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RCRA GWM Program

RCRA Groundwater Monitoring Programs

The disposal of municipal (RCRA Subtitle D), coal combustion residuals (RCRA Subtitle D) and hazardous waste (RCRA Subtitle C) is regulated by the Resource Conservation and Recovery Act (RCRA).  RCRA also applies to the protection of groundwater resources by regulating constituents of concern that may migrate into groundwater.  A RCRA monitoring system must consist of at least four wells: one up-gradient from the unit and three down-gradient.  Up-gradient wells are used to measure background water quality.  Down-gradient wells are tested for the presence of any statistically significant amounts of constituents that migrate from the waste management area.  Groundwater compliance is based on a comparison of the data from up-gradient and down-gradient wells.

Depending on the status of a RCRA site, one of several groundwater monitoring programs may be in place. 

  • Background monitoring determines the naturally occurring levels of constituents in the groundwater. Monitoring at up-gradient wells must occur quarterly for a full year.
  • Detection monitoring examines groundwater for elevated levels of indicator parameters that suggest that contamination may be occurring. During the detection monitoring phase, facility owners/operators must develop an assessment program outline in the event that an assessment monitoring program is required.
  • If the results of detection monitoring suggest that groundwater contamination has occurred, assessment monitoring will be implemented to determine the nature, extent, and rate of the groundwater contamination. Assessment monitoring must continue on a quarterly basis until the facility undergoes final closure or monitoring requirements are established in conjunction with obtaining a permit and/or performing corrective action.
  • A groundwater protection standard (GWPS) is established when a statistically significant release is detected at the waste management unit boundary under a detection monitoring program. The GWPS consists of a list of constituents and concentration limits for which groundwater monitoring must be conducted, the point of compliance, and the compliance period. The concentration limits of the GWPS are set at background levels, maximum contaminant levels (MCLs), or alternate concentration limits (ACLs).
  • Information developed in an assessment monitoring program is used by regulators to evaluate the need for corrective action. A corrective action is required when constituents of concern exceed the GWPS. The owner/operator is required to remedy the situation by removing hazardous constituents or treating them in place. The corrective action groundwater monitoring program must demonstrate that the corrective action is working.

How Can Eurofins TestAmerica Help?

Eurofins TestAmerica supports groundwater monitoring programs with services such as sampling support, courier services, laboratory analyses and customized data delivery options.  Experienced project management professionals work with you to implement testing methods that meet the requirements of your specific permit. 

Eurofins TestAmerica partners with clients performing routine groundwater monitoring, utilizing a programmatic approach to lower costs and mitigate client risk.  Customized data delivery options assist you in meeting your individualized and regulatory needs.  Data reported through TotalAccess®, Eurofins TestAmerica’s 24/7 on-line data portal, allows you to evaluate historical data and compare lab results to regulatory limits.  

Sampling Support

Eurofins TestAmerica provides coolers, packing material, certified pre-cleaned bottles with applicable preservatives and pre-printed chains of custody directly to the sampling site or office.  Our bottle kits reduce the potential of error in the field by providing the correct containers with the applicable preservatives and paperwork. 

Laboratory Analysis

Samples received at the laboratory are logged into our industry leading Laboratory Information Management System (LIMS) based on the information provided on the Chain of Custody.  Sample receipt confirmation forms detailing sample collection information and requested analyses are sent to client contacts after receipt to reduce error potential, and ensure proactive communication.

Data Delivery

Eurofins TestAmerica’s network of laboratories is linked by a single LIMS, allowing Eurofins TestAmerica to provide clients with one easy to read report and electronic data deliverable (EDD), regardless of where samples are analyzed within our network.  Clients have the option to receive their data in one of more than 2,500 formats, as well as via our online data portal, TotalAccess®.  TotalAccess® also allows clients to compare laboratory data to regulatory limits.  Please visit our Report Formats, Electronic Data Deliverables and TotalAccess® pages to learn more.