SINCE THE RESPONDENT DID NOT INCLUDE THE F006 LISTED WASTE IN THE ORIGINAL PART A APPLICATION OR SUBMIT A REVISED PART A APPLICATION TO INCLUDE SAID WASTE PRIOR TO THE JULY 20, 1983, INSPECTTION, RESPONDENT VIOLATED 40 CFR 270.13(J) AND 270.71(A)(1). ON FEBRUARY 1, 1984, RESPONDENT SUBMITTED A REVISED PART A APPLICATION TO INCLUDE THE LISTED HAZARDOUS WASTE F006. REGULATION 40 CFR 265.90(A) REQUIRES AN OWNER/OPERATOR TO IMPLEMENT A GROUNDWATER MONITORING PROGRAM CAPABLE OF DETER- MINING THE IMPACT OF THE FACILITY'S SURFACE IMPOUNDMENTS ON THE QUALITY OF GROUNDWATER IN THE UPPERMOST AQUIFER UNDER- LYING THE FACILITY BY NOVEMBER 19, 1981. AT THE TIME OF THE NOVEMBER 2, 1983, INSPECTION CONDUCTED BY MDNR, THE OWNER/OPERATOR HAD NOT IMPLEMENTED A GROUND- WATER MONITORING PROGRAM AND COULD NOT PROVIDE A WRITTEN GROUNDWATER MONITORING WAIVER DEMONSTRATION FOR THE FACILI- TY. THEREFORE, THE RESPONDENT VIOLATED 40 CFR 265.90(A). REGULATIONS 40 CFR 265.91, 265.92, 265.93 AND 265.94 ADDRESS SEVERAL COMPONENTS OF THE GROUNDWATER MONITORING PROGRAM. IN FAILING TO INITIATE A TIMELY GROUNDWATER MONITORING PROGRAM AS REQUIRED IN 40 CFR 265.90(A), RES- PONDENT HAS ALSO VIOLATED THOSE REGULATIONS RELEVANT TO THE GROUNDWATER MONITORING PROGRAM: 40 CFR 265.91(A) - GROUND- WATER MONITORING SYSTEM; 265.91(B) - WELL CONSTRUCTION; 265.92 - SAMPLING AND ANALYSIS; 266.93