The Role of Technical Guidance and Analysis Tools in Remedy Decisions, Implementation, and Closure - 18307
Selection, design, and implementation of environmental remedies are conducted under regulatory frameworks that define the activities, communication, and documentation requirements for the remediation process. However, there are site situations that are not well described in the basic regulatory frameworks, and technical guidance and analysis tools can help facilitate remedy decisions and actions. An example where technical guidance and analysis tools are helpful is in the transition from pump-and-treat (P and T) remediation to monitored natural attenuation (MNA). Standard MNA regulatory guidance does not account for a plume initially controlled by P and T hydraulic conditions rather than natural-gradient conditions. For instance, MNA guidance discusses demonstrating plume stability as a means to evaluate the suitability of MNA. However, plume stability under long-term natural gradient conditions cannot be directly demonstrated while the plume is being contained by a P and T system. Thus, additional guidance is needed to describe other measures that can be used to support transition from P and T to MNA. As an additional example, standard MNA regulatory guidance is not written to provide suitable information for application to vadose-zone contamination; discussion and examples in the regulatory guidance are predominantly for groundwater. Use of contaminant transport assessments is an important component of vadose-zone remedy decisions where technical guidance and analysis tools can facilitate these decisions. For volatile compounds, the assessment may need to also consider flux to the surface and constraints associated with vapor intrusion. Recent technical guidance and associated analysis tools provide sites with approaches to support remedy decisions for the above conditions. In particular, these recent approaches target developing and implementing P and T and soil vapor extraction remediation exit strategies and facilitating assessment and implementation of remedies for coupled vadose-zone/groundwater contamination. (authors)