Alternatives for Ground Water Cleanup (1994) / Chapter Skim
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7 Policy Implications of a Technical Problem
7 Policy Implications of a Technical Problem
Pages 255-274
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From page 255... ...
It then reviews the key evolving policies relevant to sites where technical limitations prevent the achievement of ground water cleanup goals. Finally, the chapter summarizes the committee's recommendations for improving ground water cleanup policies to reflect the limits of technology.
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From page 256... ...
A key example of a policy statement pertaining to ground water cleanup is a 1992 memorandum directing EPA employees on how to manage sites where dense nonaqueous-phase liquid (DNAPL) contaminants are preventing the achievement of ground water cleanup goals (Clay, 1992~.
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From page 257... ...
Consequently, the policies for regulating sites where health-based cleanup goals may be unachievable are still evolving and have not yet been uniformly applied. The EPA has four types of policies addressing, at least in part, the possibility that existing technology may be unable to achieve current goals for ground water cleanup.
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From page 258... ...
For example, some groups representing companies responsible for cleanup have identified as a key barrier the EPA's policy of requiring that private parties agree to implement the entire cleanup remedy all at once rather than allowing them to agree to the early action before agreeing to the full remedy (Diamond, 1991~. These groups have suggested allowing responsible parties to agree to implement ground water remedial actions in phases, without a legally binding commitment to implement the later phases.
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From page 259... ...
However, the committee believes that DNAPL investigations may require more time and effort, depending on the cleanup goals for the site, because they may require more subsurface sampling and more analysis of the samples. Despite this concern, the committee supports the EPA's decision to require expanded DNAPL investigations because the additional information will facilitate selection of an appropriate remedial action.
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From page 260... ...
. Because of the difficulty of cleaning up DNAPLs and because other site complexities in addition to DNAPLs may prevent achievement of healthbased ground water cleanup goals, more than half of the sites in the Superfund program might be eligible for technical impracticability waivers.
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. In the third phase, data should be gathered to determine whether attainment of ground water cleanup goals is feasible with existing technology.
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262 U: o ._ .s au ._ ._ .
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Programs for Innovative Technology Development As explained in Chapter 4, numerous barriers have discouraged the development and use of innovative ground water cleanup technologies. These barriers are interfering with the ability to increase the likelihood of reaching health-based cleanup goals.
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From page 264... ...
Second, even if there is disagreement over the appropriate goal for ground water cleanup or with the imposition of a fee on industry, in the long run such an approach provides benefits to the private sector. Over time, the applied ground water research that the fund would support is likely to lower the cost of ground water remedial actions at all sites.
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From page 265... ...
In addition to the specific suggestions for improving the policies described above, the committee has additional suggestions related to the broad implementation of policies for managing sites where the ability to achieve healthbased ground water cleanup goals is uncertain. Broad and Equivalent Application of Policies to All Sites The committee is concerned about inconsistencies in the application of ground water cleanup policies at different sites.
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From page 266... ...
The results of the oversight would allow the EPA to continuously improve its implementation guidance documents, its reference case examples, and its training programs. Such a program evaluation process should involve input from EPA program managers, expert scientists, and stakeholders at the site (including citizens and responsible parties)
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From page 267... ...
The long-term effectiveness of any technical impracticability policy will depend on an institutional maintenance mechanism. SUMMARY OF POLICY RECOMMENDATIONS In summary, the committee believes that the EPA is making considerable progress in developing policies to address the fact that existing technologies may be unable to achieve current ground water cleanup goals at many sites.
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From page 268... ...
For sites in the first group (group A in Table 7-1) , health-based ground water cleanup goals should be achievable with current technology.
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From page 269... ...
Recommendation 3: The committee recommends that the EPA prepare new guidance documents that will lead to improved optimization of the hazardous waste site characterization process and explicitly address factors that will determine whether health-based cleanup goals are practicable. The EPA should revise existing site characterization guidance for the Superfund and RCRA programs to ensure that factors influencing whether cleanup goals are achievable are addressed as early as possible.
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From page 270... ...
Consequently, data are not systematically collected across regions for review and evaluation. Because site-specific cleanup experience is rarely submitted for publication in peer-reviewed technical journals, it is especially important for the EPA to take the lead in gathering, assessing, and summarizing the information being generated at Superfund sites to better understand current capabilities of ground water cleanup systems and to identify key areas for future research.
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From page 271... ...
The committee believes that early site-specific public meetings, perhaps during initial scoping sessions, could provide key information to the public. The EPA should include expanded efforts at community relations within the technical impracticability waiver process or should revise its Superfund community relations guidance documents to address issues of technical impracticability.
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From page 272... ...
The EPA should pilot test this concept to determine whether it results in faster cleanups or whether it slows the process because of the added regulatory burden. Recommendation 10: The committee recommends that the EPA assess and develop guidance on institutional strategies for preventing public exposure to contamination over the long term at sites where reaching health-based cleanup goals is infeasible with present technologies.
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From page 273... ...
1992c. Enforcement Under the Superfund Accelerated Cleanup Model (SACM)
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