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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