oEPA
               United States
               Environmental Protection
               Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER:  9523.03(85)

TITLE: Additional Organic Parameters in Evaluation of In-
     terim Status Ground-Water Monitoring
                APPROVAL DATE: 8-19-35

                EFFECTIVE DATE: 8-19-85

                ORIGINATING OFFICE: Office of Solid Waste

                E FINAL

                D DRAFT

                 CTATIIC      [ ]  A" Pendiru OMB approval
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                               C- For review &/or comment
                            [ ]  D- In development or circulating

                REFERENCE (other documents):      headquarters
  OSWER      OSWER      OSWER
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"PART  270   SUBPART  B  -  PERMIT  APPLICATION
                                                DOC:  9523.03(85)
 Key Words:

 Regulations:

 Subject:


 Addressee:

 Originator:

 Source Doc:

 Date:

 Summary:
Ground-Water Monitoring, Appendix VIII

40 CFR 270.14(c)(4), 265 Subpart 5

Additional Organic Parameters in Evaluation of
Interim Status Ground-Water Monitoring

Lloyd Guerci, Acting Director, RCRA Enforcement Division

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

#9523.03(85)

8-19-85
     The memo discusses methods  to  overcome  the  limitations  of  interim status
ground-water monitoring data.  The  memo  recommends  using  the authority of
§270.14(c) after  the Part B  is called.   This  allows  the permit  writer  to direct
the applicant to  undertake a full Appendix VIII  scan or to monitor  for a set of
parameters beyond  those in Part  265 in order  to  confirm the  absence of ground-
water contamination.

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                                                                9523.03  (85)
  AUG 191985
                                                                        5 £
                                                                        x a
                                                                        CD 03
                                                                        ?? *
                                                                        Q> 01
 MEMORANDUM                                                              » »
                                                                        -t t
                                                                        »• •*
                                                                        3 3
 SUBJECT:  Use  of  Additional Organic Parameters in Evaluation of        ?. ?.^
          Interim Status  Ground-Water Monitoring                       en en
                                                                        (0 10

 PROM:     Bruce R.  Weddle,  Director                                    * *
          Permits and  State Programs Division                          u> w
                                                                   .     CO CO
                                                                        10 IO
 TOi       Lloyd Guerci, Acting Director                                ^ i.
          RCRA Enforcement  Division                                    ^ ^
                                                                        o o
                                                                        *• ••
                                                                        CO CO
     You recently asked for our views on a memo from Michael           \^
 Gansecki of Region VIII on  the limitations of ground-water             £\
 monitoring required under Interim Status.  We believe that this        ^ *
 memo (which is attached)  raises a variety of valid concerns.           ^~
 Under Part 265 regulations, the parameters are restricted to a         o >--
 few indicators and the drinking water standards, and do not            £~ £
 include numerous  organic  chemicals of possible concern.  The           **
 problems outlined in the  memo accurately characterize the diffi-       * o>
 culty encountered in interpreting Interim Stacus monitoring data.      i< ^
                                                                        CD fl>
     The most  serious  problem, however, is the lack of appropriate     n
 monitoring data for organic compounds.  Even with full compliance      M<
 with the rules, under Part 265  Subpart P, the lack of adequate          <
 organic parameters  leaves some uncertainty as to whether facilities    o
 have, in fact, contaminated the ground water.  The Part 265          *  °
 indicator parameters suffer from a lack of sensitivity, and may        ^
 be unreliable; most importantly, the only specific organic param-      o
 eters are a handful of pesticides.                                     £.
                                                                        o
     Questions concerning Interim Status ground-water monitoring       3
 have been raised, -many  times,  and the Agency has previously
 provided gu$£jP4|ca on the  subject.   The joint memo from Lee Thomas
and Courtney n»jtce  to  the Regions  (November 29, 1984)  addressed
 this isMMt/uVlioBMi  detail.   This memo advised the Regions to
 •notify facilclties  as .early as possible prior to or upon calling
 in their Part Bs  (or knowledge of  a planned new facility) of the
 types of data that  must be  submitted in the Part B in order to
satisfy $270.14(c)»-   The memo also noted that in order to satisfy
 S270.14(c)r facilities must provide information to support a
 determination of  whether  hazardous constituents (i.e., App. VIII)
 are present in the  ground water.

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                                -2-


     Aa notes): in the  Permit  Applicants'  Guidance Manual for
Haxaroou* tiMrtb» Land  Treatment,  Storage,  and Disposal Facilities
(Nay 1984>><££;BPA determine*  that the  Interim Status ground-
water monitoring program  cannot  adequately determine  whether a
plume of contamination  ha* entered the  ground water,  than tha
Region may immediately  require compliance with 5270.14(c)(4) and
direct thai applicant  to analyze  for all  Appendix VIII constituents
at one*.  Alternately,  a  compliance order nay ba iaauad directing
the applicant to collact  additional data "responsive  to
1270.14(0)(4) for use in  determining how tha facility should b«
pamittad undar tha Part  264,  Subpart P  system."


     The Compliance Ordar Gui4an amd  State*  Program Division has long advised
Regione to uaa the authority of  5270.14(c)  after the  Part B has
bean eall«4«, If tha-Permit writer  cannot  determine from the
Interim 8t«t«sxraaita vhather or not  contamination has  occurred, he
can direct IjMi'amplioant  to undertake a  full App. VIII  scan.
Rather UtaaryMtroiae  tha  full  authority of  $270.14(c) (4 ),  the
Permit Writaxr may attempt to negotiate to  have  the applicant
voluntaril^aiaftitor .for a aat  of paramatara beyond those in Part
26S in order to confirm the absence  of ground-water contaaination.
The threat the*/Permit Writer would  held  in  reserve would be to
inalat o*» full App. VIII scan.   Mote that if  a limited organic
analyst* indicate* that ground-water contamination exists,  then
a full App* VIII scan would ba mandatory  undar  $270.14(c).

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                      -3-

•'•^V*''- -' ' '•

       tne Region may pursue one of  the  above  approach**
in deattfftjr*fta problems  in Interim Status monitoring.  Whether
the Region decides  to  exercise the full authority of 5270.14(c)(4J
at once and demand  an  App.  VIII scan,  or Instead decides to choose
•indicator* chemicals,  through negotiation or an enforcement order,
will depend: on the  specific merits of  each case.  In all cases,
however, the Region must  be satisfied  that the existing monitoring
network of wells will, in fact, be able to detect contamination.
Additional wells and/or further site characterization may often
be required.

     The mer?o fror  Region VIII also urges 8PA to develop a
•national mo..?!"  .or sampling a restricted set of organic param-
eters.  However, as noted in the Compliance Order Guidance, the
parameters chosen may  vary  considerably from site to site.
Certainly, the GC/MS methods recommended in the memo (Sw>«4«
methods «240 and 8230/8270)  are quite  comprehensiver.»n4tshould
bo adequate to determine  most organic  constituents o£ concern in
App. vxii«                                           ,»f:;s!;;-;-•'.
                                                     .'*'',- •          •*"
     Currently, the Agency  has no plans to develop a "national '*•*
model* for a restricted group, of organic chemicals from. App. VIII^
However, the approach  outlined in the  memo from RegjLoft V1I1 seems
valid, i.e., to select organic* from the CE :LA priority pollut-
ant* list and other App.  VIII chemicals that are moat likely to
enter groun                                 .       '

•  the types of wamtes handled at the  facility and the likely
. .jHuardous constituentsr                               .

•tae^physical/caemical  properties  of candidate organic* that
   ares indica.tiv«e of a high  potential  for migration, i.e., high
''-K»mter solubility, low  octanol/water partition coeffioient,

               r .
               lity of proven analytical methods.

        yow' dl^your staff would like to pursue these issues with
u» further, pleaee  feel free to contact Bob xayaer and Amy Mills
of the. Permit Assistance  Team.

Attachment   ....''/.,.     -    "             "...-....

cet  feter Guerrero .   Bob  Kayser    Mike Barclay
           Gregan       Amy  Mills
                                  ••X

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