Hydrochemical Monitoring and Hydrogeologic Characterization: Conflict and Resolution

摘要

This paper focuses on the conflicts that are inherent to the federal regulations of the Resource Conservation and Recovery Act (RCRA) as codified in the Code of Federal Regulations (40 CFR 264, Subpart F (USEPA 1987a) and 40 CFR 265, Subpart F (USEPA 1987b)), and the Technical Enforcement Guidance Document (TEGD) (USEPA 1986). The RCRA regulations are enforceable laws, whereas the TEGD is strictly intended as guidance (USEPA 1986; Cook 1986). The conflicts addressed here result from the conflicting goals of (1) obtaining adequate information to determine the concentration and distribution of contaminants and (2) obtaining adequate information about the hydrologic properties of the aquifers through which the contaminants are transported. Both the hydrochemical monitoring of contaminants and the identification of hydrogeologic characteristics of the transport medium are essential and required under RCRA, specifically under 40 CFR 265.93 (USEPA 1987b). 17 refs., 2 figs. (ERA citation 14:025345)