EP 1110-1-19
30 Jun 01
report should not be approved until the determination has been made through an inspection that
the remedy is, in fact, O&F (Paragraph 2-3).
b.
Long-Term Response.
(1)
Long-term response action (LTRA) and PRP long-term response (LR) are sub-
actions of O&M used to track and assure continued Federal funding for the operation of
groundwater or surface water restoration remedies.7 LTRA is defined as the Fund-financed
operation of groundwater and surface water restoration measures, including monitored natural
attenuation, for up to the first ten years of operation. LTRA is complete after ten years, after a
technical impracticability determination is made, or after cleanup goals are achieved and
documented in a final RA report, whichever occurs first. LTRA transitions to traditional O&M
if cleanup goals are not achieved, or if continued monitoring is required, after ten years have
elapsed.
(2)
In the past, the term LTRA has been used to describe PRP-lead groundwater and
surface water restoration measures, including monitored natural attenuation. However, PRP-lead
groundwater and surface water restoration measures, including monitored natural attenuation, are
covered by a separate action, PRP LR. Because PRP LR is a specific type of O&M, the ten-year
timeframe does not apply. PRP LR is complete after a technical impracticability determination
is made, or cleanup goals are achieved and documented in a final RA report, whichever occurs
first.
c.
Cleanup Goals Achieved. Usually preceded by the interim RA report, this
milestone signifies when cleanup goals are achieved for groundwater and surface water
restoration, including monitored natural attenuation. "Cleanup goals achieved" is officially
accomplished once the final RA report is approved in writing.
d.
Five-Year Reviews. If there are any hazardous substances, pollutants, or
contaminants remaining at the site above levels that do not allow for unlimited use and
unrestricted exposure, EPA is required to conduct a review of the RA at least once every five
years to assure that human health and the environment are being protected. CERCLA 121(c)
and NCP 300.430(f)(5)(iii)(C) provide the legal bases for conducting five-year reviews.
Generally, five-year reviews may be discontinued when no hazardous substances, pollutants, or
contaminants remain at the site above levels that allow for unlimited use and unrestricted
exposure.
2-3. Remedial Action Completion. The RA for an OU is complete after the remedy is
determined to be O&F (if applicable), the remediation objectives and/or cleanup goals stated in
7
LTRA and PRP LR apply to groundwater and surface water restoration measures only, including monitored natural
attenuation. These terms do not apply to groundwater and surface water restoration measures conducted under other leads;
groundwater or surface water containment measures; groundwater or surface water measures initiated for the primary purpose of
providing a safe drinking water supply; or groundwater monitoring. Federal facilities-lead sites do not use LTRA or PRP LR.
Instead, groundwater and surface water restoration measures go from RA directly to O&M at these sites.
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