HIPPENSTEEL, D. L., Halliburton NUS Environmental Corp., Aiken, SC; J. E. BOLEN and T. J. TEMPLES, U. S. Department of Energy, Savannah River Field Office, Aiken, SC

ABSTRACT: A Comparison and Contrast of the Requirements of 40 CFR 264 and 265, Subparts F

The objectives of this paper are to compare and contrast the requirements presented in the Resource Conservation and Recovery Act (RCRA) as modified by the Hazardous and Solid Waste Amendments (HSWA, 1984) and found in Title 40, Code of Federal Regulations, Parts 264 (Permitted facilities) and 265 (Interim Status facilities), Subparts F (40 CFR 264 and 265) and to provide some insight into the rationale that the U. S. Environmental Protection Agency (EPA) used during the compilation and modification of those regulations.

Originally, EPA intended 40 CFR 265 Subpart F (265) to establish a foundation for compliance with 40 CFR 264 Subpart F (264). Part 265 is designed to detect potential impacts on groundwater quality from Treatment, Storage, and Disposal Facility (TSDF) operations and to characterize identified impacts to groundwater quality. Part 264 is designed to detect specific types of groundwater contamination, monitor compliance with a set standard of concentration limits unique to each TSDF, and monitor the effectiveness of implemented corrective action.

The major differences in the groundwater monitoring between Parts 264 and 265 are the types of TSDFs impacted and the monitoring parameters prescribed. The exemptions allowed under Part 265 do not apply to Part 264. This creates the potential for a TSDF to perform Part 264 groundwater monitoring without having performed monitoring under Part 265. The generic nature of the Part 265 monitoring parameters allows them to be influenced by natural or seasonal variations in groundwater quality, especially the groundwater contamination indicator parameters. Part 264 monitoring parameters have a much higher resistance to such influences.

Sampling protocol, reporting requirements, concentration limits, and statistical analyses are generally similar between Parts 264 and 265.

AAPG Search and Discovery Article #90987©1993 AAPG Annual Convention, New Orleans, Louisiana, April 25-28, 1993.