What is EPA's inspection authority ?
Section §3007 of RCRA Subtitle C gives EPA
the authority to conduct compliance and
evaluation inspections of hazardous waste
facilities for the purpose of developing
regulations, preparing permits, or ensuring
compliance with RCRA regulations. Access to
these facilities is granted to "duly designated"
officers, representatives, or employees of
authorized State hazardous waste programs.
Section §3007 allows authorized officials to:
Have access to, and copy all records at
hazardous waste management facilities at
all reasonable times.
Obtain samples of any waste containers or
labeling for such waste, including spills.
Determine compliance with RCRA .
FYI
Aquifer - A geologic formation, group of
formations, or part of a formation
capable of yielding a significant amount
of ground water to wells or springs.
Ground Water - Water below the land
surface in a zone of saturation.
Landfill - A disposal facility or part of a
facility where hazardous waste is placed
in or on land and that is not classified as
a land treatment facility, surface
impoundment, or an injection well.
Land Treatment - A facility or part of a
facility at which hazardous waste is
applied onto or incorporated into the soil
surface. Such facilities are disposal
facilities if the waste remains after
closure.
EPA and the States seek a positive working
relationship with the RCRA regulated
community to ensure the best protection of
the environment and human health. Please
call any of the following telephone numbers
to receive information concerning Federal
and/or State solid and hazardous waste
policies and regulations:
EPA REGIONAL OFFICE
TELEPHONE NUMBER
STATE OFFICE
TELEPHONE NUMBER
(703) 920-9810 or 800-424-9346
RCRA/CERCLA HOTLINE
(202) 260-9327
RCRA DOCKET
United States EPA 9950.3FS
Environmental Protection October 1991
Agency
Soild Waste and Emergency Response
SEPA RCRA
Comprehensive
Ground Water
Monitoring
Evaluations (CME)
and
Operation &
Maintenance (O&M)
Inspections
f '.• Printed on Recycled Paper
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The Comprehensive Ground Water Monitoring
Evaluation (CME) and Operation and Mainten-
ance (O&M) inspection evaluates the adequacy
of ground water monitoring systems at Resource
Conservation and Recovery Act (RCRA) land
disposal facilities (e.g., surface impoundments,
landfills, land treatment units, etc.).
What is a CME inspection ?
The objective of a CME is to determine whether
a facility has a ground water monitoring system
which is adequately designed and operated to
detect releases and to define the rate and extent
of contaminant migration from a RCRA
regulated unit.
The CME includes:
Evaluation of the site geological
characterization.
Evaluation of the site hydrological
characterization and description of the
uppermost aquifer.
Evaluation of the criteria used for well
placement and for screen lengths of ground
water monitoring wells.
Evaluation of the criteria for drilling method,
monitoring well design, and construction.
Evaluation of the ground water assessment
plan or outline.
Evaluation of the sampling and analysis
plan and its implementation.
Field verification of ground water levels, and
of the number and location of ground water
monitoring wells and piezometers.
Collection of samples for analysis to help
verify the analytical precision and
methodology of a facility's procedures.
Possible use of confirmatory geophysical
methods to verify facility assessment of
hydrogeology or contaminant distribution.
Possible evaluations of other ground water
activities at RCRA facilities (e.g., corrective
action activities).
What is an O&M inspection ?
The O&M inspection focuses on how ground
water monitoring systems are operated and
maintained. The O&M inspection is designed to :
Determine that the facility's personnel are
collecting ground water samples in
accordance with the Sampling and Analysis
Plan.
Determine that the facility's sampling devices
are in working order and that the facility is
abiding by maintenance provisions.
Determine that individual monitoring wells
and piezometer/observation wells within a
ground water monitoring system continue to
yield representative ground water samples
and reliable hydrologic data.
Identify violations in regard to operation and
maintenance programs and/or detect a need
for a more thorough scrutiny of the facility's
ground water monitoring program.
Identify issues or concerns that enforcement
staff should assess in a future comprehen-
sive ground water monitoring evaluation.
Collect ground water evaluation data.
TYPICAL ARRANGEMENT OF CLUSTERED.
VERTICALLY SEPARATED WELLS
Shallow
Ground Well
Surface
Intermediate
Well
Deep
Well
In addition, if the facility has been notified of
deficiencies in the ground water monitoring
system, the O&M inspection will determine
whether these deficiencies have been corrected.
What is the relation between the
O&M and CME ?
Once the CME inspection has determined that a
facility has an adequately designed and properly
operated ground water monitoring system in
place, subsequent O&M inspections determine
how well the owner/operator maintains the
ground water monitoring system's efficiency and
operations.
The field inspection portion of both inspections
may be the same; however, during the O&M
inspection any activities or system changes that
have been completed since the last CME are
evaluated. An O&M inspection report can
recommend that a CME be performed if the
ground water flow regime has changed.
Split samples may be collected for either type of
inspection.
What can be expected from EPA/
State after a CME or an O&M
inspection has been completed ?
EPA/State will make a determination, based on
the inspection results, to pursue one of the
following actions:
No further action.
A warning letter (Notice of Violation or
Notice of Deficiency).
An administrative order or civil action
requiring compliance and payment of a
penalty.
A permit denial or modification.
A criminal investigation or action.
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