Subject: Risk Assessment

MEMORANDUM FOR ASSISTANT SECRETARY OF THE ARMY: Investigating Per- and Polyfluoroalkyl Substances within the Department of Defense Cleanup Program

The Department of Defense (DoD) conducts cleanup under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the Defense Environmental Restoration Program (DERP). Their goal is protection of human health and the environment in a risk-based, fiscally sound manner. This memorandum provides clarifying technical guidance on the investigation of per- and polyfluoroalkyl substances (PFAS) based on updated U.S. Environmental Protection Agency (EPA) information. This guidance is applicable to investigating these chemicals at Environmental Restoration Account-funded, Base Realignment and Closure Account-funded, and federal Air and Army Guard Operation and Maintenance account-funded sites.

EPA Federal Facilities Superfund Program – RPM Bulletin 2024-02 Developing a Crosswalk between Legacy and PFAS Sites

The purpose of this document is to assist United States Environmental Protection Agency (EPA) Remedial Project Managers (RPMs) with the tracking of the location of per- and poly-fluoroalkyl substances (PFAS) with regard to “legacy” contaminants that have been historically addressed in the Superfund program. This is important because the presence of PFAS in the same location and media as legacy contaminants can affect protectiveness, as well as worker safety and remedy selection and function. This strategy will be useful at all phases of the Remedial Investigation, including Remedial Investigation Scoping, Conceptual Model development, sampling and data interpretation, remedy selection, and Federal Facility Superfund Sites’ Five-Year Reviews (FYRs). This Bulletin is providing recommendations that are consistent with existing guidance and identifies …

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TI waiver 198193

The purpose of this memo is to clarify the U.S. Environmental Protection Agency’s (EPA’s) internal consultation process for Superfund groundwater technical impracticability (Tl) Evaluations. It also provides recommendations on how to prepare technically sound Tl Evaluation documents when considering whether a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) groundwater cleanup site merits an applicable or relevant and appropriate requirement (ARAR) waiver.

TI Waiver Wolford 2011

The purpose of this memorandum is to provide clarification to the 1995 Office of Solid Waste and Emergency Response (OSWER) memorandum entitled, Superfund Groundwater RODs: Implementing Change This Fiscal Year, July 31, 1995, (OSWER Directive 9335.3-03P) regarding the use of Technical Impracticability (TI) waivers at Comprehensive Environmental Response Compensation and Liability Act (CERCLA) sites with Dense Non-Aqueous Phase Liquid (DNAPL) contamination.