United States Office of Solid Waste April 1982
Environmental Protection and Emergency Response SW - 954
Agency
SoMd Waste
SEPA interim Status
Groundwater Monitoring
Program Evaluation
A Guidance Manual
-------
-------
'> INTERIM STATUS GOUNDWATER
MONITORING PROGRAM EVALUATION
A Guidance Manual
This document (SW-954) was prepared for
the Office of Solid Waste under contact no. 68-01-6515
U.S. Environmental Protection Agency
1982
U S. Envi:— - . ,.
V,
-------
',.,,: v.ronr
-------
TABLE OF CONTENTS
PAGE
1.0 INTRODUCTION 1-1
1.1 APPLICABILITY 1-1
2.0 SITE INSPECTIONS 2-1
2.1 GENERAL 2-1
2.2 DOCUMENT REVIEW 2-1
2.2.1 Hydrogeologic Setting 2-2
2.2.1.1 Unconsolidated Materials 2-4
2.2.1.2 Karst Terrain 2-4
2.2.1.3 Bedrock 2-4
2.2.2 Site-Specific Information 2-5
2.2.3 Sample Collection/Analysis 2-7
2.3 SITE RECONNAISSANCE 2-11
2.3.1 SURFACE FEATURES 2-11
2.3.2 MONITORING WELLS 2-12
2.3.3 WATER LEVELS 2-12
3.0 MONITORING WAIVER DEMONSTRATION 3-1
4.0 EVALUATION REPORT PREPARATION 4-1
4.1 SAMPLING AND ANALYSIS PLANS 4-5
4.2 SUMMARY 4-5
APPENDIX A - COMPLIANCE CHECKLISTS
APPENDIX B - GROUND-WATER MONITORING AND ALTERNATE SYSTEM
TECHNICAL INFORMATION FORMS
APPENDIX C - GROUND-WATER QUALITY ASSESSMENT PROGRAM
TECHNICAL INFORMATION FORMS
APPENDIX D - WAIVER DEMONSTRATION TECHNICAL INFORMATION FORM
APPENDIX E - RCRA REFERENCES
-------
-------
1.0 INTRODUCTION
The intent and purpose of this document is to provide compliance status
and technical guidance to administrative authority personnel for the preliminary
evaluation of ground-water monitoring systems, ground-water quality assessment
programs, and monitoring waiver demonstrations pursuant to the RCRA ground-
water monitoring requirements of Subpart F of 40 CFR 265 (45 Federal Register
33239 et seq., May 19, 1980). The Compliance Checklists and Technical Infor-
mation Forms (see Appendices A, B, C,and D) have been developed to provide only
a preliminary check for completeness and adequacy and will not involve detailed
hydrogeologic or engineering review.
While detailed technical analysis of individual ground-water programs
will ultimately be conducted, the preliminary field evaluation process will provide
a mechanism whereby rapid determinations of the compliance status and apparent
adequacy of various ground-water programs can be made. The initial review of
technical data and site information will allow the administrative authority to
prioritize the need for detailed analysis by indicating which monitoring programs
do not appear adequate or seem marginal in view of the regulations. Only "first
cut" determinations can be made and any final decision on the adequacy of an
individual ground-water program must be made based on in-depth analysis of all
available technical data.
1.1 APPLICABILITY
Subpart F - Ground-Water Monitoring requires that the owner or
operator of a surface impoundment, landfill, or land treatment facility managing
hazardous waste and has qualified for interim status, implement .a ground-water
monitoring program capable of determining the facility's impact on water quality
in the uppermost aquifer underlying the facility.
The ground-water monitoring programs, designed and implemented to
detect and assess changes in the ground-water quality due to the emanation of
leachate derived from the waste materials, may be partially or fully waived if the
owner or operator of the facility can demonstrate that there is a low potential for
1-1
-------
migration of hazardous waste or hazardous waste constituents from the facility
through the ground-water system.
In cases where the owner or operator of a facility suspects or knows
that the facility has already impacted the uppermost aquifer in such a way that the
indicator parameters would show statistically significant increases when evaluated,
an alternate ground-water monitoring system may be utilized to determine the rate
and extent of contaminant migration and the concentrations of hazardous waste
and hazardous waste constituents in the ground water.
1-2
-------
2.0 SITE INSPECTIONS
2.1 GENERAL
The site inspection allows the field investigator to ascertain the level
of RCRA compliance at a facility by gathering information relative to the
effectiveness of any ground-water monitoring programs instituted at the site or the
validity of any waiver demonstrations. The compliance status evaluation is
generally straightforeward and requires that the investigator fill out the appro-
priate checklist(s) contained in Appendix A.
Determination of the effectiveness of ground-water monitoring systems
requires that the investigator be aware of the general subsurface conditions in the
area. Aside from obvious things like ensuring that monitoring wells are installed at
the facility and that there are no surficial sources of contaminant discharge to the
ground-water system, the field inspector is somewhat limited by what may be
documented on the surface. The nature of ground-water systems requires that
subsurface data, including the physical and hydrogeologic character of the under-
lying materials as well as the construction of the monitoring system components,
be examined prior to the site inspection.
2.2 DOCUMENT REVIEW
The Agency expects that some information on ground-water monitoring
system details, ground-water assessment programs, and monitoring waiver demon-
strations will be submitted to the administrative authority for review prior to site
visit. There will, however, be instances when such information will not be
available for review until the site inspection. In either case the inspector will have
to carefully review the data in order to obtain as much information'as is possible.
The Appendix A checklists are provided to record compliance status
information. These checklists should be used by the inspector to examine those
areas where RCRA requirements apply. They are organized in accordance with
Part 265, Subpart F and are cross-referenced to those sections in the regulations
where applicable.
2-1
-------
Technical Information Forms (TIF's) are included in Appendicies B, C,
and D. These forms, while not checklists, may be used in a similar fashion to allow
the field inspector to collect data in an orderly manner.
The general organization of the TIF's is such that the field inspector
may collect data in related blocks, (e.g., soil boring, well construction, regional
hydrogeology). Experience has shown that most professionally compiled reports
(geologic, hydrogeologic, engineering) present these types of data together. In the
cases where the facility data was not prepared or compiled by a professional, the
investigator is advised to collect data in the same manner and order as is shown on
the TIF's. If maps or plot plans are included, it is recommended that these be
examined first.
The TIF's should be filled out to the fullest extent in order to gain the
maximum amount of information about the facility. The inspector should also
inquire about the possibility of obtaining copies of the information for office
review, thereby reducing time at the facility and increasing accuracy.
During the review of the ground-water program, several aspects of in-
formation should be noted for later field verification. These include:
• the locations of waste handling, storage, or disposal areas and the
type(s) of hazardous waste(s)
• the proximity of surface water bodies (e.g., stream courses, lakes,
wetlands)
• the topographic and surficial features of the site
• the number, locations, and the depths of the ground-water moni-
toring wells
• the depths to ground water, hydraulic gradients, and the inferred
ground-water flow directions, and
• the locations of off-site ground-water wells and their depths
The field inspector is advised to record this information in his/her Field Inspection
Log Book, for reference during the site reconnaissance.
2-2
-------
2.2.1 Hydrogeologic Setting
The geologic formations underlying a facility and their hydrogeologic
properties are of extreme interest since they determine the rate and direction of
ground-water movement. Prior to the site visit the field inspector should:
1) locate the facility on a U.S.G.S. topographic quadrangle map;
2) check the geologic and hydrogeologic data available for the area;
and,
V '
\ 3) review U.S.D.A. Soil Conservation Service soil maps.
As aerial photographs of the area are always available through the soil service,
they should also be examined in order to identify any significant topographic,
geologic, or hydrologic features. The use of aerial photographs facilitates the
location of surface water bodies, as well as dwellings and other structures in the
vicinity. Some sources of geologic and hydrogeologic data include:
U.S. Geological Survey, Ground-Water Branch;
U.S. Soil Conservation Survey;
State Geological Surveys;
State Departments of Environmental Protection;
State Divisions of Solid Waste;
State Divisions of Water Resources;
Regional and Local Planning Authorities;
h
Local Universities and Colleges;
Local Consulting Firms;
Private Environmental Groups; and,
Resource Related Industries.
The review of the above cited sources and materials should provide the
field inspector with an understanding of the regional geologic and general hydro-
geologic conditions in the site vicinity. This knowledge will allow the inspector to
2-3
-------
be able to determine the general accuracy of the information presented in the
various ground-water programs.
2.2.1.1 Unconsolidated Materials
Some local deviations from the general geologic and hydrogeologic
patterns may be expected due to natural heterogeneity and the field inspector
should document these where they occur. Glacial, alluvial valley and coastal plain
deposits exhibit alternating textural differences and it is necessary that the
investigator be aware of and record certain factors. These include:
1) the areal extent, depth, and orientation of individual strata;
2) the head differencials which may occur between individual water
bearing formations.;
3) the differences in permeability between individual strata; and,
4) the degree of hydraulic connection that may exist between various-
water bearing units.
2.2.1.2 Karst Terrain
Areas of karst terrain should be identified and assessed for collapse
potential and the presence of solution channels. While the regional net ground-
water flow patterns may be identified for the karst region, local flow systems may
sometimes be quite different.
2.2.1.3 Bedrock
The occurrence of bedrock (or indurated sediments) at or near the
surface requires additional considerations. Consolidated materials may exhibit
small effective porosities and low hydraulic conductivities which impede ground-
water flow. The development of secondary porosity may allow ground-water to
flow through fractures, joints, cleavage planes and foliation and should be noted
where they occur. These features tend to be highly directional in nature, exhibit
varying degrees of interconnection, and may produce local ground-water flow
regimes much different from the regional trends.
2-4
-------
Care must be taken when evaluating data from ground-water moni-
toring wells in bedrock due to the irregularities of fracture interconnections. It is
possible that monitoring wells may be located out of the path of flow from the
waste management area. The field inspector must understand the relationship of
fracture trends and monitoring well location to be able to ascertain whether the
wells intercept the appropriate flow path.
2.2.2 Site-Specific Information
Data in the various ground-water monitoring programs provides in-
formation on the geologic and hydrogeologic conditions beneath the site.
These data should include:
• detailed logs of the test pits or soil borings;
• well construction details;
• geologic cross-sections;
• a description of the subsurface conditions including extent of forma-
tions, fracture patterns, and dip;
• the estimation of various hydraulic properties of the strata encountered
(e.g., transmissivity, intrinsic permeability, porosity, hydraulic con-
ductivity, etc.);
• the depths to ground water;
• potentiometric map; and,
• the inferred hydraulic gradients between the wells.
The review of this material will give the field inspector the information necessary
to evaluate the adequacy of the monitoring programs.
Soil boring or test pit logs will provide the basis for the description of
the subsurface materials and the construction of geologic cross-sections. This
information should:
• provide lithologic descriptions of the subsurface materials;
• indicate the presence of apparent low permeability materials that
may act as confining bedsjand,
2-5
-------
• show the areal extent and thickness of the unsaturated and
saturated zones.
The installation of ground-water monitoring wells provides a means
whereby the various hydraulic properties of the subsurface materials may be
measured as well as allowing ground water samples to be periodically collected.
Hydraulic properties may be determined from several in situ tests at
the site. These include: •
I
• pumping/recovery tests;
• packer tests; and,
• falling or constant head tests.
Textural analysis of boring samples may be performed in the laboratory, and
permeameter tests can be used to determine hydraulic conductivity. However, in
most cases, field tests may provide more reliable information since measurements
are made under natural conditions and include all hydraulic features of the
substrate. Laboratory analyses usually entail some disturbance of the materials
and examine only small localized horizons in the substrate.
Ground water elevations, measured from some common datum, provide
useful information when properly analyzed. It is essential that the water level
measurements are made at all wells in as short a time period as possible to ensure
that conditions are relatively constant. It is also important that the well's depth
and screened interval be known in order to avoid serious error in evaluating the
data. Potentiometric contour majps may be constructed which show the inferred
direction of ground-water flow and hydraulic gradient. It is important to use water
levels from wells open to the same aquifer horizon in order to prevent possible
distortions caused by pressure differences in the aquifer due to vertical flow. A
properly constructed equipotential contour map will show whether the required
monitoring wells are, indeed, upgradient or downgradient and indicate whether the
monitoring wells appear capable of detecting any leachate generated from the
hazardous wastes on site in the uppermost aquifer.
2-6
-------
The design and construction of the monitoring wells must also be
considered in the evaluation of a monitoring program. Wells may be screened (open
to the formation) for the entire length of the saturated thickness, or completed
with intakes set at discrete intervals. In cases where the entire saturated
thickness is screened, the water levels will represent an average elevation of the
potentiometric surface. Fully penetrating wells indicate contaminant strati-
fication but allow a large volume of water to enter the well and, in cases where
contaminants may be in trace amounts, dilution would tend to mask their presence.
Well clusters with intakes set at discrete depths in the saturated zone
provide more detailed information on ground-water pressure gradients and allow
for less dilution of contaminants should chemical stratification occur, since a
smaller quantity of ground water enters through the shorter screen. By setting the
well intakes at specific depths, recharge and discharge effects can be measured
and monitored.
2.2.3 Sample Collection/Analysis
Since the primary goal of the regulations is to obtain reliable infor-
mation on the changes in ground-water quality, the proper collection of ground-
water samples, their handling and analysis is of great importance. The ground-
water sampling and analysis plan should outline the methods utilized to obtain
samples of the ground water.
Prior to sample collection, it is necessary to evacuate some quantity of
water from the well to ensure that fresh ground water is sampled. The amount of
water flushed may vary due to differences in transmissivities of individual water
bearing zones. It is generally accepted that the removal of three to five well
volumes is sufficient to ensure the flow of fresh water. In very low transmissivity
aquifers with slow recovery times, only one casing volume may be available for
evacuation. Depending on the depth of the well and production capability,
evacuation may be by:
• bailing;
• centrifugal pump;
• airlift pump;
2-7
-------
• submersible pump; or,
• positive displacement pump.
The ground-water programs should indicate the well evacuation procedures to be
utilized prior to sampling.
The manner in which the ground-water samples are collected from the
well should also be considered along with equipment decontamination procedures
necessary to avoid cross contamination between samples. In cases where samples
are collected from the discharge of centrifugal, airlift or submersible pumps the
potential for volatilization of organic contaminants should be evaluated along with
the increased opportunity of cross contamination since complete cleaning of these
types of pumps is difficult. If such equipment is used, the potential loss of
constituents through volatization should also be evaluated. This is very important
when trace concentrations of contaminants are expected.
In most cases inorganic constituents samples can be sampled with a
bailer or positive displacement pump. Peristaltic pumps provide good samples of
water tables within 25 feet of the surface. They are not, however, advised to be
used for volatile organic compounds in minute quantities when pressure differ-
entials may cause volatilization.
Once samples are collected they should be handled in a manner that will
minimize the alteration of the constituents to be analyzed for. The samples should
be filtered when necessary and the appropriate chemical preservatives added as
soon as possible. Recommended sample containers should be utilized and samples
should be kept refrigerated or on--ice during transport to the laboratory. Recom-
mended holding times should be adhered to in order to ensure that constituent
alteration is minimized. (See Sealf, et al, 1981 for summary of recommended
sampling methods.)
The chain-of-custody control should be outlined in the sampling and
analysis plan to ensure that the possession of samples may be documented from the
time of collection to the time that the analyses are performed.
2-8
-------
For detection monitoring programs, analysis of the ground-water
samples should include:
Drinking Water Suitability Parameters
Arsenic Lindane
Barium Methoxychlor
Cadmium Toxaphene
Chromium 2,4, D
Fluoride 2,4,5-TP Silvex
Lead Radium
f Mercury Gross Alpha
f Nitrate (as N) Gross Beta
Selenium Coliform Bacteria
Silver Endrin
Parameters Establishing Ground-water Quality
Chloride Phenols
Iron Sodium
Manganese Sulfate
Parameters Used as Indicators of Ground-water Contamination
pH Total Organic Carbon
Specific Conductance Total Organic Halogen
The sampling and analysis plan should also indicate a schedule of
analyses, as follows:
1) For the first year, all above cited parameters must be analyzed on a
quarterly basis to establish background concentrations.
V, .
2) After the first year, ground-water quality samples must be obtained and
analyzed at least annually.
3) After the first year, ground-water contamination indicator parameters
must be obtained and analyzed at least semi-annually.
2-9
-------
The owner or operator must also prepare an outline of a ground-water
quality assessment program that is capable of determining whether hazardous
waste constituents have entered the ground-water system, the rate and extent that
the contaminants have migrated, and the concentration of any contaminants. The
field inspector should review this outline to determine whether the program
appears capable of performing the required functions.*
The field inspector should review the monitoring program for infor-
mation relating to statistical analysis to be performed on the water quality analysis
results and to see that the proper reporting procedures are being followed.
*The compliance date for this requirement has been extended to August 1, 1982
(Federal Register, February 23, 1982, p. 7841-7842). EPA will be proposing (Spring
1982) to eliminate this requirement and extend from 15 to 90 days the time frame
for development and submission of ground-water quality assessment programs that
would have been based upon these outlines.
2-10
-------
2.3 SITE RECONNAISSANCE
With the completion of the review and collection of information
contained in the ground-water monitoring program, either at the facility OP in the
office, field verification of certain data must be undertaken. A copy of the site
plot plan should be available for the reconnaissance.
2.3.1 Surface Features
I An important aspect of the site investigation is to ensure that all potential
sources of discharge of hazardous waste to the ground-water system are addressed
in the program. It is necessary for the inspector to locate the sources described in
the program and determine if any source has been omitted. In the event that any
waste management areas have been left out, the inspector must note the location,
size and type of area in his/her inspection log book.
During the reconnaissance attention should be paid to any surface water
bodies or streams on or adjacent to the site. Since ground water may be discharged
to these surface water bodies, there is a possibility that contaminants in the ground
water may be present in the surface water. Signs of contamination may be:
• an oily sheen on the surface of the water;
• discoloration on the banks from precipitation of contaminants;
• dead or distressed vegetation along the banks; and,
• unusual foaming or odors.
*_.
The distances of surface water bodies, streams and wetlands should be
noted and compared to information in the program.
The occurrence of significant topographic or surficial features, if any, should
be noted and located on the plot plan. These features may indicate areas of
ground-water recharge or discharge.
2-11
-------
2.3.2 Monitoring Wells
While it is not possible to observe the complete well construction
detail, there are several items that can be checked. These include the construction
materials, the location and number of the monitoring wells, the total depths and
the ground-water elevations. During the field reconnaissance the locations and
numbers of the monitoring wells should be checked to ensure that all wells are
located and in agreement with the monitoring program locations.
It is recommended that the field inspector sound each well to ensure
that the well is completed to the described depth. This is also a means of
determining if the wells are numbered properly. The soundings are performed by
measuring the total depth of the well with an appropriate steel tape. There is a
chance that the bottom of the well may have been filled in by some sediment which
entered through the screen. A discrepancy of up to one foot may be tolerated,
except in cases where short well screens are indicated in the construction detail.
If more than 30% of the screened area is filled in, usefulness of the well may be
jeopardized.
Discrepancies in the well depths of more than two feet should be noted.
Large deviations of more than five feet may indicate that the well numbering
system may be in error. When this is noted, the field investigator should inquire
about that possibility.
2.3.3 Water Levels
All monitoring wells must be constructed so they are screened below the
lowest level of ground-water fluctuation to prevent wells from being periodically
dry. Any dry wells encountered must be noted during the field investigation.
Ground-water elevations must be measured during the visit to verify present data.
The elevations are determined by subtracting the depth to water from the marked
datum on the well casing or standpipe. It is important to note whether the
elevations were determined by field surveying or from a topographic map in order
to assess the accuracy of the elevations. The water level elevation will be utilized
later in the construction of a potentiometric contour map to determine ground-
water flow direction and hydraulic gradients.
2-12
-------
3.0 MONITORING WAIVER DEMONSTRATION
This section presents information on the evaluation of monitoring
waiver demonstrations. This material, in conjunction with that presented in
previous sections, will outline the steps that the field inspector should take in order
to assess the practicality of such demonstrations. The Waiver Demonstration
Technical Information Form (Appendix D) is to be filled out, in addition to the
Ground-water Monitoring System Technical Information Form (Appendix B), during
the data review.
The technical nature of any waiver demonstration requires that the
investigator be aware of, and record the existence of more detailed geologic and
hydrogeologic information. Since the owner or operator is requesting the waiver,
the burden of proof is upon the applicant to sufficiently convince the adminis-
trative authority that a waiver should be approved for the facility.
The major areas of interest in the review process are:
• depth to ground water;
• the character of the hazardous waste materials;
• the water balance in the facility area (i.e., precipitation, runoff,
evapotranspiration and infiltration);
• the physical and chemical nature of the unsaturated zone;
• the physical and chemical nature of the saturated zone; and,
• proximity to water supply wells and surface water.
The information supplied by the applicant should be compared to that gathered
from other sources during the background information search to ensure the validity
of the applicant's data. In some cases, the applicant may utilize computer
modeling techniques to predict the ground-water flow, solute transport in the
ground-water system and flow through the unsaturated zones. When models are
used, the field inspector should inform his/her technical supervisor who will make
appropriate arrangements to have the model information reviewed by expert
personnel in that field.
3-1
-------
Brief descriptions of the data and references for techniques used in the
documentation are requested on the Waiver Demonstration Technical Information
Form (Appendix D) and should be filled out as fully as possible. Whether the
method or techniques are applicable to the conditions described in the waiver docu-
mentation will have to be determined. The evaluation of waiver demonstrations
may prove to be more time consuming and complex than the detection monitoring
or assessment programs. Discussions with the technical staff members experienced
in such areas should be undertaken and are encouraged in 6rder to aid the field
inspector in evaulating the adequacy of waiver demonstrations.
3-2
-------
4.0 EVALUATION REPORT PREPARATION
The field inspector's evaluation of ground-water monitoring program is
geared toward an assessment of the accuracy, completeness and apparent technical
adequacy of the plans and other information. At this time, detailed engineering
and hydrogeologic analyses will not be undertaken. However, the information from
the field investigation should be made available to the hydrogeologist or engineer
performing the final evaluation since it will, in addition to the technical data
included, provide key information on site conditions. Due to this later use of the
site inspection information, the field inspector must be clear and concise in his/her
site evaluation report.
The inspector should refer to Table 1 for an outline of the various
components of the compliance reviews. Refering to this outline during the report
preparation will ensure that required information will not be omitted in the
presentation. The inspector should also refer to the information in Appendix E for
RCRA Regulation References.
The reviewer must first determine whether the data supplied in the
monitoring programs, in conjunction with the field verification reconnaissance, is
sufficient to determine the capability of the monitoring program to perform the
required functions. If information is not sufficient, or is inconsistent, the de-
ficiencies should be noted and elaborated on.
The determination of the apparent capability of the monitoring program
to perform in the required manner should be based on information presented in the
various monitoring program documentations. Where assumptions and deter-
minations presented are not logical or appear erroneous, the evaluation report
should point them out.
The capability determinations should consider the points in the program
that address:
• the type of facility and the nature of the various waste management
areas on the site;
• the plot plan of the facility and its relationship to surface waters;
4-1
-------
TABLE 1
INSPECTION OF FACILITIES FOR COMPLIANCE WITH THOSE INTERIM
STATUS STANDARDS COVERING GROUND-WATER MONITORING
(PART 265-SUBPART FT
1. Sampling and Analysis (check)
a) valid techniques used for collection, preservation <3c analysis
b) determined quarterly for first year
1) drinking water suitability parameters
2) ground-water quality parameters
3) ground-water contaminant indicator parameters
2. Outline of Ground-Water Quality Assessment Program*
a) capable of determining ground-water contamination
b) capable of determining the rate and extent of migration and concentration
of hazardous waste (HW) or HW constituents.
3. Number, Location, Depth and Effectiveness of the Wells
a) are upgradient wells in fact upgradient?
b) are wells at appropriate depth?
c) are enough wells upgradient and downgradient?
d) are wells in the uppermost aquifer likely to be contaminated?
e) are upgradient wells unaffected by the facility?
f) will upgradient wells yield representative samples?
g) were ground-water surface elevations evaluated annually?
h) if wells were no longer upgradient/downgradient, were they brought
into compliance?
i) method of sample collection?
4. Record Keeping and Reporting
a) do presented data appear consistent and valid?
INSPECTION OF FACILITIES USING AN ALTERNATE SYSTEM
FOR GROUND-WATER MONITORING
Check if:
1. Facility submitted a plan certified by a qualified geologist, etc., in which:
a) number, location and depths of all wells were specified
b) sampling and analysis methods were specified
c) evaluation procedures were specified
d) previously gathered data was used in evaluation procedures
e) there is a schedule for implementation of the plan
*See note Page 2-10
4-2
-------
2. The following were determined:
a) rate and extent of migration of HW or HW constituents in ground water
b) concentrations of HW or HW constituents in ground water (gw)
3. Facility submitted (to RA) a report containing assessment of the ground-
water quality within 15 days of first determination of 2a
-------
INSPECTION ITEMS FOR A FACILITY WHICH HAS DETERMINED
THAT IT MAY BE AFFECTING GROUND-WATER QUALITY
1. Did the facility resolve doubt as to whether the data was real or spurious?
Were additional samples split in two?
2. If real,
a) did the facility notify the RA within seven days?
b) did the facility submit to the RA the required certified plan within
15 days?
3. Did the plan specify:
a) number, location and depth of wells?
b) sampling and analytical methods for HW or HW constituents?
c) evaluation procedures, including any use of previous information?
d) a schedule of implementation?
4. Did the facility owner or operator determine:
a) rate and extent of migration of HW in ground water?
b) concentrations of HW in ground water?
c) the above (a&b) as soon as technically feasible?
5. Did the facility submit a written report to RA containing an assessment
of the ground-water quality?
6. If determinations in 4 a&b revealed ground water was not affected, did
facility notify RA within 15 days, and reinstate indicator monitoring program?
7. If determinations in 4 a&b revealed HW has entered ground water, did
facility continue making these determinations quarterly until closure?
8. If ground-water quality assessment plan was instituted prior to closure,
was it:
a) completed?
b) reported in accordance with 265.93(d)(5)?
9. 265.94(b)(l) - Did the facility keep records of analyses and evaluations
specified in the ground-water quality assessment plan throughout life of
facility and during post-closure if necessary?
10. Annual Report submitted to RA*
a) did it include results of its ground-water quality assessment program?
b) did it contain measured or calculated rate of migration of HW in
ground water?
*See note Page 4-3.
4-4
-------
• the location and construction of ground-water monitoring wells;
• the subsurface geologic and hydrogeologic information.
4.1 SAMPLING AND ANALYSIS PLANS
The field investigator must determine if appropriate sample collection,
handling and storage procedures, and analysis techniques are being performed. The
ground-water sampling and analysis plan should outline the methods and techniques
to be employed at the site. Where inadequate sampling methods and analytical
techniques are indicated, the reviewer should note which procedures do not appear
appropriate.
The schedule of sample collecting must also be checked to ensure that
the proper time intervals are adhered to.
4.2 SUMMARY
The reviewer should provide a brief summary of site conditions and
comments on the ground-water monitoring programs. This summary should
highlight areas where the monitoring program appears to not be in compliance or
inadequate. A recommendation should also be included as to whether or not more
detailed technical evaluation is required to determine the adequacy of the
program.
4-5
-------
REFERENCES
Scalf, M. R., McNab, J. F., Dunlap, W. J., Cosby, R. L., and Friberger, J. S.,
1981, Manual of Ground-Water Quality Sampling Procedures, EPA
PB-82-103-045.
-------
APPENDIX - A
COMPLIANCE CHECKLIST FORMS
-------
APPENDIX A-l
FACILITY INSPECTION FORM FOR COMPLIANCE WITH INTERIM
STATUS STANDARDS COVERING GROUND-WATER MONITORING
Company Name:_
Company Address:
; EPA I.D. Number:
; Inspector's Name:
Company Contact/Official:
Title:
Type of facility: (check appropriately)
a) surface impoundment
b) landfill
c) land treatment facility
d) disposal waste pile*
Ground-Water Monitoring Program
1. Was the ground-water monitoring program
reviewed prior to site visit?
If "No",
a) Was the ground-water program
reviewed at the facility prior
to site inspection?
2. Has a ground-water monitoring program
(capable of determining the facility's
impact on the quality of groundwater in
the uppermost aquifer underlying the
facility) been implemented? 265.90(a)
_; Branch/Organization:
; Date of Inspection:
Yes
No
Unknown Waived
*Listed separate from landfill for convenience of identification.
-------
Yes No Unknown Waived
3. Has at least one monitoring well been
installed in the uppermost aquifer
hydraulically upgradient from the limit
of the waste management area?
265.91(a)(l)
a) Are ground-water samples
from the uppermost aquifer, represen-
tative of background ground-water
quality and not affected by the facility
(as ensured by proper well number,
locations and depths?)
4. Have at least three monitoring wells been
installed hydraulically downgradient at the
limit of the waste handling or management
area? 265.91(a)(2)
a) Do well number, locations; and depths
ensure prompt detection of any
statistically significant amounts of HW
or HW constituents that migrate from
the waste management area to the
uppermost aquifer?
5. Have the locations of the waste management
areas been verified to conform with infor-
mation in the ground-water program?
a) If the facility contains multiple waste
management components, is each
component adequately monitored?
6. Do the numbers, locations, and depths
of the ground-water monitoring wells
agree with the data in the ground-water
monitoring system program?
If "No", explain discrepancies.
7. Well completion details. 265.91(c)
a) Are wells properly cased?
b) Are wells screened (perforated)
and packed where necessary to enable
sampling at appropriate depths?
c) Are annular spaces properly sealed
to prevent contamination of ground-
water?
-------
Yes No Unknown
8. Has a ground-water sampling and analysis
plan been developed? 265.92(a) _
a) Has it been followed? _
b) Is the plan kept at the facility? _
c) Does the plan include procedures
and techniques for:
1) Sample collection? _
2) Sample preservation? _
3) Sample shipment? _
4) Analytical procedures? _
5) Chain of custody control? _
9. Are the required parameters in ground-water
samples being tested quarterly for
the first year? 265.92(b) and 265.92 (c)(l)
a) Are the ground-water samples
analyzed for the following:
1) Parameters characterizing
the suitability of the ground-
water as a drinking water supply?
265.92(b)(l)
2) Parameters establishing
ground-water quality?
265.92(b)(2)
3) Parameters used as indicators of
ground-water contamination?
265.92(b)(3)
(i) For each indicator parameter
are at least four replicate
measurements obtained at each
upgradient well for each sample
obtained during the first year of
monitoring? 265.92(c)(2) _
(ii) Are provisions made to calculate
the initial background arithmetic
mean and variance of the respective
parameter concentrations or values
obtained from the upgradient well(s)
during the first year? 265.92(c)(2) _
b) For facilities which have completed
first year ground-water sampling and analysis
requirements:
1) Have samples been obtained and analyzed
for the ground-water quality parameters
at least annually? 265.92(d)(D _
2) Have samples been obtained and
analyzed for the indicators of
ground-water contamination at
least semi-annually? 265.92(d)(2)
-------
Yes No Unknown
c) Were ground-water surface elevations
determined at each monitoring well each
time a sample was taken? 265.92(e)
d) Were the ground-water surface elevations
evaluated annually to determine whether the
monitoring wells are properly placed?
265.93(f)
e) If it was determined that modifi-
cation of the number, location or depth
of monitoring wells was necessary, was
the system brought into compliance with
265.91(a)? 265.93(f)
10. Has an outline of a ground-water quality
assessment program been prepared?
265.93(a)*
a) Does it describe a program capable
of determining:
1) Whether hazardous waste or hazardous
waste constituents have entered the
ground water?
2) The rate and extent of migration of
hazardous waste or Imzardous waste
constituents in ground water?
3) Concentrations of hazardous waste
or hazardous waste constituents
in ground water?
b) After the first year of monitoring,
have at least four replicate measure-
ments of each indicator parameter been
obtained for samples taken for each
well? 265.93(b)
1) Were the results compared with the
initial background means from the
upgradient well(s) determined
during the first year?
(i) Was each well considered
individually?
(ii) Was the Student's t-test used
(at the 0.01 level of significance)?
2) Was a significant increase (or pH
decrease as well) found in the:
(i) Upgradient wells
(ii) Downgradient wells
If "Yes", Compliance Checklist A-2
must also be completed.
note Page 2-10
-------
11. Have records been kept of analyses for
parameters in 265.92(c) and (d)?
265.94(a)(l)
12. Have records been kept of ground-water
surface elevations taken at the time of
sampling for each well? 265.94(a)(l)
13. Have records been kept of required
elevations in 265.93(b)?
265.94(a)(l)
14. Have the following been submitted to the
Regional Administrator 265.94(a)(2) :*
a) Initial background concentrations of
parameters listed in 265.92(b) within
15 days after completing each quarterly
analysis required during the first year?
b) For each well, have any parameters whose
concentrations or values have exceeded
the maximum contaminant levels allowed
in drinking water supplies been
separately identified?
c) Annual reports including:
1) Concentrations or values of
parameters used as indicators
of ground-water contamination for
each well along with required
evaluations under 265.93(b)?
2) Any significant differences from
initial background values in up-
gradient wells separately identified?
3) Results of the evaluation of
ground-water surface elevations?
Yes
No
Unknown
*EPA will be proposing (Spring 1982) to replace this reporting require-
ment with an exception reporting system where reports will be submitted
only where maximum contaminant levels or significant changes in the
contamination indicators or other parameters are observed. EPA has
delayed compliance stage for 14 a) above until August 1, 1982 (Federal
Register, February 23, 1982, p.7841-7842) to be coupled with exception
reporting in the interim.
-------
APPENDIX A-2
INSPECTION COMPLIANCE FORM FOR A FACILITY WHICH
MAY BE AFFECTING GROUND-WATER QUALITY
Company Name: ; EPA I.D. Number:_
Company Address: ; Inspector's Name:_
Company Contact/Official: ; Branch/Organization:
Title: ; Date of Inspection:
Yes No Unknown
Type of facility: (Check appropriately)
a) surface impoundment
b) landfill
c) land treatment facility
d) disposal waste pile
Have comparisons of ground-water
contamination indicator parameters for the
upgradient well(s) 265.93(b) shown a signifi-
cant increase (or pH decrease as well) over
initial background?
a) If "Yes", has this information been
submitted to the Regional Administrator
according to 265.94(a)(2)(ii)?
2. Have comparisons of indicator parameters for
the downgradient wells 265.93(b) shown a
significant increase (or pH decrease as well)
over initial background?
a) If "Yes", were additional ground-water
samples taken for those downgradient
wells where the significant difference
was determined? 265.93(c)(2)
1) Were samples split in two?
2) Was the significant difference due to
human (e.g., laboratory) error?
(If "Yes", do not continue.)
-------
Yes No Unknown
3. If significant differences were not due to
error, was a written notice sent to
the Regional Administrator within 7 days of
confirmation?
4. Within 15 days of notification of the Regional
Administrator was a certified ground-water quality
assessment plan submitted? 2S5.93(d)(2)*
a) Does the plan specify 265.93(d)(3) :
1) well information (specifics)
(a) number?
(b) locations?
(c) depths?
2) sampling methods?
3) analytical methods?
4) evaluation methods?
5) schedule of implementation?
b) Does the plan allow for determination of
265.93(d)(4) :
1) Rate and extent of migration of
hazardous waste or hazardous waste
constituents?
2) Concentrations of the hazardous
waste or hazardous waste constituents?
c) Is it indicated that the first determination
was made as soon as technically feasible?
265.93(d)(5)
1) Within 15 days after the first determi-
nation was a written report containing
the assessment of ground-water
quality submitted to the Regional
Administrator?
d) Was it determined that hazardous waste
or hazardous waste constituents from the
facility have entered the ground water?
1) If "No", was the original indicator
evaluation program, required by
265.92 and 265.93(b), reinstated?
(a) Was the Regional Administrator
notified of the reinstatement of
program within 15 days of the
determination? 265.93(d)(6)
*See note Page 2-10
-------
Yes No Unknown
e) If it was determined that hazardous waste
or hazardous waste constituents have
entered the ground water 265.93(d)(7) :
1) For facilities where program was
implemented prior to final closure, are
determinations of hazardous waste or
hazardous waste constituents continued
on a quarterly basis?
(If program was implemented during
the post-closure care period, determinations
made in accordance with the ground-water
quality assessment plan may cease
after the first determination.)
(a) Were subsequent ground-water quality
reports submitted to the Regional
Administrator within 15 days of
determination?
2) Were records kept of the analyses
and evaluations, specified in the ground-
water quality assessment (throughout
the active life of the facility)?
265.94(b)(l)
(a) If a disposal facility, were(are) records
kept throughout the post-closure
period as well?
f) Are annual reports submitted to the Regional
Administrator containing the results of the
ground-water quality assessment program?
265.94(b)(2)*
1) Do the reports include the calculated
or measured rate of migration of
hazardous waste or hazardous waste
constituents during the reporting
period?
*See note Page 4-3
-------
APPENDIX A-3
INSPECTION COMPLIANCE FORM FOR DEMONSTRATING
A WAIVER OF INTERIM STATUS REQUIREMENTS
Company Name:
Company Address:_
; EPA I.D. Number:
; Inspector's Name:
Company Contact:_
Title:
_; Branch/Organization:
; Date of Inspection:
Yes
No
Unknown
1. Is a written waiver demonstration kept at
the site?
2. Is the demonstration certified by a qualified
geologist or geotechnical engineer?
265.90(c)
3. Does the waiver demonstration establish:
a) The potential for migration of hazardous
waste or hazardous waste constituents
from the facility to the uppermost aquifer?
265.90(c)(l)
b) An evaluation of a water balance
including:
1) Precipitation?
2) Evapotranspiration?
3) Runoff?
4) Infiltration? (including' any
liquid in surface impoundments)
c) Unsaturated zone characteristics?
1) Geologic materials?
2) Physical properties?
3) Depth to ground water?
-------
Yes No Unknown
d) The potential for hazardous waste or
hazardous waste constituents which may
enter the uppermost aquifer to migrate
to a water supply well or surface water,
by evaluation of: 265.90(c)(2)
1) Saturated zone characteristics,
including:
(a) Geologic materials?
(b) Physical properties?
(c) Rate of ground-water flow?
2) Proximity of the facility to water
supply wells or surface water?
-------
APPENDIX -B
GROUND-WATER MONITORING AND ALTERNATE SYSTEM
TECHNICAL INFORMATION FORM
-------
APPENDIX B
GROUND-WATER MONITORING AND ALTERNATE SYSTEM
TECHNICAL INFORMATION FORM
1.0 Background Data;
Company Name: ; EPA I.D.#:_
Company Address:
Inspector's Name: ; Date:_
1.1 Type of facility (check appropriately):
1.1.1 surface impoundment
1.1.2 landfill _
1.1.3 land treatment facility
1.1.4 disposal waste pile
1.2 Has a ground-water monitoring system been
established? (Y/N)
1.2.1 Is a ground-water quality assessment
program outlined or proposed? (Y/N)
If Yes,
1.2.2 Was it reviewed prior to the site visit? (Y/N)
1.3 Has a ground-water quality assessment program been
implemented or proposed at the site? (Y/N)
If yes, Appendix C, Ground-Water Quality Assessment
Program Technical Information Form must be utilized also.
2.0 Regional/Facility Map(s)
2.1 Is a regional map of the area, with the facility
delineated, included? (Y/N)
If yes,
2.1.1 What is the origin and scale of the map?
2.1.2 Is the surficial geology adequately illustrated? (Y/N)
-------
2.1.3 Are there any significant topographic or
surficial features evident? (Y/N)
If yes, describe
2.1.4 Are there any streams, rivers, lakes, or wet
lands near the facility? (Y/N)
If yes, indicate approximate distances from
the facility
2.1.5 Are there any discharging or recharging wells
near the facility? (Y/N)
If yes, indicate approximate distances from the
facility.
2.2 Is a regional hydrogeologic map of the area included?
(This information may be shown on 2.1) (Y/N)
If yes:
2.2.1 Are major areas of re charge/dishcarge shown? (Y/N)
If yes, describe.
2.2.2 Is the regional ground-water flow direction
indicated? (Y/N)
2.2.3 Are the potentiometric contours logical? (Y/N)
If not, -explain. •
2.3 Is a facility plot plan included? (Y/N)
2.3.1 Are facility components (landfill areas, impound-
ments, etc.) shown? (Y/N)
2.3.2 Are any seeps, spring:?, streams, ponds, or
wetlands indicated? (Y/N)
-------
2.3.3 Are the locations of any monitoring wells, soil
borings, or test pits shown? (Y/N)
2.3.4 Is the facility a multi-component facility? (Y/N)
If yes:
2.3.4.1 Are individual components adequately
monitored? (Y/N)
2.3.4.2 Is a Waste Management Area delineated? (Y/N)
2.4 Is a site water table (potentiometric) contour map
included? (Y/N)
If yes,
2.4.1 Do the potentiometric contours appear logical
based on topography and presented
data? (Consult water level data) (Y/N)
2.4.2 Are groundwater flowlines indicated? (Y/N)
2.4.3 Are static water levels shown? (Y/N)
2.2.4 May hydraulic gradients be estimated? (Y/N)
2.4.5 Is at least one monitoring well located
hydraulically upgradient of the waste
management area(s)? (Y/N)
2.4.6 Are at least three monitoring wells located
hydraulically downgradient of the waste
management area(s)? (Y/N)
2.4.7 By their location, do the upgradient wells appear
capable of providing representative ambient ground-
water quality data? (Y/N)
If no, explain.
-------
3.0 Soil Boring/Test Pit Details
3.1 Were soil borings/test pits made under the supervision
of a qualified professional? (Y/N)
If yes,
3.1.1 Indicate the individual(s) and affiliation(s):
3.1.2 Indicate the drilling/excavating contractor, if known
3.2 If soil borings/test pits were made, indicate the method(s)
of drilling/excavating:
Auger (hollow or solid stem)
Mud rotary
Air rotary
Reverse rotary
Cable tool
Jetting
Other, including excavation (explain)
3.3 List the number of soil borings/test pits made at the site
3.3.1 Pre-existing
3.3.2 For RCRA compliance
3.4 Indicate borehole diameters and depths (if different
diameters and depths use TABLE B-l).
3.4.1 Diameter:
3.4.2 Depth:
3.5 Were lithologic samples collected during drilling? (Y/N)
If yes,
3.5.1 How were samples obtained? (Check method(s))
Split spoon
Shelby tube, or similar
Rock coring
Ditch sampling
Other (explain)
-------
INFORMATION TABLE B-1
BORING NO.
DEPTH
DIAMETER
-------
3.5.2 At what interval were samples collected?
3.5.3 Were the deposits or rock units penetrated
described? (boring logs, etc.) (Y/N)
3.6 If test pits were excavated at the site, describe
procedures._
4.0 WeU Completion Detail
4.1 Were the wells installed under the supervision of a qualified
professional? (Y/N)
If yes:
4.1.1 Indicate the individual and affiliation, if known
4.1.2 Indicate the well construction contractor, if known
4.2 List the number of wells at the site
4.2.1 Pre-existing
4.2.2 For RCRA Compliance
4.3 WeU construction information (fill out INFORMATION
TABLE B-2)
4.3.1 If PVC well screen or casing is used, are joints
(couplings):
• Glued on
• Screwed on
4.3.2 Are well screens sand/gravel packed? (Y/N)
-------
4.3.3 Are annular spaces sealed?
If yes, describe:
• bentonite slurry
• Cement grout
• Other (explain)
(Y/N)
• Thicknesses of seals
4.3.4 If "open hole" wells, are the cased portions sealed
in place? (Y/N)
If yes, describe how:
4.3.5 Are there cement surface seals?
If yes,
• How thick?
(Y/N)
4.3.6 Are the wells capped?
If yes,
• Do they lock?
4.3.7 Are protective standpipes cemented in place?
4.3.8 Were wells developed?
If yes, check appropriate method(s):
Air lift pumping
Pumping and surging
Jetting
Bailing
Other (explain)
(Y/N)
(Y/N)
(Y/N)
(Y/N)
5.0 Aquifer Characterization
5.1 Has the extent of the uppermost saturated zone
(aquifer) in the facility area been defined?
If yes,
5.1.1 Are soil boring/test pit logs included?
5.1.2 Are geologic cross-sections included?
(Y/N)
(Y/N)
(Y/N)
-------
INFORMATION TABLE B-2
WELL NO.
GROUND ELEVATION
TOTAL DEPTH
«o
<
u
III
*
TYPE MATERIAL
DIAMETER
LENGTH
STICK-UP
TOP ELEVATION
BOTTOM ELEVATION
ui
ui
f
U
0»
UI
DEPTH TOP/BOTTOM
TYPE MATERIAL
DIAMETER
LENGTH
SLOT SIZE
TOP ELEVATION
BOTTOM ELEVATION
H
* B
Z O
UI ^
a Q
O z
-------
5.2 Is there evidence of confining (low permeability)
layers beneath the site? (Y/N)
If yes,
5.2.1 Is the areal extent and continuity indicated? (Y/N)
5.2.2 Is there any potential for saturated conditions
(perched water) to occur above the uppermost
aquifer? (Y/N)
If yes, give details:
a) Should or is this perched zone being
monitored? (Y/N)
Explain
5.2.3 What is the lithology and texture of the
uppermost saturated zone (aquifer)?
5.2.4 What is the saturated thickness, if indicated?
5.3 Were static water levels measured? (Y/N)
If yes,
5.3.1 How were the water levels measured (check method(s)).
• Electric water sounder
• Wetted tape
• Air line
• Other (explain)
5.3.2 Do fluctuations in static water levels occur? (Y/N)
If yes,
5.3.2.1 Are they accounted for (e.g. seasonal,
tidal, etc.)? (Y/N)
If yes, describe:
-------
5.3.2.2 Do the water level fluctuations alter the
general ground-water gradients and flow
directions? (Y/N)
If yes,
5.3.2.3 Will the effectiveness of the wells to
detect contaminants be reduced? (Y/N)
Explain
5.3.2.4 Based on water level data, do any head
differentials occur that may indicate a vertical
flow component in the saturated zone? (Y/N)
If yes, explain
5.4 Have aquifer hydraulic properties been determined?
If yes,
5.4.1 Indicate method(s):
• Pumping tests
• Falling/constant head tests
• Laboratory tests (explain)
(Y/N)
5.4.2 If determined, what are the values for:
Transmissivity
Storage coefficient
Leakage
Permeability
Porosity
Specific capacity
5.4.3 In cases where several tests were undertaken, were
discrepancies in the results evident?
If yes, explain
(Y/N)
5.4.4 Were horizontal ground-water flow velocities
determined?
If yes, indicate rate of movement
(Y/N)
-------
6.0 Well Performance
6.1 Are the monitoring wells screened in the uppermost aquifer? (Y/N)
6.1.1 Is the fuE saturated thickness screened? (Y/N)
6.1.2 For single completions, are the intake areas in the:
(check appropriate levels)
• Upper portion of the aquifer
• Middle of the aquifer
• Lower portion of the aquifer
6.1.3 For well clusters, are the intake areas open
to different portions of the aquifer? (Y/N)
6.1.4 Do the intake levels of the monitoring weDs appear
to be justified due to possible contaminant
density and groundwater flow velocity? (Y/N)
7.0 Ground-Water Quality Sampling
7.1 Is a sampling (groundwater quality) program and schedule
included? (Y/N)
7.2 Are sample collection field procedures clearly outlined? (Y/N)
7.2.1 How are samples obtained: (check method(s))
Air lift pump
Submersible pump
Positive displacement pump
Centrifugal pump
Peristaltic or other suction-lift
pump
Bailer
Other (describe)
7.2.2 Are all wells sampled with the same equipment and
procedures? (Y/N)
If no, explain
7.2.3 Are adequate provisions included to clean equipment after
sampling to prevent cross-contamination between
wells? (Y/N)
-------
7.2.4 Are organic constituents to be sampled? (Y/N)
If yes,
7.2.4.1 Are samples collected with equipment to
minimize absorption and volatilization? (Y/N)
If yes,
Describe equipment
8.0 Sample Preservation and Handling
8.1 Have appropriate sample preservation and preparation
procedures been followed (filtration and preservation
where appropriate)? (Y/N)
8.2 Are samples refrigerated? (Y/N)
8.3 Are EPA recommended sample holding period requirements
adhered to? (Y/N)
8.4 Are suitable container types used? (Y/N)
8.5 Are provisions made to store1 and ship samples under
cold conditions (ice packs, etc.)? (Y/N)
8.6 Is a chain of custody control procedure clearly defined? (Y/N)
8.7 Is a specific chain of custody form illustrated? (Y/N)
If yes,
8.7.1 Will this form provide an accurate record of
sample possession from the moment the sample
is taken until the time it is analyzed? (Y/N)
9.0 Sample Analysis and Record Keeping
9.1 Is sample analysis performed by a qualified laboratory? * (Y/N)
Indicate lab
9.2 Are analytical methods described in the records? (Y/N)
9.2.1 Are analytical methods acceptable to EPA? (Y/N)
9.3 Are the required drinking water suitability parametters
tested for? (Y/N)
9.4 Are the required groundwater quality parameters tested for? (Y/N)
-------
9.5 Are the required groundwater contamination indicator
parameters tested for? (Y/N)
9.6 Are any analytical parameters determined in the field? (Y/N)
Identify:
• pH
• Temperature
• Specific conductance
• Other (describe)
9.7 Is a plan included to record information about each sample
collected during the groundwater monitoring program? (Y/N)
9.7.1 Are field activity logs included? (Y/N)
9.7.2 Are laboratory results included? (Y/N)
9.7.3 Are field procedures recorded? (Y/N)
9.7.4 Are field parameter determinations included? (Y/N)
9.7.5 Are the names and affiliation of the field personnel
included? ' (Y/N)
9.8 Are statistical analyses planned or shown for all water
quality results where necessary? (Y/N)
9.8.1 Is an analysis program set-up which adheres
to EPA guidelines? (Y/N)
9.8.2 Is Student's t-test utilized? (Y/N)
If other evaluation procedure used, identify
9.8.3 Are provisions made for submitting analysis reports
to the Regional Administrator? (Y/N)
10.0 Site Verification
10.1 Plot Plan indicating the locations of various facility
components, ground-water monitoring wells, and surface
waters? (Y/N _
10.1.1 Is the plot plan used for the inspection the same as in
the monitoring program plan documentation? (Y/N)
If not, explain
-------
10.1.2 Are all of the components of the facility identified
during the inspection addressed in the monitoring program
documentation? (Y/N)
If not, explain
10.1.3 Are there any streams, lakes or wetlands on or
adjacent to the site? (Y/N)
If yes, indicate distances from waste management areas
10.1.4 Are there any signs of water quality degradation
evident in the surface water bodies? (Y/N)
If yes, explain
10.1.5 Is there any indication of distressed or dead
vegetation on or adjacent to the site? (Y/N)
If yes, explain
10.1.6 Are there any significant topographic or surficial
features on or near the site (e.g., recharge
or discharge areas)? (Y/N)
If yes, explain
10.1.7 Are the monitor well locations and numbers in
agreement with the monitoring program
documentation? • (Y/N)
If no, explain
10.1.7.1 Were locations and elevations of the monitor
wells surveyed into some
known datum? (Y/N)
If not, explain
-------
10.1.7.2 Were the wells sounded to determine total
depth below the surface? (Y/N)
If not, explain
10.1.7.3 Were discrepancies in total depth greater than
two feet apparent in any well? (Y/N)
If yes, explain
10.1.8 Was ground water encountered in all monitoring
wells? (Y/N)
If not, indicate which well(s) were dry
10.1.9 Were water level elevations measured during the site
visit? (Y/N)
If yes, indicate well number and water level elevation
If not, explain
-------
APPENDIX - C
GROUND-WATER QUALITY ASSESSMENT PROGRAM
INFORMATION FORM
-------
APPENDIX C
GROUND-WATER QUALITY ASSESSMENT PROGRAM
INFORMATION FORM
Company Name: -L EPA I.D.#:_
Company Address:
Inspector's Name: ; Date:_
1.0 Background
1.1 List the constituents (contaminants) originating from the
waste management area: (use separate sheet
if necessary
1.2 Have the concentrations of the hazardous waste or hazardous
waste constituents shown significant increases in:
• upgradient monitoring wells (Y/N)
• downgradient monitoring wells (Y/N)
1.2.1 List or indicate on a map, the wells which have
shown significant increases: (use separate
sheet if necessary)
1.3 Were the significant increases in contaminant concentration
determined through the use of the student's t-Test? (Y/N)
If no,
1.3.1 Explain procedure used
1.4 Has the possibility of error (e.g., laboratory) been eliminated? (Y/N)
1.4.1 Explain
-------
2.0 Contaminant Characteristics
2.1 If available, list the chemical and physical properties
of the contaminants which have been detected in the
ground water: (deasity, solubility, etc.). Include on a
separate sheet if list is extensive
3.0 Implementation of the Assessment Program
3.1 Has the extent of the migration of hazardous waste or
hazardous waste constituents been determined? (Y/N)
If yes,
3.1.1 Indicate how: (check appropriate method(s))
• additional ground-water monitoring
wells
• geophysical methods
• computer simulation
• other, explain
3.2 Were monitoring wells installed? (Y/N)
If yes,
3.2.1 Record monitoring well/peizometer
completion data on INFORMATION TABLE
C-l.
3.2.2 Were well clusters (nests) used or were wells
with multiple intake areas constructed? Give
details
3.2.3 Show the numbers and locations of the additional
wells/peizometers on a site map.
3.2.4 Are the locations of the wells/piezometers justified
in view of the water table or potentiometric
surface map? (Y/N)
Give details
-------
INFORMATION TABLE C-1
WELL NO.
GROUND ELEVATION
TOTAL DEPTH
WELL CASINO
WELL SCREEN
OPEN HOLE OR
SAND/GRAVEL PACK
TYPE MATERIAL
DIAMETER
LENGTH
STICK-UP
TOP ELEVATION
BOTTOM ELEVATION
DEPTH TOP/BOTTOM
TYPE MATERIAL
DIAMETER
LENGTH
SLOT SIZE
TOP ELEVATION
BOTTOM ELEVATION
DEPTH TOP/BOTTOM
DIAMETER
LENGTH
TOP ELEVATION
BOTTOM ELEVATION
X
X
•
X
X
X
X
X
X
X
X
X
-------
3.2.5 Are the depths of the monitoring wells/
piezometers justified due to the relative
characteristics (e.g.. densities) of the contaminants? (Y/N)
Give details
3.2.6 List any other methods (e.g., soil sample analysis)
used to document the extent of the contamination.
(use separate sheet if necessary)
3.3 Has the rate of contaminant migration been determined? (Y/N)
If yes, what is it and how was it determined?
3.3.1 Does the rate of migration differ for various
contaminants? (Y/N)
Give details
3.3.2 If known, what is the cause (reason) of (for) this
differential in migration rates?
-------
APPENDIX - D
WAIVER DEMONSTRATION TECHNICAL INFORMATION FORM
-------
APPENDIX D
WAIVER DEMONSTRATION TECHNICAL INFORMATION FORM
Company Name: ; EPA ID.#:_
Company Address:
Inspector's Name: ; Date:
1.0 Site Characterization
Regional Map (U.S.G.S., 7.5 min. Topographic Quadrangle Map, or similar)
showing facility location with water supply wells near the
facility indicated.
1.0.1 Are there discharging wells near the facility? (Y/N)
If yes, give distances to wells
1.0.1.1 Which aquifers in the vicintiy provide water
supplies?
1.0.1.2 What is the estimated withdrawal (diversion)
rate from these aquifers?
1.0.2 Are there any streams, rivers, or lakes near
the facility? (Y/N)
1.0.2.1 If so, indicate approximate distances from
the facility.
1.1 Regional Hydrogeologic/Surficial Geologic Map
1.1.1 Is the surficial geology adequately illustrated? (Y/N)
1.1.2 Are areas of recharge/discharge shown? (Y/N)
1.1.3 Is regional groundwater flow direction indicated? (Y/N)
1.1.4 Are the water table or potentiometric
contours logical? (Y/N)
-------
1.2 Map of Facility (scale at least 1" = 200'), showing the locations of
facility components (e.g., surface impoundments, and disposal
areas), and groundwater monitoring wells, springs, seeps, streams, etc.
1.2.1 Is the facility a multi-component facility? (Y/N)
1.2.2 Are locations of test borings (or pits) and observation
wells shown? (Y/N)
1.2.2.1 Are borings, pits, or wells located in or near
the waste management area? (Y/N)
If yes,
1.2.2.2 Do the borings, pits, or wells appear to be
of such number, and depth to adequately
characterize the substrate? (Y/N)
Give brief detail
1.3 Boring Logs and Geologic Cross Sections
1.3.1 Are there logs of the borings or test pits? (Y/N)
1.3.2 How are the sub-surface materials described:
(check as appropriate)
1.3.2.1 Unified Soil Classification System
1.3.2.2 U.S.D.A. Soil Classification System
1.3.2.3 Burmeister Classification System
1.3.2.4 Other (explain)
1.3.3 Are geologic cross-sections included? (Y/N)
1.3.4 Is there evidence of confining (low permeability)
layers beneath the facility? (Y/N)
2.0 Waste Characterization
2.1 Has the waste material been stabilized in any way to preclude
the potential of leachate being generated? (Y/N)
If yes, briefly explain methods
-------
2.2 Have specially engineered features been incorporated
into the facility design to minimize the migration of
leachate? (Y/N)
If yes, briefly explain
3.0 Water Balance
3.1 Is precipitation data included? (Y/N)
3.1.1 How is it tabulated? (check one)
• Daily
• Weekly
• Monthly
• Annually
3.1.2 Source of data (check one)
• U.S. Weather Service
• State Agency
• Other Source
Identify
3.1.3 Length of record, in years
3.1.4 Distance of measuring point from the
facility
3.2 Is actual evapotranspiration (AET) data included? (Y/N)
3.2.1 Is the source of AET data indicated? (Y/N)
If yes, give reference
3.3 Is run-off calculated? (Y/N)
3.3.1 Is the technique referenced? - (Y/N)
If yes, give reference
3.4 Is infiltration data included? (Y/N)
3.4.1 Is source of data referenced? (Y/N)
If yes, give reference
-------
3.5 Is there a positive net infiltration recorded? (Y/N)
If yes, how much?
4.0 Unsaturated Zone Characteristics
4.1 Has the applicant demonstrated that the unsaturated
zone will isolate any waste derived leachate from the water
table, chemically or physically? (Y/N)
Briefly describe mechanismfe)
4.2 Physical Properties
4.2.1 Has the applicant defined the unsaturated thickness
and areal variability? (Y/N)
Briefly describe
4.2.2 Has the primary and secondary porosity (if any) of the
unsaturated zone been determined? (Y/N)
Briefly describe
4.2.3 Have hydraulic conductivity curves for each sediment
type comprising the unsaturated zone been
established? (Y/N)
4.2.4 Have textural analyses been performed? (Y/N)
4.2.5 Have bulk densities been estimated? (Y/N)
4.3 Chemical Properties
4.3.1 Has cation exchange been cited as an
attenuation means? (Y/N)
If yes,
4.3.1.1 Type of clay
4.3.1.2 Percent of clay
4.3.1.3 Percent of organics
4.3.1.4 pH of materials
-------
4.3.2 Have other attenuation mechanisms, if any, been
adequately explained? (Y/N)
If yes, cite mechanism:
4.3.2.1 Biodegradation
4.3.2.2 Complexation
4.3.2.3 Precipitation
4.3.2.4 Chelation
4.3.2.5 Other
5.0 Saturated Zone Physical Characteristics
5.1 Have the saturated zone hydrologic properties been
determined? (Y/N)
If yes, were pumping tests performed to determine (check
appropriate determinations and give results)
5.1.1 Transmissivity
5.1.2 Hydraulic Conductivity
5.1.3 Storage Coefficient
5.1.4 Leakage
5.2 How many tests were performed?
5.2.1 The duration(s) of test(s)
5.2.2 The length(s) of the recovery test(s)_
5.3 Were other insitu tests performed? (Y/N)
(check appropriate tests)
5.3.1 Falling head tests
5.3.2 Constant head tests
5.3.3 Packer tests
5.3.4 Other
Explain
5.4 Was the saturated thickness determined? (Y/N)
-------
5.5 Are static water level measurements included? (Y/N)
5.6 Is a site water table (equipotential) contour map included? (Y/N)
5.6.1 Does the contour map appear logical based on the
presented data and topography? (Y/N)
5.6.2 Are groundwater flowlines indicated? (Y/N)
5.6.3 Are hydraulic gradients included? (Y/N)
5.6.4 Are flow velocities included? (Y/N)
5.7 Is there any indication of vertical flow in the saturated zone? (Y/N)
5.8 Saturated Zone Chemical Properties of Ground Water
5.8.1 Have water quality analyses been performed to
establish background data? (Y/N)
5.8.2 Does background information indicate that the
aquifer may be degraded in any way? (Y/N)
6.0 Computer Modeling
6.1 Was a computer simulation utilized in the demonstration? (Y/N)
Check appropriate model:
6.1.1 Mass transport
6.1.2 Flow model
6.2 Type of model? (check appropriate type)
6.2.1 Numerical
6.2.2 Analytic
6.2.3 Reference for model?
6.2.4 Does the data appear to warrant the use of modeling
techniques? (Y/N)
If not, explain
-------
APPENDIX - E
RCRA REFERENCES
-------
APPENDIX E
RCRA REFERENCES
1. Implement a ground-water monitoring system (265.90)
2. Submit a written report to have all or part of the ground water require-
ments waived (265.90(c)) (by a geologist or geotechnical engineer)
migration of hazardous waste (or HW constituents) to the
uppermost aquifer
potential for HW to migrate from uppermost aquifer to
water supply wells or surface water
3. To qualify for an alternate plan (265.90(d))
4. Have at least one well hydraulically upgradient and at least three
hydraulically downgradient (listing # and location and depths (265.91)
5. Have all wells properly completed (265.91(c))
6. Obtain and analyze samples; also must develop and follow a ground-water
sampling and analysis plan (265.92(a))
7. Must determine the concentration or values of parameters listed
in 265.92(b)
8. Must establish background concentrations or values for all wells as
in Paragraph (b), quarterly (265.92(c))
for contaminant indicator parameters take
at least four replicate measurements, initial background arithmetic
mean <5c variance for upgradient wells (first year)
after first year, all wells must be sampled and analyzed with
the following frequencies:
- those in 265.92(b)(2) at least annually
- those in 265.92(b)(3) (indicators) at least semi-annually
elevation of ground-water surface must be determined at each
sampling
9. Within one year of effective date of regulations, prepare an
outline of a ground-water assessment program (265.93(a))*
10. Calculate arithmetic mean and variance for each indicator for each well
and compare with its initial background (265.93(b))
*See note page 2-10.
-------
11. If comparisons (265.93(c)(D) for upgradient wells show a significant
change, info must be submitted as in 265.94(aK2)(ii)
12. If comparisons (265.93(c)(2)) for the downgradient wells show a
significant change, obtain additional samples, split in two, and obtain
analyses of all additional samples to determine if difference was due
to error.
13. If significant change is confirmed, notify Regional Administrator (RA)
within seven days (265.93(d)(D)
14. Within 15 days after notification, develop and submit a specific plan to
the RA (based on outline in Paragraph a) certified by a geologist, etc.,
for a ground-water assessment program at the
facility (265.93(d)(2))
15. Must specify (265.93(d)(3))
(i) No., location and depth of wells
(ii) sampling and analytical methods
(Hi) evaluation procedures, including any use of previously gathered
ground-water quality info
(iv) schedule of implementation
16. Must implement ground-water quality assessment plan and determine
(i) rate and extent of migration of HW in ground water
(ii) concentrations of HW (or HW constituents) in ground water
(265.93(d)(4))
17. Must make first assessment determination under Paragraph 265.93(d)(4)
as soon as technically feasible, and submit a written report to the
RA (265.93(d)(5))
18. If it is determined HW's or HW constituents have not entered
the ground water:
reinstate the indicator evaluation program described in 265.92 and
265.93(b)
notify the RA within 15 days after determination
19. If it is determined HW's or HW constituents have entered the
ground water:
(265.93(d)(7)(i)) continue to make determinations on quarterly
basis until final closure; if implemented prior to final closure or
(ii) cease to make further determinations if plan was implemented
during the post-closure care period
20. 265.93(e) (Notwithstanding any other provision of this subpart), any
ground-water quality assessment to satisfy 285.93(d)(4) which is
initiated prior to final closure must be completed and reported in
accordance with 265.93(d)(5)
21. 265.93(0 Unless the ground water is monitored for 265.93(d)(4), at
least annually o/o must evaluate ground-water surface elevations under
265.92(e) to determine if 265.91(a) is satisfied. If not, the system must
be brought into compliance.
------- |