January 18, 1995

TO:       Owners And Operators Of Currently Operating MSWLFs
                          
FROM:     Solid Waste Section
                        
RE:       Water Quality Sampling At Municipal Solid Waste Landfill 
          Facilities

The Solid Waste Section in our memorandum of June 24, 1994,
provided guidance on sampling and analysis requirements for the
Baseline Water Quality Sampling at Municipal Solid Waste Landfill
Facilities.  It has become apparent, based upon the initial
sampling reports submitted, that there is still some confusion with
regard to sampling analytical methods and reporting levels. 

In the 6-24-94 memorandum the required laboratory certification
methods were outlined and MSWLF Owners and Operators were
instructed to use "an appropriately certified method" for the
sample analysis.  For most of the metals a "low level"
certification method was specified.  In most cases this would make
a graphite furnace method necessary.  A common mistake was the use
of 6000 series Inductively Coupled Plasma (ICP) methods or Flame AA
methods for some or all of the metals that should have been
analyzed with a graphite furnace method.  

Please note the approved methods for analyzing metals samples:

-    Antimony, Beryllium, Cadmium, Chromium, Cobalt, Lead,
     Selenium, Thallium, and Vanadium require low level metals
     certification and therefore require graphite furnace methods. 
     
-    Arsenic and Selenium also require low level metals
     certification and therefore either a graphite furnace or a
     gaseous hydride analytical method.  

-    Barium, Copper, Nickel, and Zinc require a regular metals
     certification and therefore may be analyzed using an AA Flame
     or Inductively Coupled Plasma (ICP) methods.  

MSWLF Owners/Operators
Water Quality Monitoring
Page 2

The data should be reported at the specified Practical Quantitation
Limits (PQLs).  The method detection limits must be at or below the
specified PQLs.  

A summary table of certification levels, preferred analytical
methods, and Practical Quantitation Limits required for MSWLF water
quality metals sampling and analysis follows:  

PARAMETER     CERTIFICATION        METHOD         PQL in ppb

Antimony       low level           7041            30
Arsenic        low level           7060,7061       10
Barium         (20)                7080,6010      500
Beryllium      low level           7091             2
Cadmium        low level           7131             1
Chromium       low level           7191            10
Cobalt         low level           7201            10
Copper         regular level       7210,6010      200
Lead           low level           7421            10
Nickel         regular level       7520,6010       50
Selenium       low level           7740,7741       20
Silver         low level           7761            10
Thallium       low level           7841            10
Vanadium       low level           7911            40
Zinc           regular level       7950,6010       50

For the Appendix I volatile organic analysis the laboratory shall
be certified for an SW-846 GC/MS Method (8240 or 8260).  The method
detection limits must be at or below the PQLs specified on the
attachment - APPENDIX I ORGANIC CONSTITUENTS.  

Another problem with the reporting of the initial baseline sampling
event is that some MSWLF Owners and Operators did not report all
the information required.  If you have not already done so, you
should provide the following information along with the next
sampling report:

-Well Completion Records and Boring Logs for all newly constructed 
 monitoring wells;
-Hydraulic Conductivity values, porosity values, and effective  
porosity values for each monitoring well;

MSWLF Owners/Operators
Water Quality Monitoring
Page 3

-Calculations of ground-water flow directions and rates for each  
monitoring well (This is required for each sampling); and
-Results of the sampling analysis.  

The Subtitle D Rules and The N.C. Solid Waste Management Rules for
MSWLF units (the .1600 rules) do not specifically address seasonal
variation in water quality monitoring samples.  Therefore the Solid
Waste Section does not require that the baseline sampling account
for seasonal variations in ground-water quality.  However, the
Solid Waste Section would recommend that if your sampling schedule
allows, sampling be scheduled in such a way as to account for
seasonal variations in ground-water quality.  

The Solid Waste Management rules require all four sampling events
that comprise the baseline sampling to be completed and reported to
the Solid Waste Section on or before April 9, 1995.  

All future sampling and analysis at MSWLF facilities (including any
additional baseline sampling) is to be performed as directed in
this memorandum and the previous memorandum of June 24, 1994. 
Failure to use approved sampling and analysis methods and detection
limits will result in the need to resample.  




Attachment:APPENDIX I ORGANIC CONSTITUENTS