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
, ' Pending AA-OSWER approval
C- For review &/or comment
[ ] D- In development or circulating
REFERENCE (other documents): headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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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
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MEMORANDUM » »
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SUBJECT: Use of Additional Organic Parameters in Evaluation of ?. ?.^
Interim Status Ground-Water Monitoring en en
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PROM: Bruce R. Weddle, Director * *
Permits and State Programs Division u> w
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TOi Lloyd Guerci, Acting Director ^ i.
RCRA Enforcement Division ^ ^
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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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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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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
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