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
                            c        .    _
                ORIGINATING OFFICE: °ffice of Solid Waste

                0 FINAL

                D DRAFT
                            [ ]  .A- Pending'OMB approval.
                 STATUS      [ ]~ ,B-£.Pending AA-OSWER approval-""
                            [- ]  ;c~:For- review.&/or comment
                            [ ]! l®~Jj-n_ ^envelopment ^ or'; circulating
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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).

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