April 21, 1995 TO: Owners And Operators Of Currently Operating MSWLFs FROM: Solid Waste Section RE: Water Quality Monitoring For Appendix II Constituents This memorandum provides guidance on Solid Waste Section requirements for Appendix II monitoring of MSWLF Units, as required by Rule .1634 of the Solid Waste Management Rules. The memorandum suggests methods believed to be the most cost effective that will attain the desired Practical Quantitation Limits (PQLs). In order to reduce costs and the amount of water sample required for analyses, most organic analyses are best done by using methods 8260 and 8270. However these methods must utilize additional standards in order to attain all constituents on the Appendix II list. Rule .1634(a) Assessment monitoring is required whenever a statistically significant increase over background has been detected for one or more of the constituents listed in Appendix I or whenever a violation of the North Carolina ground-water quality standards (15A NCAC 2L, .0202) has occurred. Rule .1634(b) Within 90 days of triggering an assessment monitoring program, and annually thereafter, the owner or operator shall sample and analyze the ground water for all constituents identified in Appendix II of 40 CFR Part 258. The owner or operator is required by Rule .1633(c) to establish an assessment monitoring program within 90 days of determining that there is a statistically significant increase over background for one or more of the constituents listed in Appendix I. Since the baseline sampling reports were due on or before April 9, 1995, MSWLF unit owners or operators should have determined if assessment monitoring is necessary by this date. Therefore for those facilities that do trigger assessment monitoring, within 90 days (on or before July 9, 1995) the MSWLF unit owners or operators are required to sample and analyze the ground water from each detection monitoring well for all 213 constituents identified in Appendix II of 40 CFR 258. Appendix II Monitoring Page 2 MSWLF unit owners and operators are not to wait for direction from the Solid Waste Section to begin Appendix II monitoring. The rules require the MSWLF unit owner or operator, upon determining that Appendix II monitoring is necessary, to proceed with sampling and analysis for the Appendix II constituents within 90 days. GUIDANCE FOR APPENDIX II SAMPLING AND ANALYSIS All water quality analyses must be done by a laboratory certified by the N.C. Div. of Environmental Management for the appropriate methods. Data must be reported at levels equal or less than the PQLs listed, unless there is matrix interference or some documented technical problem that prevents attaining the required levels. The suggested methods are those believed to be the most cost effective that will attain the desired PQLs. Other SW-846 methods can be used for organic analyses if the required PQLs can be attained and if the lab is certified by DEM for use of the methods. Appendix I constituents are also part of the Appendix II list. The previous guidance provided in the memorandums of June 24, 1994, and January 18, 1995, continue to apply for these constituents. Note that regular ICP method 6010 is not acceptable for metals that require the low level certification. DEM has approved some laboratories for low level metals analysis using ICP/MS method 6020 and some laboratories for low level metals analyses using Trace ICP equipment. The Solid Waste Section will accept these methods in addition to the graphite furnace methods delineated in the 1-18-95 memo if the laboratory is certified by DEM for low level analyses using one of these newer methods. Other Inorganic Parameters PARAMETER CERTIFICATION METHODS PQL in ppb Cyanide Cyanide (12) 9010, 9012 50 Mercury Mercury (21) 7470 0.5 Sulfide Sulfide (38) 9030 1000 Tin 6010, 282.2 100 Chlorinated Herbicides by certified method 8150 or 8151 PARAMETER PQL in ppb 2,4-D; 2,4-Dichlorophenoxyacetic acid 2 Dinoseb; DNBP; 2-sec-Butyl-4,6-dinitrophenol 1 Silvex; 2,4,5-TP 2 2,4,5-T; 2,4,5-Trichlorophenoxyacetic acid 2 Appendix II Monitoring Page 3 Organochlorine Pesticides and PCBs by certified method 8080 or 8081 PARAMETER PQL in ppb Aldrin 0.05 alpha-BHC 0.05 beta-BHC 0.05 delta-BHC 0.05 gamma-BHC; Lindane 0.05 Chlordane 0.50 4,4-DDD 0.10 4,4-DDE 0.10 4,4-DDT 0.10 Dieldrin 0.10 Endosulfan I 0.10 Endosulfan II 0.10 Endosulfan sulfate 0.10 Endrin 0.10 Endrin aldehyde 0.10 Heptachlor 0.05 Heptachlor epoxide 0.10 Methoxychlor 1.00 Polychlorinated biphenyls; PCBs; Aroclors 2.00 Toxaphene 2.00 Most of the other Appendix II organic compounds can be analyzed using either method 8260 or method 8270. Although the Subtitle D Federal Register does not list one of these methods for the following six parameters, the Solid Waste Section will accept method 8260 or 8270 for these compounds: PARAMETER METHOD PQL in ppb Acetonitrile; Methyl cyanide 8260 100 Bis(2-ethylhexyl) phthalate 8270 20 Nnitrosodimethylamine 8270 10 Nnitrosodiphenylamine 8270 10 Nnitrosodipropylamine 8270 10 Phenol 8270 10 Appendix II Monitoring Page 4 Volatile Organic Compounds by certified method 8260 or 8240 In addition to the Appendix I VOCs the Subtitle D Federal Register has eighteen additional organic constituents that list method 8260 or 8240 as an acceptable method: PARAMETER PQL in ppb Acrolein 100 Allyl chloride 10 Chloroprene 20 m-Dichlorobenzene; 1,3-Dichlorobenzene* 10 Dichlorodifluoromethane; CFC 1 5 1,3-Dichloropropane 5 2,2-Dichloropropane 15 1,1-Dichloropropene 5 Ethyl methacrylate * 10 Hexachlorobutadiene* 10 Hexachloroethane* 10 Isobutyl alcohol 100 Isodrin* 20 Methacrylonitrile 100 Methyl methacrylate 30 Naphthalene* 10 Propionitrile; Ethyl cyanide 150 1,2,4-Trichlorobenzene* 10 Note: The constituents with an asterik (*) in the above list of volatile organic compounds may also be analyzed using method 8270 if comparable PQLs are attained. All additional organic compounds on the Appendix II list that have not yet been specifically referenced in this memorandum can be analyzed using method 8270. The reporting levels (PQLs) are those listed in the Subtitle D Federal Register for these compounds using method 8270. Although method 8270 is believed to be the most economic way to analyze the additional organic compounds, the Solid Waste Section will accept the use of other SW-846 methods referenced in the Subtitle D Federal Register, if PQLs comparable to those listed for method 8270 can be attained and if the laboratory is certified by DEM for the method used. Any questions regarding these guidelines for Appendix II sampling and analyses may be referred to the Solid Waste Section at (919) 733-0692.