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PARTON 19
statement that affected
facilities must implement a detection monitoring program after permit issuance
does not imply that your facility is no longer subject to Part 265 Subpart
F requirements prior to permit issuance.
The University of Arizona -
Page Ranch site is currently in a state of non-compliance with 40 CFR Part
265 Subpart F and ACRR R9-8-1821 .A.2 As stated in item #6 of my last letter
to you (January 12, 1983; HW 1372), these requirements must be addressed,
either by submittal of a plan describing the installation of a groundwater
monitoring system, or by the submittal of a certified demonstration which
states the reasons why the requirements for monitoring should be waived,
and addresses all items contained in 40 CFR 265.90(c). Your groundwater
monitoring submittal of March 7, 1983 alludes to the choice of the waiver
demonstration to fufill these requirements, and mentions a request which
has already been made to a certified University geologist to preare(sic)
the necessary documentation. The completed waiver demonstration must be
submitted to the Bureau of Waste Control no later than April 22, 1983.
(23)
Following
shortly thereafter, on March 24,1983 more pressure was brought to bear
on the University. On that day, Randy Marcus of the Field Inspections Sections,
EPA Region IX conducted an inspection of the Page-Trowbridge site. He sent
a notice to R. Bruce Scott, P.E. , Chief, Bureau of Waste Control, Arizona
Department of Health Services on May 27,1983. The resulting correspondence
states:
“The purpose of this
letter is to provide notice, pursuant to section 3008(a)(2) of RCRA that
EPA has found the University of Arizona, Page Trowbridge Ranch Disposal
Facility to be in violation of various State requirements contained in
ACRR Article 18, and various Federal requirements contained in 40 CFR Part
265.
The following deficiencies
were observed during the records review and facility inspection:
1.
40 CFR Subpart F, ACRR R9-8-1821.A.2
The facility has not implemented
a groundwater monitoring program capable of
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