade fill layer
rather than disposing of the soil offsite, which “significantly reduced energy con-
sumption associated with truck trips for off-site disposal and importing common
fill and allowed for the beneficial reuse of the excavated materials in a manner
which is protective of human health and the environment.” Emissions of regulated
air pollutants were also reduced (EPA, 2010d).
The Reichhold Chemical Site is a former paint and coatings manufacturer
located south of downtown Chicago. The site was redeveloped following RCRA
clean closure that left no residual contamination on the site. Two large retail stores
were opened on this formerly abandoned site, and 500 new inner city jobs were
created. In addition to the obvious economic benefits, there is also the social ben-
efit of having major retailers in the community; residents previously had to drive
over 10 miles to find comparable services.
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REMEDIAL OBJECTIVES, REMEDY SELECTION, AND SITE CLOSURE 105
evaluation, (3) identifying and implementing sustainability impact mea-
sures, and (4) balancing sustainability and other considerations during the
remediation decision-making process.”
The SURF approach includes a series of separate toolkits (organized
into tables) for the investigation, remedy selection, remedial design and
construction, and operation and maintenance phases of site cleanup. For
each phase, the team identifies parameters, objectives, metrics, and benefits
and challenges to applying these metrics to each phase of the remediation
(Butler et al., 2011). For example, the project team and stakeholders re-
view which of the potential sustainability parameters (i.e., consumables,
physical disturbances and disruptions, land stagnation, air impacts, water
impacts, solid wastes, job creation, and remediation labor) are appropriate
for consideration at a particular site (see Butler et al., 2011). For each of
the relevant parameters, the team identifies the applicable objectives, the
metrics for measuring the achievement of each objective, the benefits that
are likely to be derived, and challenges of using this parameter for each
remedy being considered for the site. The team considers these factors,
benefits, and tradeoffs explicitly in the table. The results obtained during
this exercise are balanced with project considerations to determine the most
appropriate remedy.
Critical to the implementation of the SURF approach is the preferred
future use of the site, including consideration of (a) local laws, ordinances,
and deed restrictions; (b) the end use of the site and the likely future devel-
opment around the site; (c) the capacity to establish and maintain necessary
institutional controls; (d) potential liabilities and community needs; and (e)
long-term technical and environmental issues (Holland, 2011).
Legal Basis for Considering Sustainability
As mentioned previously, sustainability criteria are not included explic-
itly in CERCLA or RCRA guidance on remedy selection or modification
(e.g., the feasibility study guidance, EPA, 1988b). Consideration of social
factors (such as jobs or the economic well-being of a community) is not
traditionally within the statutory authority of environmental regulators
and is particularly difficult to envision. For example, if consideration of
the impact on job creation for each remedial alternative were required, the
result could be that the most expensive remedy is chosen since it is likely
to create more jobs. Similarly, if job creation is considered on a site-specific
basis, it may be necessary to evaluate the net gain or loss of jobs caused by
the devotion of a company’s capital to remediation versus expanding their
production or other economic activities.
Such dramatic changes in remedy selection criteria are more appro-
priately adopted by statute (i.e., create a tenth criterion and specify how
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106 MANAGING THE NATION’S CONTAMINATED GROUNDWATER SITES
social factors are to be weighed on a site-specific and remedy-specific ba-
sis). More detailed direction than can be found in SURF guidance will be
necessary concerning how to balance social factors, economic factors, and
environmental factors. Absent a statutory basis (either federal or state),
regulators cannot require a more costly remedy than a remedy that is
consistent with the current statute and regulations. Of course, potentially
responsible parties including the military may decide voluntarily to imple-
ment a remedy that goes beyond what might be selected by application of
the nine remedy selection factors, based on a general good neighbor policy
or adoption of a policy such as sustainable development. There is greater
incentive to use sustainability factors in remedy selection when the costs of
the remedial alternatives are similar. However, a more sustainable remedy
is not necessarily a less expensive one. Thus, it remains to be seen whether
implementation of more sustainable remedial alternatives will be feasible
at hazardous waste sites.
CONCLUSIONS AND RECOMMENDATIONS
At most hazardous waste sites in the United States, meeting drink-
ing water standards is the long-term goal of remediation. Unfortunately,
drinking water MCLs will not likely be met in many affected aquifers for
decades, especially at complex sites. Fortunately, EPA’s current remedia-
tion guidance provides flexibility within the remedy selection process in a
number of ways, although there are legal and practical limits to this flex-
ibility. The following conclusions and recommendations discuss the value
of exploring goals and remedies based on site-specific risks, sustainability,
and other factors.
By design (and necessity), the CERCLA process is flexible in (a) deter-
mining the beneficial uses of groundwater; (b) deciding whether a regula-
tory requirement is an ARAR at a site; (c) using site-specific risk assessment
to help select the remedy; (d) using at least some sustainability factors to
help select the remedy; (e) determining what is a reasonable timeframe to
reach remedial goals; (f) choosing the point of compliance for monitoring;
and (g) utilizing alternate concentration limits, among others. These flexible
approaches to setting remedial objectives and selecting remedies should be
explored more fully by state and federal regulators, and EPA should take
administrative steps to ensure that existing guidance is used in the appropri-
ate circumstances. Often the same level of protection can be attained for
lower costs by exercising this flexibility.
To fully account for risks that may change over time, risk assessment
at contaminated groundwater sites should compare the risks from taking
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REMEDIAL OBJECTIVES, REMEDY SELECTION, AND SITE CLOSURE 107
“no action” to the risks associated with the implementation of each reme-
dial alternative over the life of the remedy. Risk assessment at complicated
groundwater sites is often construed relatively narrowly, with an emphasis
on risks from drinking water consumption and on the MCL. Risk assess-
ments should include additional consideration of (a) short-term risks that
are a consequence of remediation; (b) the change in residual risk over time;
(c) the potential change in risk caused by future changes in land use; and
(d) both individual and population risks.
Progress has been made in developing criteria and guidance concern-
ing how to consider sustainability in remedy selection. However, in the
absence of statutory changes, remedy selection at private sites regulated
under CERCLA cannot consider the social factors, and may not include
the other economic factors, that fall under the definition of sustainability.
At federal facility sites, the federal government can choose, as a matter of
policy, to embrace sustainability concepts more comprehensively. Similarly,
private companies may adopt their own sustainable remediation policies in
deciding which remedial alternatives to support at their sites. New guidance
is needed from EPA and DoD detailing how to consider sustainability in
the remediation process to the extent supported by existing laws, including
measures that regulators can take to provide incentives to companies to
adopt more sustainable measures voluntarily.
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