Hazardous Waste: Compliance With Groundwater Monitoring Requirements at
Land Disposal Facilities (Briefing Report, 02/07/95, GAO/RCED-95-75BR).

Pursuant to a congressional request, GAO provided information on the
Environmental Protection Agency's (EPA) groundwater monitoring
requirements for hazardous waste land disposal facilities, focusing on
the number of facilities that: (1) are subject to groundwater monitoring
requirements; (2) have monitoring systems in place; (3) have released
pollutants into the underlying groundwater; (4) have initiated
corrective actions; and (5) have been issued citations for groundwater
monitoring violations.

GAO found that: (1) of the 1,209 facilities reviewed, about 976 had
monitoring systems capable of immediately detecting groundwater
releases, 169 had some monitoring wells that were not capable of
detecting a release, and 54 had no monitoring wells in place; (2) of the
890 facilities where releases occurred, about 608 had groundwater
monitoring systems capable of determining the rate and extent of
migration and the concentrations of hazardous waste in groundwater, 260
facilities had some monitoring wells that were not capable of fully
assessing groundwater releases, and 15 facilities had no wells; (3)
there was incomplete data on the capability of groundwater monitoring
systems at 7 facilities; (4) all facilities were not required to assess
releases into the groundwater; (5) 606 facilities have initiated
corrective actions to prevent further groundwater contamination and 261
facilities have not initiated any corrective actions; (6) since October
1989, 650 of the 1,209 facilities have been cited for groundwater
monitoring violations; (7) the most frequent types of monitoring
violations cited were sampling and analysis violations; and (8) as of
September 1993, 211 of the 650 facilities were not in compliance with
EPA regulations.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-95-75BR
     TITLE:  Hazardous Waste: Compliance With Groundwater Monitoring 
             Requirements at Land Disposal Facilities
      DATE:  02/07/95
   SUBJECT:  Pollution monitoring
             Water quality
             Water pollution control
             Industrial facilities
             Health hazards
             Safety standards
             Environmental policies
             Hazardous substances
             Waste disposal
             Potable water
IDENTIFIER:  EPA Resource Conservation and Recovery Information System
             
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Cover
================================================================ COVER


Briefing Report to the Ranking Minority Member, Committee on
Governmental Affairs, U.S.  Senate

February 1995

HAZARDOUS WASTE - COMPLIANCE WITH
GROUNDWATER MONITORING
REQUIREMENTS AT LAND DISPOSAL
FACILITIES

GAO/RCED-95-75BR

Hazardous Waste


Abbreviations
=============================================================== ABBREV

  EPA - Environmental Protection Agency
  GAO - General Accounting Office
  RCRA - Resource Conservation and Recovery Act
  RCRIS - Resource Conservation and Recovery Information System

Letter
=============================================================== LETTER


B-259701

February 7, 1995

The Honorable John Glenn
Ranking Minority Member
Committee on Governmental Affairs
United States Senate

Dear Senator Glenn: 

Groundwater is a major source of drinking water for many parts of the
nation.  If not properly constructed, land disposal facilities for
hazardous waste may result in the leakage or release of pollutants
and contaminants into the underlying groundwater.  Through the
enactment of the Resource Conservation and Recovery Act (RCRA) of
1976, the Congress sought to impose, among other things, control over
land disposal facilities to minimize their potential adverse
environmental impacts. 

As part of its effort to implement the act, the Environmental
Protection Agency (EPA) issued regulations generally requiring that
owners/operators of land disposal facilities used to manage hazardous
waste on or after November 19, 1980, install wells to monitor the
groundwater under their facilities.  The regulations' objectives were
to immediately detect releases of hazardous waste.  If a release is
detected, owners/operators must assess the rate and extent of
migration and the concentrations of hazardous waste in the
groundwater and may be required to take corrective action to rectify
any adverse environmental impact caused by the facility. 

This briefing report responds to your request that we provide you
with information on the implementation of EPA's groundwater
monitoring requirements for hazardous waste land disposal facilities. 
Specifically, we are providing information on the number of (1) land
disposal facilities subject to groundwater monitoring requirements
and whether monitoring systems have been installed, (2) facilities
where releases to the groundwater have occurred, (3) corrective
actions that have been taken to prevent further groundwater
contamination, and (4) citations that have been issued for
groundwater monitoring violations.  This briefing report summarizes
the information we provided to your staff during a briefing on
January 31, 1995. 

To obtain data for the request, we surveyed EPA and state hazardous
waste officials in March 1994.  However, we did not independently
confirm the information provided to us by the survey respondents.  In
summary, we identified 1,209 hazardous waste land disposal facilities
that must comply with EPA's groundwater monitoring requirements.  For
these facilities, respondents reported the following: 

At 976 facilities, or about 81 percent, all required monitoring
systems are capable of immediately detecting if a release to the
groundwater has occurred.  Another 169 facilities, or about 14
percent, have some monitoring wells in place, but not all required
systems are capable of immediately detecting a release.  Only 54
facilities have no monitoring wells in place.  We were unable to
obtain complete data on the monitoring systems of the remaining 10
facilities. 

Releases have occurred at 890, or almost 74 percent, of the
facilities.  At 608, or about 68 percent, of these facilities, all
groundwater monitoring systems are capable of determining the rate
and extent of migration and the concentrations of hazardous waste in
the groundwater.  Of the remaining 282 facilities, 260, or about 29
percent, have some monitoring wells, but the systems may not be
capable of fully assessing releases to the groundwater.  However, not
all facilities where releases have occurred are required to assess
releases into the groundwater.  At 15 other facilities, no wells have
been installed.  We were unable to obtain complete data on the
capability of groundwater monitoring systems for seven facilities. 

Corrective action to prevent further groundwater contamination has
been initiated at 606, or about 68 percent, of the 890 facilities
where releases have occurred.  Corrective action has not been
initiated at 261 facilities where releases have occurred. 
Questionnaire respondents were unsure of the corrective status for
the remaining 23 facilities. 

Groundwater monitoring violations have been cited at 650, or about 54
percent, of the 1,209 facilities since October 1, 1989.  Sampling and
analysis violations were the most frequent type of monitoring
violation cited.  As of September 30, 1993,\1 211 of the 650
facilities were not in compliance with EPA's regulations. 

Section 1 of this briefing report provides additional information on
RCRA and the groundwater monitoring requirements.  Section 2
discusses the universe of hazardous waste land disposal facilities
subject to groundwater monitoring requirements and the extent to
which these facilities have installed groundwater monitoring systems
capable of immediately detecting a release of contaminants into the
groundwater.  Section 3 discusses facilities where releases have
occurred, whether such facilities have groundwater monitoring systems
that can assess those releases, and the status of corrective action
at those facilities.  Section 4 discusses groundwater monitoring
violations. 

To identify hazardous waste land disposal facilities subject to EPA's
groundwater monitoring regulations, we obtained data from the
agency's Resource Conservation and Recovery Information System
(RCRIS).  RCRIS contains inspection, enforcement, and permit data on
hazardous waste facilities nationwide.  We then developed a
questionnaire for the 1,427 land disposal facilities identified in
RCRIS and mailed it to EPA regions and to states and territories
authorized to administer their own RCRA programs.  We asked the
hazardous waste program officials who received the questionnaires to
confirm whether each of the 1,427 facilities identified by RCRIS were
subject to EPA's groundwater monitoring requirements and, if so, the
status of each facility's compliance with those requirements.  We
also asked if the officials were aware of any additional facilities
subject to these requirements. 

Of the 1,427 questionnaires we distributed, 1,406, or almost 99
percent, were returned.  Of these 1,406 questionnaires, 1,119, or
about 80 percent, confirmed that the facility is subject to
groundwater monitoring requirements.  The respondents completed
questionnaires for an additional 90 facilities that they cited as
being subject to groundwater monitoring requirements.  Thus, we
obtained and subsequently analyzed groundwater monitoring information
for a total of 1,209 facilities.  Appendix I provides details on our
scope and methodology, and appendix II contains the questionnaire. 
We performed our work from July 1993 to December 1994 in accordance
with generally accepted government auditing standards. 

We did not obtain written agency comments on a draft of this briefing
report.  However, we discussed a draft of the report with officials
in EPA's Office of Enforcement and Compliance Assurance--including
Branch Chiefs in the agency's Chemical, Commercial Services and
Municipal Division and Regional Support Division--and Offices of
Solid Waste and of Ground Water and Drinking Water.  The officials
generally concurred with the information presented in the briefing
report.  However, the officials suggested that we revise the report
to clarify that the agency treats assessment monitoring and
corrective action as one single approach to addressing groundwater
contamination.  We revised the report to include this and a few minor
technical comments where appropriate. 


--------------------
\1 This briefing report contains the most recent information that was
available at the time our survey was distributed. 


---------------------------------------------------------- Letter :0.1

As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this briefing
report until 30 days after the date of this letter.  At that time, we
will send copies of the briefing report to the Administrator of EPA. 
We will also make copies available to others upon request. 

Please contact me at (202) 512-6112 if you or your staff have any
questions.  Major contributors to this briefing report are listed in
appendix III. 

Sincerely yours,

Peter F.  Guerrero
Director, Environmental
 Protection Issues


Section 1 GROUNDWATER MONITORING
AND RCRA
============================================================== Letter 

   Cross Section of a Minimal
   Groundwater Monitoring System

   (See figure in printed
   edition.)

Groundwater is the source of drinking water for about 50 percent of
the nation's total population and nearly all of its rural population. 
Hazardous waste land disposal facilities present a direct
contamination threat to groundwater because rain and snowmelt
entering the soil can leach the hazardous constituents from such
facilities and carry these contaminants to the groundwater. 
Depending upon the underlying terrain, the rate of groundwater flow,
and the type and amount of constituents released from facilities,
contaminated groundwater can easily migrate off-site and adversely
affect groundwater users.  Contaminated groundwater can cause cancer
and other serious health problems, and clean-up of groundwater is
costly and difficult, if not impossible, to achieve. 

Groundwater monitoring is the principal means of detecting
contamination at hazardous waste land disposal facilities. 
Groundwater monitoring systems normally consist of a number of wells
placed in strategic locations and depths around a facility's disposal
units.\1 Wells, which are referred to as "upgradient wells," are
required to determine the quality of the groundwater before it
reaches the facility, and additional wells, which are referred to as
"downgradient wells," are needed to determine the groundwater quality
after it passes under or by the facility.  If the wells are properly
located, comparison of data from upgradient and downgradient wells
should indicate if contamination is occurring at the facility. 



   (See figure in printed
   edition.)

The Resource Conservation and Recovery Act (RCRA), an amendment of
the Solid Waste Disposal Act of 1965, was enacted in 1976.  One of
RCRA's stated objectives is to ensure that hazardous waste management
practices are conducted in a manner that protects human health and
the environment.  RCRA allows the Environmental Protection Agency
(EPA) to authorize states to implement their own RCRA programs if the
programs are determined to be equivalent to and consistent with EPA's
and provide for adequate enforcement.  Currently, 46 states, the
District of Columbia, and Guam have received such authorization.  EPA
has responsibility for implementing RCRA in the remaining states. 

Under RCRA, hazardous waste land disposal facilities are required to
obtain permits in order to accept and dispose of hazardous waste or
to close their operations.  The Congress established an interim
status period that allowed facilities in existence on November 19,
1980, who met certain conditions, to continue operating until their
permit applications were approved or denied. 

The Congress, concerned with EPA's limited progress in implementing
the RCRA program, amended RCRA in 1984 to, among other things,
require that all land disposal facilities certify compliance with the
basic interim status program requirements and apply for an operating
permit by November 1985.  Facilities that failed to do so by November
8, 1985, lost interim status and were required to close within the
next 14 months (by Jan.  1987).  If these facilities did not remove
all waste and contaminated soil, they must apply for a post-closure
permit that describes, among other things, what corrective action
will be taken to abate any contamination and how monitoring the
facility for leakage for generally 30 years will occur. 



   (See figure in printed
   edition.)

EPA promulgated initial RCRA groundwater monitoring requirements on
May 19, 1980,\2 in order to assess the impact of a facility on the
groundwater beneath it.  These requirements apply only to interim
status facilities.  All or part of the requirements may be waived if
a facility can demonstrate that there is a low potential of migration
of contaminants to water supply wells or to surface water.  Under the
requirements, by November 1981, owners/operators of existing land
disposal facilities were to install a groundwater monitoring system
consisting of a minimum of one upgradient well and three downgradient
wells.  The hydrogeology of the site,\3

however, may require that the owners/operators install more than one
system.  Once wells are installed, owners/operators are required to
collect quarterly data for 1 year to establish background
concentrations for selected chemicals.  Routine detection monitoring
is then required.  In the event that a significant increase of
contaminants is confirmed, owners/operators must implement a quality
assessment program to determine what is contaminating the
groundwater, the rate and extent of contaminant migration, and the
concentrations of hazardous waste in the groundwater.  If the
assessment shows hazardous waste contamination, the owners/operators
must continue assessing the groundwater until the facility is closed. 
Upon closure, monitoring is required unless the facility removes all
waste and contaminated soil. 

On July 26, 1982, EPA issued final groundwater monitoring
regulations.\4 The regulations apply to land disposal units at
hazardous waste facilities that received waste after this date. 
These units are referred to as "regulated units." The final
regulations are similar to the interim status requirements and
require a detection monitoring program and a compliance monitoring
program.  The regulations also establish a corrective action program. 
Detection monitoring is similar to the interim status detection
monitoring requirement and is used to determine whether hazardous
wastes are leaking at levels great enough to warrant compliance
monitoring.  Compliance monitoring is similar to the interim status
assessment monitoring requirement and is used to determine whether
groundwater contamination is occurring at a level requiring
corrective action.  Corrective action applies only to cleaning up or
containing contamination resulting from releases at regulated
units.\5

Section 2

--------------------
\1 A unit refers to a surface impoundment, waste pile, land treatment
unit, or landfill.  A facility may have more than one unit and/or
several types of units. 

\2 40 C.F.R.  part 265, subpart F. 

\3 Hydrogeology is the science dealing with the behavior of
groundwater. 

\4 40 C.F.R.  part 264, subpart F. 

\5 In general, if EPA discovers any contamination, it will evaluate
the entire facility for additional contamination at both regulated
units and those that stopped receiving waste before July 27, 1982. 
Depending on the source of the contamination, EPA can use several
statutory and regulatory authorities to more comprehensively and
efficiently address all contamination problems at a facility at the
same time. 


NUMBER OF FACILITIES SUBJECT TO
GROUNDWATER MONITORING
REQUIREMENTS AND DETECTION
MONITORING CAPABILITIES
============================================================== Letter 



   (See figure in printed
   edition.)


   NUMBER OF FACILITIES SUBJECT TO
   GROUNDWATER MONITORING
   REQUIREMENTS
------------------------------------------------------------ Letter :1

Through a survey of EPA and state hazardous waste officials, we
identified 1,209 hazardous waste land disposal facilities nationwide
that are subject to groundwater monitoring requirements as of March
1994.  This number is comparable to the number of facilities found by
the Subcommittee on Oversight and Investigations, House Committee on
Energy and Commerce, in a 1985 groundwater monitoring survey.\1 The
Subcommittee found that 1,246 facilities were subject to the
groundwater monitoring requirements. 

Texas and Ohio have the greatest number of facilities subject to the
requirements (130 and 76, respectively), while Vermont, Rhode Island,
and South Dakota have none.  States and territories have, on average,
23 facilities subject to the requirements. 

About 77 percent of the facilities require only one groundwater
monitoring system in order to determine if a release has occurred. 
Due to hydrogeological conditions, the remainder of the facilities
require from 2 to 17 systems. 



   (See figure in printed
   edition.)


--------------------
\1 Groundwater Monitoring Survey, Subcommittee on Oversight and
Investigations, House Committee on Energy and Commerce, U.S. 
Government Printing Office, (Apr.  1985). 


   DETECTION MONITORING
   CAPABILITIES
------------------------------------------------------------ Letter :2

Respondents to our questionnaire reported that all required
monitoring systems at 976, or about 81 percent, of the 1,209
facilities subject to groundwater monitoring requirements are capable
of determining if a release has occurred to the groundwater.  At 169
facilities, or about 14 percent, some monitoring wells are in place,
but either (1) the groundwater monitoring system is not capable of
immediately detecting if a release has occurred or (2) if more than
one system is required, not all are capable of such detection.  At
the remaining 54 facilities, or about 4 percent, no wells are in
place.  The respondents did not provide complete data on the
monitoring systems at 10, or less than 1 percent, of the facilities. 

   Detection Monitoring
   Capabilities, by State

   (See figure in printed
   edition.)

Monitoring system capabilities vary among the 47 states and 3
territories where the 1,209 hazardous waste land disposal facilities
are located.  All facilities in 10 states and 1 territory have
groundwater monitoring systems fully capable of detecting releases. 
At least 75 percent of the facilities have such systems in 23 states
and 1 territory.  In another 12 states and 1 territory, 50 percent or
more of the facilities have systems fully capable of detecting
releases.  Less than one-half of the facilities in the remaining two
states are fully capable of detecting releases. 

On the basis of the information the respondents provided for 47
states and 3 territories, 4 states (Illinois, Indiana, Ohio, and
Texas) account for over one-third of the facilities nationwide that
have either no monitoring wells or one or more monitoring systems
that are not fully capable of detecting releases to the groundwater. 


Section 3 ENVIRONMENTAL IMPACT OF
FACILITIES
============================================================== Letter 



   (See figure in printed
   edition.)


   RELEASES TO THE GROUNDWATER
------------------------------------------------------------ Letter :3

The questionnaire respondents reported that most land disposal
facilities have had a release of contaminants to the groundwater
since they began receiving hazardous waste.  Of the 1,209 facilities
subject to the groundwater monitoring requirements, 890, or almost 74
percent, have had a release.  Conversely, releases have not occurred
at 156 (about 13 percent) of the facilities.  The respondents were
unsure whether 162 (about 13 percent) facilities have had a release,
and information regarding releases was not provided for 1 facility. 

In the four states (Illinois, Indiana, Ohio, and Texas) that account
for over one-third of the facilities nationwide that have either no
monitoring wells or one or more monitoring systems not fully capable
of detecting releases, the respondents reported that 59 percent of
the facilities have had a release and 16 percent have not had a
release.  The respondents were unsure whether the remaining 25
percent have had a release. 



   (See figure in printed
   edition.)

Nationally, releases occurred from only regulated units--units that
received waste after July 26, 1982--at 360 facilities.  At 384
facilities, releases occurred from both regulated units and units
that had stopped receiving waste prior to July 27, 1982.  At 97
facilities, releases occurred from only those units that stopped
receiving waste prior to July 27, 1982.  The respondents were unsure
what type of units had releases at the remaining 49 facilities. 



   (See figure in printed
   edition.)


   ASSESSMENT MONITORING
   CAPABILITIES AND CORRECTIVE
   ACTION
------------------------------------------------------------ Letter :4

The questionnaire respondents reported that at the 890 facilities
where releases have occurred, 608, or about 68 percent, have
groundwater monitoring systems that are fully capable of assessing
the rate and extent of migration and the concentrations of hazardous
waste in the groundwater.  Of the remaining facilities, 260 have some
monitoring wells, but the systems may not be capable of fully
assessing releases to the groundwater, if required.\1

Although 153 of these facilities (about 17 percent) have systems
capable of determining if a release has occurred but not fully
capable of assessing such releases, another 107 facilities (about 12
percent), have some systems that are not capable of detecting
releases.  Also, 15 facilities, or about 2 percent, have installed no
monitoring wells.  Finally, the respondents did not provide complete
data on the status of groundwater monitoring systems for seven
facilities (less than 1 percent). 



   (See figure in printed
   edition.)

The questionnaire respondents reported that owners/operators of 606
of the 890 facilities (about 68 percent) where releases have occurred
have taken corrective action to remove and/or treat hazardous
constituents to prevent further groundwater contamination. 
Conversely, 261, or about 29 percent, of the facilities have not
initiated corrective action.  The respondents were unsure about the
corrective action status of the remaining 23 facilities. 



   (See figure in printed
   edition.)

Of the 606 facilities that have initiated corrective action, 438, or
about 72 percent, reportedly have systems capable of both detecting
and assessing releases.  Eighty-four facilities, or about 14 percent,
have systems capable of detecting but not assessing releases.\2
Another 73 facilities, or about 12 percent, have some systems that
are not capable of either detecting or assessing releases.  Eight
facilities, or about 1 percent, have installed no monitoring wells. 
The questionnaire respondents have incomplete data on the status of
groundwater monitoring systems at the remaining three facilities, or
about 1 percent. 



   (See figure in printed
   edition.)

   Note:  Numbers do not add to
   100 percent because of
   rounding.

   (See figure in printed
   edition.)

Of the 261 facilities that have not initiated corrective action, 153,
or about 59 percent, reportedly have systems capable of both
detecting and assessing releases.  In addition, 65 facilities, or
about 25 percent, have systems capable of detecting but not assessing
releases.  Another 33 facilities, or about 13 percent, have some
systems that are not capable of either detecting or assessing
releases.  Six facilities, or about 2 percent, have installed no
monitoring wells.  The questionnaire respondents have incomplete data
on the status of groundwater monitoring systems at the remaining four
facilities, or about 2 percent. 

Section 4

--------------------
\1 Not all groundwater monitoring systems at the 890 facilities where
releases have occurred may be required to assess releases into the
groundwater.  A facility may have multiple land disposal units that
require separate systems.  However, a system need not be capable of
assessment monitoring unless a release has occurred from a unit the
system monitors.  In addition, units that stopped receiving waste
before November 19, 1980, are not subject to these groundwater
monitoring requirements. 

\2 As noted earlier, all systems may not be required to assess
releases. 


GROUNDWATER MONITORING VIOLATIONS
============================================================== Letter 



   (See figure in printed
   edition.)


   VIOLATIONS CITED SINCE OCTOBER
   1989
------------------------------------------------------------ Letter :5

Of the 1,209 facilities subject to groundwater monitoring
requirements, 650, or about 54 percent, were cited for groundwater
monitoring violations between October 1, 1989, and March 10, 1994. 
The most prevalent types of violations cited during this time period
were (1) sampling and analysis violations and (2) inadequate number
or placement of monitoring wells.  Sampling and analysis violations
were found at 328 facilities, or about 27 percent, while an
inadequate number or placement of wells was found at 286 facilities,
or about 24 percent. 

Groundwater monitoring violations vary in their degree of
seriousness.  Failure to perform sampling and analysis is a serious
violation because it may result in a failure to detect changes in
groundwater quality.  Likewise, having an inadequate groundwater
monitoring system may allow hazardous waste to remain undetected
until a large volume of waste or leachate has been released to the
groundwater.  Other violations, such as minor deviations from record
keeping requirements, that do not impede compliance monitoring or
enforcement efforts are less serious. 



   (See figure in printed
   edition.)

   Note:  Numbers do not add to
   100 percent because of
   rounding.

   (See figure in printed
   edition.)


   OUTSTANDING GROUNDWATER
   MONITORING VIOLATIONS AS OF
   SEPTEMBER 30, 1993
------------------------------------------------------------ Letter :6

As of September 30, 1993, 211, or about 32 percent, of the 650
facilities that were cited for groundwater monitoring violations in
the prior 4 years had outstanding Class I groundwater monitoring
violations.\1 About 91 percent of these facilities have had
outstanding violations for 1 or more years, while 9 percent have had
outstanding violations for more than 10 years. 

Of the 211 facilities, 116, or about 55 percent, are considered by
questionnaire respondents to be "very likely" or "somewhat likely" to
comply with the groundwater monitoring requirements.  Another 24
facilities, or about 11 percent, are considered as likely as not to
comply.  In addition, 54 facilities, or about 26 percent, are
considered "somewhat unlikely" or "very unlikely" to comply.  The
respondents were unsure whether 16 facilities, or nearly 8 percent,
would return to compliance, and information was not provided for 1
facility. 



   (See figure in printed
   edition.)

The reasons why facilities have not complied with groundwater
monitoring requirements vary.  The questionnaire respondents' most
frequently cited reason was disagreement over
technical/administrative requirements.  Recalcitrance, or resistance
to authority, was the second most frequent reason given.  In
addition, many of the respondents provided other reasons for
noncompliance.  Bankruptcy and a failure to understand the
regulations were the two most frequently cited other reasons for
noncompliance. 



                                    Table 4.1
                     
                      Violation Status Based on Groundwater
                      Monitoring Capability, as of September
                                     30, 1993

                                                  Number and
                                                (percent) of
                                    Number and    facilities
                                  (percent) of        out of
Groundwater                Total    facilities    compliance  Most frequently
monitoring             number of          with     more than  cited reason for
capability            facilities    violations       5 years  noncompliance
--------------------  ----------  ------------  ------------  ------------------
No wells                      54        22(41)        12(22)  Lack of funds
Some wells; all              169        66(39)        32(19)  Disagreement over
 systems not capable                                           requirements
 of detection
 monitoring
All systems capable          194        55(28)         16(8)  Disagreement over
 of detection                                                  requirements
 monitoring but not
 assessment
 monitoring
All systems capable          782         64(8)         11(1)  Disagreement over
 of detection and                                              requirements
 assessment
 monitoring
Total                    1,199\a       207(17)         72(6)
--------------------------------------------------------------------------------
\a The questionnaire respondents did not provide data on the
groundwater monitoring capabilities of 10 facilities; therefore, the
facilities are not included in this table. 

The number of facilities that have outstanding Class I groundwater
monitoring violations,\2 the length of time they have been out of
compliance, and the most frequently cited reason for their failure to
comply varies depending on whether owners/operators have installed
adequate groundwater monitoring systems.  As expected, a higher
percentage of facilities without monitoring wells had outstanding
Class I violations and were out of compliance as of September 30,
1993.  Lack of owner/operator funds was the most frequently cited
reason for why these facilities were out of compliance. 


--------------------
\1 EPA classifies RCRA violations into one of two categories.  A
Class I violation is any deviation from EPA regulations, provision of
compliance orders, consent degrees, or permit conditions that could
result in a failure to (1) ensure hazardous waste is destined for and
delivered to authorized treatment, storage, or disposal facilities;
(2) prevent releases; (3) ensure early detection of releases; or (4)
perform corrective action for releases.  A Class II violation is any
other violation of a RCRA requirement. 

\2 Additional facilities may have outstanding Class I monitoring
violations.  However, because our questionnaire only asked for
information on facilities that had been notified of violations
detected since October 1, 1989, information was not obtained on
facilities notified of violations detected prior to that time. 


SCOPE AND METHODOLOGY
=========================================================== Appendix I

To determine the universe of hazardous waste land disposal facilities
subject to groundwater monitoring, we obtained data from the
Environmental Protection Agency's (EPA) Resource Conservation and
Recovery Information System (RCRIS).\1 As of August 1993, RCRIS data
indicated that 1,427 facilities were subject to monitoring
requirements. 

We developed a questionnaire and distributed it to EPA regions and
authorized states and territories to obtain data on the extent of
groundwater monitoring compliance for each of the 1,427 facilities. 
In instances where states and territories are not authorized to
administer the Resource Conservation and Recovery Act (RCRA) program,
we sent the questionnaire(s) to the respective EPA regional office. 
We asked respondents to confirm whether each facility is subject to
groundwater monitoring requirements and requested that they complete
questionnaires for any additional facilities not identified by RCRIS
that are subject to the requirements.  We also contacted three states
that had no facilities among the 1,427 to confirm that no hazardous
waste land disposal facilities in their respective states are subject
to the requirements. 

We received responses for 1,406, or almost 99 percent, of the 1,427
facilities.  According to the respondents, 1,119, or about 80
percent, of these facilities are required to comply with EPA's
groundwater monitoring requirements.\2 We also received
questionnaires for an additional 90 facilities identified by the
respondents as being subject to RCRA groundwater monitoring
requirements that were not identified by RCRIS as being subject to
the requirements.  Therefore, the universe of facilities subject to
the monitoring requirements is 1,209. 

We determined whether facilities subject to groundwater monitoring
requirements have monitoring systems in place and the capabilities of
those systems.  For example, we determined how many facilities have
all required systems in place versus those that have only some or no
systems in place.  Of those that have some or all required systems in
place, we compiled information on (1) how many were capable of
immediately detecting releases and (2) how many were adequate to
determine the rate and extent of migration and concentration of
hazardous wastes in the groundwater.  We then cross-tabulated this
information with additional questionnaire data on groundwater
violations, environmental impact, and corrective action.  We did not
report on the data we obtained concerning the potential effects posed
by releases to the groundwater (questions 20 and 21) because the
responses received were subjective, and respondents based their
assessment of potential effects on different criteria.  As a result,
we are unable to rely on respondents' answers to these questions in
analyzing questionnaire data.  We did not independently confirm the
information provided to us by the respondents. 

We performed our work from July 1993 to December 1994 in accordance
with generally accepted government auditing standards. 



(See figure in printed edition.)Appendix II

--------------------
\1 RCRIS contains inspection, enforcement, and permitting data on
hazardous waste facilities. 

\2 The reasons why 287 facilities are not subject to the requirements
vary.  Some facilities have no regulated land disposal units, while
groundwater monitoring requirements have been waived for others.  At
other facilities, all hazardous waste and waste residues were removed
from regulated units during the closure process. 


SURVEY ON THE ADEQUACY OF
GROUNDWATER MONITORING AT LAND
DISPOSAL FACILITIES
=========================================================== Appendix I



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)


MAJOR CONTRIBUTORS TO THIS
BRIEFING REPORT
========================================================= Appendix III

ENVIRONMENTAL PROTECTION ISSUES

Kelly S.  Ervin, Social Science Analyst
Michael H.  Harmond, Staff Evaluator
Gerald E.  Killian, Assistant Director
Marcia B.  McWreath, Senior Evaluator
Deborah S.  Ortega, Evaluator-in-Charge
Dorothy M.  Tejada, Computer Specialist

