Last week, EPA released a draft Groundwater Remedy Completion Strategy.
The strategy is intended to provide:
a recommended step-wise plan and decision making process for
evaluating remedy operation, progress and attainment of [remedial
action objectives] using an updated conceptual site model,
performance metrics and data derived from site-specific remedy
evaluations.
I like to think that I am skeptical, not cynical. Having
worked on this stuff for 25 years, including some specific
Superfund sites for most of that time, I'm skeptical that this
means anything other than increased sampling and analytical costs
and increased oversight costs, as my clients and I are forced to
attend meetings which which include not only the EPA project
manager, but also three groundwater experts from the EPA regional
office, another 3 or 4 experts at EPA's outside technical
consultant, and yet another 3 or 4 experts at EPA's Ada,
Oklahoma, groundwater research center. When I
