Pointing out the Obvious to the US EPA
On June 30, 2020, The US EPA’s Office of Superfund Remediation and Technology Innovation had a “Listening Session” on Superfund Groundwater Remediation (something I have been doing since 1987). The purpose of the listening session was for the policy experts at US EPA to present their perspectives on the various ways my clients and I could take advantage of existing groundwater cleanup regulations. The US EPA had this event to:
• Increase transparency and improve communication
• Share existing approaches for six major groundwater principles or flexibilities
• Solicit input from regulators and stakeholders on implementation
But the US EPA completely missed the fundamentals behind what is wrong with the Superfund groundwater cleanup “approach.” At the event’s end, they asked the invited participants (100 of my closest friends and me) to provide them comments on what we heard. On July 6, 2020, I submitted the following letter to Laurence Libelo, Ph.D., PG, Chief Science and Policy Branch, Office of Superfund Remediation and Technology Innovation at the US EPA.