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Introduction

Table 1. Summary of Key USEPA Documents Pertaining to TI Waivers

DATE	USEPA DOCUMENT	DESCRIPTION
1993	Guidance for Evaluating the Technical Impracticability of Ground Water Restoration. EPA/540/R-93/080, OSWER Directive 9234.2-25	This is the primary USEPA guidance document on TI waivers that is still used today. It includes the definition of TI, summarizes technical challenges faced at remediation sites, describes what is and is not included in a TI waiver, outlines a consistent, site-specific approach for evaluating the TI of groundwater cleanup and establishing a protective alternative remedial strategy if restoration is determined to be technically impracticable within a reasonable timeframe.
1995	Memorandum: Consistent Implementation of the FY 1993 Guidance on Technical Impracticability of Groundwater Restoration at Superfund Sites. OSWER Directive 9200.4-14	This memorandum specified a process for maintaining consistency for TI waiver implementation among different EPA regions. (The number of CERCLA sites conducting TI evaluations was reportedly far less than expected; therefore, the process outlined in this memorandum was not fully implemented).
2007	Recommendations from the EPA Ground Water Task Force. EPA/500/R-07/001	The task force identified and prioritized groundwater issues. They recommended developing supplemental guidance on TI and a fact sheet describing program flexibilities and alternative cleanup goals for DNAPL source zones. The report included an attachment describing cleanup goals that may be appropriate for DNAPL source zones.
2009	Summary of Key Existing EPA CERCLA Policies for Groundwater Restoration. OSWER Directive 9283.1-33	This memorandum compiled key existing USEPA policies to enhance the transparency of USEPA decisions and to assist USEPA regions with making groundwater restoration decisions. The memo addressed expectations for groundwater restoration and TI waiver consideration in the context of principles for remediation. No new guidance or policy was included.
2011	Groundwater Road Map: Recommended Process for Restoring Contaminated Groundwater at Superfund Sites. OSWER Directive 9283.1-34	The Groundwater Road Map compiled relevant highlights of existing USEPA laws, policy and guidance into a roadmap for groundwater restoration. Included is a discussion of TI waivers, institutional controls, wellhead treatment and other topics to the extent that these may be part of a comprehensive groundwater remedy.
2012	Summary of Technical Impracticability Waivers at National Priorities List Sites. Report with General Technical Impracticability Site Information Sheets. OSWER Directive 9230.2-24	The report summarized TI waivers issued by USEPA regions, presented some summary statistics and included an appendix of brief site information sheets for each site where a TI waiver was adopted. A total of 91 waivers at 85 sites were identified.
2016	Clarification of the Consultation Process for Evaluating the Technical Impracticability of Groundwater Restoration at CERCLA Sites. OLEM Directive 9200.3-117	The memo provides clarification of existing relevant Superfund policy and guidance and recommendations for planning and developing TI evaluation packages and describes the recommended process for EPA internal review and approval. The memo transmits five new recommended products, including a consultation process flowchart, TI evaluation flowchart, regional TI evaluation work planning spreadsheet, EPA review routing slip, and a summary checklist for the TI evaluation.