vvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9481.02(85)
Ground-Water Monitoring above the Uppermost Aquifei
APPROVAL DATE: 4;8-85
EFFECTIVE DATE: ^r8-85
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ORIGINATING OFFICE: °ffice of Solid Waste
0 FINAL
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[ ] .A- Pending'OMB approval.
STATUS [ ]~ ,B-£.Pending AA-OSWER approval-""
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REFERENCE (other documents]:
OSWER OSWER OSWER
fE DIRECTIVE DIRECTIVE
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PARTS 264-265 SUBPART F - GROUND-WATER PROTECTION DOC: 9481.02(85)
Key Words: Ground-Wacer Monitoring, Aquifer
Regulations:
Subject: Ground-Water Monitoring above the Uppermost Aquifer
Addressee: Hazardous Waste Management Division Director Regions I - X
Originator: John H. Skinner, Director Office of Solid Waste (WH-562)
Source Doc : 9481.02(85)
Date: 4-8-85
Summary:
This memo discusses ground-water monitoring in non-aquifer saturated zones,
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9i3L.02 (85)
APR 8 198F
MZMORAMDCM
SOBJKCTi Ground-water Monitoring Above the "Uppermost Aquifer*
faCHt John £. Skinner/ Director
Office of Solid Waste (WH-562)
TO: Hazardous Waste Management Division Director
legions I - X
Office of General Counsel (LE-130)
Some hazardous wast* facilities that are subject to the
ground-water protection (Subpart F) rules are situated in or
above saturated sones that do not meet the customary definition
of "aquifer.* In these cases, questions arise as to how to apply
the ground-water monitoring regulations which call for aonitoring
in the uppermost aquifer. I aa aware that several of you have
been and are negotiating with facilities in these situations.
For a number of reasons/ EPA. regions/ with encouragement
and support fro* OSW, have been requesting applicants for RCRA
Part B permits to provide monitoring in non-aquifer saturated
sones. The major reasons aret (1) the intent of the regulations
is to monitor the first ground-water contamination, not to link
aonitoring to a cosnercially productive aquifer. The preamble to
the regulations (33192 PR/ Hay 19, 1980) states "The monitoring
program seeks to detect contamination of the uppermost aquifer
because that will be the first ground water affected by a leaking
disposal facility!" (2) such monitoring provides early warning
on the performance of liner and leachate collection and removal
systems, since the flow of contaainants to the uppermost aquifer
and subsequently to monitoring wells in the aquifer may take many
tens or even hundreds of years; and (3) such monitoring provides
essential information on the direction and concentration of the
flow of contaainants from hazardous waste units since formations
with low permeability (e.g./ aquitards and aquicludes) nay divert
the flow of contaainants to surface water/ upgradient wells, or
beyond downgradient wells so that the contaminants are not dis-
cernable in the aquifer monitoring wells at the waste boundary.
BApril:vh:Vra-565E:rro2102M:382-4658:03/15/85:dsM3
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On January 30, 1935, Z discussed this issue at a meeting
with the national Solid Wastes Management Association (asHMA).
HSWIA agreed that such information is useful and proposed that
guidance be developed by OSM. To assist us, 3S33HA developed a
proposed draft of that guidance (the guidance and SStCMA cover
letter are attached). 91ease review this proposal and transmit
your comments by April 29 to Bob April, of ay staff, at mail
code MB-5651, electronic mail bos BMS301. Tou may also wish to
discuss this issue with State authorities. The MSttMA proposal
is more of a policy statement than a guidance. Z am interested
in your comments on the need for such a statement or guidance,
the scope and content of the guidance, and the desirability of
regulatory amendments.
Thank you for your cooperation. Zf you have aay questions,
please telephone me (332-4*27) or Bob April (382-4654).
Attachment -
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