oEPA
               united St
               Environmental Protection
               Agency
            Office of
            Solid Waste and
               DIRECTIVE NUMBER: 9481.10(84)
               TITLE:  Neutralization Surface Impoundments

               APPROVAL DATE:  8-20-84
               EFFECTIVE DATE:  8-20-84
               ORIGINATING OFFICE: office of solid waste
               m FINAL
               D DRAFT
                STATUS:
]
]
                          [ ]
                          [ ]
               A- Pending OMB approval
               B- Pending AA-OSWER approval
               C- For review &/or comment
               D- In development or circulating
REFERENCE (other document*):
                                       headquarters
  OSWER      OSWER      OSWER
VE   DIRECTIVE   DIRECTIVE   Dl

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PARTS 264 AND 265  SUBPART F - GROUND-WATER PROTECTION
                                                DOC:  9481.10(84)
Key Words:    Ground-Water Monitoring, Surface Impoundments

Regulations:  40 CFR 265.90(e), 264 Subpart F
Subject:

Addressee:

Originator:

Source Doc:

Date:

Summary:
Neutralization Surface Impoundments

James Scarbrough, Chief, Residuals Management Branch, Region IV

Bruce R. Weddle, Director, Permits and State Program Division

#9481.10(84^

8-20-84
     Neutralization surface impoundments, exempted from the interim status
ground-water monitoring requirements 40 CFR §265.90(e), are required to meet
40 CFR §264, Subpart F, ground-water monitoring requirements when they are
permitted.  Permits for facilities must show compliance with the detection
monitoring regulations 40 CFR §264.98.

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9481.10 (84)
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SUBJECT!  Neutralization Surface Impoundments

PROMt     Bruce R. Weddle, Director
          Permits and state Program Division                            "-

TOt       James Scarbrough, Chief                                       .*
          Residuals Management Branch, Region IV                        *>
                                                                        •v
                                                                        a
     In a recent phone conversation with Rick Nace, you
asked whether neutralization surface impoundments, which are     .       i
exempted from the interim status ground-water monitoring                £
requirements pursuant to 40 CFR $26S.90(e), will be required            <•
to meet the 40 CPR Part 264, Suhgart P ground-water monitoring          Z
requirements when they are permitted.  The answer  is yes.               £
The $265.90(e) exemption is not applicable for permitted                ^
facilities.  Permits for such facilities must contain condi-            t-
tions requiring compliance with the detection monitoring                £
regulations at 40 CPR 5264.98.  Detection monitoring parameters
must be specified in the permits in accordance with §264.98(a).

     I hope the above information answers your question.
It is my understanding that a RIM is being prepared by the^ X/vT
Waste Management and Economics Division to address this   J)  ^ r7 '
issue in greater detail.  If you have any further  questions, /
please feel free to contact Rick Nace (382-2210).

cci  Truett DeCeare
     Peter Guerrero
     Burnell Vincent
     Rick Nace

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