scope:

As required in 40 Code of Federal Regulations (CFR) Part 264, owners and operators of permitted hazardous waste management facilities must sample and analyze the groundwater at the site at specified intervals to determine if hazardous constituents from the waste are contaminating the groundwater. On July 9, 1987, the Environmental Protection Agency (EPA) promulgated a final rule that would require these owners and operators to analyze for a specified core list of chemicals, listed in Appendix IX of 40 CFR Part 264 (52 Federal Register (FR) 25942). Monitoring is required for this list of chemicals for both detection monitoring in $264.98 and compliance monitoring in $264.99.

This report is directed towards company environmental coordinators who must address regulatory issues, and field personnel who are responsible for obtaining analyses to fulfill regulatory requirements. The primary objectives of the work summarized in this report are to:

• summarize the analytical requirements,

• assess the adequacy of the analytical methods to meet these requirements,

• document the performance of selected analytical methods,

• identify any problems or deficiencies in the selected methods,

• provide insight into inconsistencies and contradictions between the regulation and the selected methods, and

• provide guidance on the implementation of the analytical requirements.

The information in this report was prepared under the sponsorship of API by Tischler/Kocurek (TK) and Enseco-Rocky Mountain Analytical (RMAL), Much of the information contained in this report is based on RMAL's considerable experience as an environmental laboratory. RMAL is one of two laboratories on EPA's ad hoc task force for Appendix IX and has been actively involved in Appendix IX issues since 1984, including the writing of comments on and research into Appendix IX issues.