Remedy Evaluation Framework For Inorganic Non Volatile Contaminants In The Vadose Zone

Contaminants in the vadose zone may act as a potential long-term source of groundwater contamination and need to be considered in remedy evaluations. In many cases, remediation decisions for the vadose zone will need to be made all or in part based on projected impacts to groundwater. Because there are significant natural attenuation processes inherent in vadose zone contaminant transport, remediation in the vadose zone to protect groundwater is functionally a combination of natural attenuation and use of other remediation techniques, as needed, to mitigate contaminant flux to groundwater. Attenuation processes include both hydrobiogeochemical processes that serve to retain contaminants within porous media and physical processes that mitigate the rate of water flux. In particular, the physical processes controlling fluid flow in the vadose zone are quite different and generally have a more significant attenuation impact on contaminant transport relative to those within the groundwater system. A remedy evaluation framework is presented herein that uses an adaptation of the established EPA Monitored Natural Attenuation (MNA) evaluation approach and a conceptual model based approach focused on identifying and quantifying features and processes that control contaminant flux through the vadose zone. A key concept for this framework is to recognize that MNA will comprise some portion of all remedies in the vadose zone. Thus, structuring evaluation of vadose zone waste sites to use an MNA-based approach provides information necessary to either select MNA as the remedy, if appropriate, or to quantify how much additional attenuation would need to be induced by a remedial action (e.g., technologies considered in a feasibility study) to augment the natural attenuation processes and meet groundwater protection goals.