Use of Technical Impracticability (TI) Waivers at Superfund Sites

摘要

This presentation will provide an overview of a recent survey of groundwater remedies at Superfund sites across the nation. Over the past decade, there has been a noticeable trend away from pump-and-treat remedies to those which include the application of in-situ remedies and the selection of monitored natural attenuation. At a small subset of sites, restoration of groundwater is not feasible from an engineering perspective. These sites have made a decision to waive restoration as a remedial action objective (RAO) by making a TI decision in a record of decision (ROD). This talk will discuss the US EPA regulatory framework for groundwater cleanup and factors which influence groundwater restoration. The EPA guidance on TI decisions will be reviewed along with critical components which are necessary for making a TI decision.