CHAPTER THREE

DEFINING REQUIREMENTS AND TECHNICAL OBJECTIVES

One of the most important steps in the design and implementation of a ground water

monitoring program is defining the data, analyses, and information that are required from a

regulatory standpoint. The next step is to develop technical objectives to meet those

requirements. Once requirements are identified and objectives are developed, the

owner/operator should thoughtfully consider the activities necessary to achieve the

requirements and objectives. One of the keys to implementing a successful monitoring

program is planning activities that logically progress to obtain the desired information.

3.1

Defining Requirements

As stated previously, owners and operators of TSDFs are required to comply with both

the ground water monitoring regulations contained in Subpart F and with the permitting

standards of 40 CFR Part 270 Subpart B. This Manual is also applicable to owners and

operators of TSDFs who are required to comply with 40 CFR Part 264 Subparts J (Tank

Systems), K (Surface Impoundments), L (Waste Piles), N (Landfills), and X (Miscellaneous

Units) when preparing hydrogeologic reports for various regulatory purposes. For owners and

operators of TSDFs, the initial step in conducting a ground water monitoring program should

be to define the regulatory requirements with which they are required to comply.

The sources of applicable requirements will depend on whether a facility is designing

a proposed ground water monitoring program to submit with its permit application, or is

already permitted and is designing a program or a portion of a program in response to a

permit requirement. In the latter case, under the permit as a shield provision of 40 CFR

 270.4, the permit will contain, either expressly or by reference, all of the applicable

requirements. In the former case, the program should comply with all applicable regulatory

requirements of Parts 264 and 270 (or with applicable State regulations in an authorized State,

along with any applicable EPA regulations promulgated under the authority of the Hazardous

and Solid Waste Amendments of 1984 (HSWA) which the State is not authorized to

administer). The requirements and objectives of a facility's hydrogeological investigations

and/or ground water monitoring programs should always be discussed with the appropriate

EPA representative prior to initiating any activities.

3.2

Defining Technical Objectives

In a broad sense, technical objectives are the data or information that the

owner/operator wants to obtain. Technical objectives are typically developed to satisfy

regulatory requirements. This Manual discusses the basic data necessary for meeting the

performance standards for the design and implementation of a RCRA ground water

November 1992

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