Superfund Sites with Dense Non-Aqueous Phase Liquids (DNAPLs) may require additional groundwater treatment under a recent guidance document issued by the U.S. Environmental Protection Agency (EPA) on September 19, 2011. The OSWER directive, Clarification of OSWER’s 1995 Technical Impracticability Waiver Policy, #5355.5-32, instructs Regions to discard the 1995 guidance document that had advised Regions to