monitoring program. Performance standards, rather than specifications, are set forth in

Subpart F because of the diversity of the environmental settings in which regulated units

exist, and because of the need to tailor monitoring systems to fit each setting. While this is

still the philosophy behind the regulations, the Agency has found through experience that it is

necessary to provide specific protocols to guide the implementation of some portions of the

ground water monitoring regulations. This Manual presents protocols that correspond to the

following areas: 1) a comprehensive review of existing information (Chapter Four); 2) the

characterization of site hydrogeology, particularly the hydrogeology of the uppermost aquifer

(Chapter Four); 3) choosing ground water monitoring locations (Chapter Five); 4) well design

and construction (Chapter Six); and 5) sample collection and analysis (Chapter Seven).

3.3

Data Quality Objectives for RCRA Ground Water Monitoring

Inherent in the development of technical objectives is the determination of what

quality of data is required or desired. Chapter One of SW 846 addresses Quality Assurance

(QA) programs and Quality Control (QC) procedures that should be implemented by owners

and operators who are conducting ground water monitoring programs pursuant to RCRA.

Chapter One of SW 846 states that it is the goal of EPA's QA program to ensure that all data

be scientifically valid, defensible, and of known precision and accuracy. Data should be of

sufficient known quality to withstand scientific and legal challenges relative to the use for

which the data are obtained. The QA program is management's tool for achieving this goal.

All activities implemented pursuant to Subpart F (i.e., hydrogeologic site

investigations, design and installation of ground water monitoring wells, sampling, and sample

analysis) should include a QA and QC program as required by  264.97(e). The QA/QC

programs should be part of the facility permit application (  270.14(c)(5), 270.14(c)(6)(iv)

and 270.14(c)(7)(vi)) and operating record ( 264.97(e)). QA/QC programs should meet the

specifications of Chapter One of SW 846.

Chapter One of SW 846 defines fundamental elements of a data collection program:

1.

Design of a project plan to achieve the data quality objectives (DQOs);

2.

Implementation of the project plan; and

3.

Assessment of the data to determine if the DQOs are met.

DQOs for the data collection activity describe the overall level of uncertainty that a

decision maker is willing to accept in results derived from environmental data. This

uncertainty is used to specify the quality of the measurement data required, usually in terms

of objectives for precision, bias, representativeness, comparability, and completeness. As

described in Chapter One of SW 846, the owner/operator should define the DQOs prior to the

initiation of the field and laboratory work. Also, the owner/operator should inform the field

November 1992

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