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2. ESTABLISHING AND MEETING GROUND WATER PROTECTION GOALS IN THE SUPERFUND PROGRAM
Pages 22-33

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From page 22...
... The process being developed will guide remedial project managers and other decisionmakers concerned with ground water remedial actions at Superfund sites so that a consistent ground water evaluation and decision approach is applied to all such sites. APPLICABLE OR RELEVANT Al APP1tOPR~TE REQUIREMENTS Under the National Contingency Plan (NCP)
From page 23...
... , health advisories, and water quality criteria for the protection of public health, all of which are evaluated for ground water protection levels in the Superfund program. EPA's ground water protection strategy (U.S.
From page 24...
... is contaminated with known or suspected carcinogens, the program suggests the development of a limited number of ground water protection goals be developed that vary between 10-4 UCR and 10-7 UCR and vary between restoration time periods. A pointof-departure alternative for initial decision evaluation should be developed at a 10-6 UCR with a limited restoration time period.
From page 25...
... DECISION ANALYSIS The decision as to which remedial action alternative to select and implement depends on many factors. Those factors relating to the concentration level for carcinogens in the ground water include other health risks borne by the affected population and population sensitivities.
From page 26...
... Acute and chronic levels for noncarcinogens are threshold values and therefore are not influenced by these two factors. Factors that influence the restoration time period for ground water contaminated with carcinogens and noncarcinogens are as follows: feasibility of providing an alternative water supply; current use of ground water; potential need for ground water; electiveness and reliability of institutional controls; and ability to monitor and control the movement of contaminants in ground water.
From page 27...
... Therefore, a careful evaluation of capital outlays and the operation and maintenance costs associated with each alternative must be considered and compared to those of each of the other alternatives. Ground water remediation time frames may be extended if the agency decides that the costs to meet performance goals in 1 to 5 years are extraordinarily high and as long as institutional controls will be effective for the additional period.
From page 28...
... Figure 2-4 illustrates this evaluation process. Should it be determined that it is not practicable to restore the ground water to the initial cleanup goal level, an exception to the NCP could be demonstrated, based on extraordinary costs or the technical impracticability of meeting applicable or relevant and appropriate federal requirements.
From page 29...
... GROUND WATER PROTECTION GOALS REMAINING GROUND WATER CONTAMI NANT CONCENTRATION REMAINING G ROUND WATE R CONTAMI NANT CONCENTRATION REMAINING G ROUND WATE R CONTAM I NANT CONCENTRATION LEGEND Remedial Action Performance Goal Time of Performance Evatua~,on 29 Actu al Performance . ~ L Pred icted Performance __ i ~ DURATION Of REMEDIAL ACTION Case 3A Ground Water Goal will be achieved _ ~ DURATION OF REMEDIAL ACTION Case 3B Ground Water Goal will be achieved in longer time frame DURATION OF REMEDIAL ACTION Case 3C Ground Water Goal will not be achieved over long period of time FIGURE 2-3 Possible restoration scenarios when evaluating performance data.
From page 30...
... 1985b. Superfund Public Health Evaluation Manual.
From page 31...
... In other words, if you do a risk assessment and you say, here is the exposure from a particular contaminated water supply, you cannot neglect the fact that the same population is being exposed to the same, similar, or different chemicals from other roots of exposure, including other cleanups. We have seen situations in which half a dozen cleanups are going on, stuff is going into a river that is becoming the drinking water supply downstream, and none of this has been factored into the risk assessment.
From page 32...
... ~ think we have created a monster with the Superfund program that is, a great deal of federal authority (because the federal government provides a lot of the money) ; yet if we apply this logic of dealing with the future use of natural resources, you would have to shift decisionmaking to a local level.
From page 33...
... Creating a Superfund program at an $8 billion spending level without adequate information, adequate technology, and adequately trained people is another folly, analogous to giving a loaded gun to a child. ~ wish we would talk more about how we can implement these frameworks, how we can implement the use of risk assessment; and if we cannot implement it now or in 5 to 10 years, are you willing to talk about making a commitment to delay action until we get the information or the technology or the trained people?


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