For questions C23 and C24, what type of estimation (e.g., mass balance) should a facility use in completing the survey?
EPA does not require the use of a particular estimation technique. However, unless the facility notes the technique used, EPA will assume a mass balance technique. Q: For C24f, a facility does not directly collect leachate from their surface impoundment but has some groundwater monitoring wells nearby. Can the facility use the concentrations of Appendix 2 chemicals in the groundwater monitoring wells to report the requested leachate data in C24f? A: Yes, if the facility feels the groundwater data best represents the leachate values (i.e., there are no other sources nearby that affect the concentrations in the groundwater, and the groundwater data represents the leachate during the time period requested in the survey). If the facility does use groundwater data rather than leachate data, the facility should annotate the hard copy of the survey to specify that the data source is not actual leachate data, but is groundwater data. Q: Table C25 asks for information about upsets and overtoppi
Related Questions
- Should facilities develop programs if they do not have one at present before completing and returning the facility process survey?
- For questions C23 and C24, what type of estimation (e.g., mass balance) should a facility use in completing the survey?
- How accurate does the quantity check / mass balance on traceability need to be as specified in clause 3.9.2?
