Frequent Questions

How do the Environmental Indicator determinations for Current Human Exposure under Control and Migration of Contaminated Groundwater relate to final remedy decisions at a RCRA corrective action facility?

The environmental indicator (EI) determinations are a snapshot reflecting current conditions at a facility. The Human Exposure EI focuses on current exposure scenarios, and the Groundwater EI addresses the question of whether existing plumes of contaminated groundwater are continuing to expand above levels of concern. These determinations do not address whether corrective action is "complete" at the site, whether remedial long-term goals are met, or whether a site will be safe if land uses change in the future. 

As a result, overseeing agencies should not look at EI determinations at a facility as the "final" decision, and facility owner/operators should not interpret positive EI determinations as indicating that all corrective action obligations are met. In some cases, a facility that meets both Environmental Indicators may well need no further corrective action. But in many other cases, substantial work will be needed before a cleanup is complete. At some facilities, for example, current exposures may be cut off through interim measures, and groundwater migration may be under control, but more permanent measures (or more extensive site characterization) are needed to ensure that the site is safe for reasonably anticipated future uses. These measures would be addressed as part of longer term cleanup at the site.

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