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RCRA CME Handbook
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905R90109
RCRA
Comprehensive Ground-Water Monitoring
Evaluation (CME) Handbook
To Be Utilized in Conjunction With
The Comprehensive Ground-Water Monitoring Evaluation
Operation & Maintenance
CME/O&M
Training Program 1990
PREPARED FOR
ILS. Environmental Protection Agency
RegionS
RCRA Enforcement Branch
Chicago, Illinois
and
U.S. Environmental Protection Agency
Office of Waste Programs Enforcement
Washington, D.C.
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Comprehensive Ground Water Monitoring
Evaluation Handbook
TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1
1.1 Purpose of CME 2
1.2 Relationship of CME to Other RCRA Inspections 2
13 CME Training Versus TEGD/COG Training. 4
1.4 References 6
2.0 SCOPE OF CME 7
2.1 Office Evaluation 7
2.2 Field Sampling and Analysis Audits 15
2.3 Reporting Requirements 16
2.4 References 18
3.0 OFFICE EVALUATION 19
3.1 Regulatory Status/History 20
3.2 Characterization of Site Hydrogeology 23
33 Complex Hydrogeologic Conditions 27
3.4 Well Design and Installation 27
3.5 Evaluating Past Analytical Results 31
3.6 Denning Regulatory Versus
Technical Deficiencies 35
3.7 Available Information Sources 36
35 References 37
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TABLE OF CONTENTS (CONTINUED)
Page
4.0 FIELD INSPECTION PRE-PLANNING 39
4.1 Split Sampling 39
4.2 Choosing Analytes and Monitoring
Wells for Sampling 40
4.3 Identifying Required Field Verification 42
4.4 Contacting the Facility 42
4.5 References 44
50 FIELD INSPECTIONS 45
5.1 CME Versus O & M Inspection 46
5.2 Sampling and Analysis Audits 46
5.3 Collecting Split Samples 53
5.4 Collection of Additional Reid Data 54
5.5 Documenting the Audit 56
5.6 Defining Regulatory Versus
Technical Deficiencies 58
5.7 References 59
6.0 REPORTING REQUIREMENTS 61
6.1 The CME Report 61
6.2 Office Assessment Report 61
6.3 Field Inspection Report 61
6.4 Variations of CME Report 62
6.5 Data Gaps and Missing Information 63
6.6 References 64
6.7 Other References 64
APPENDIX A - Example Tables of Contents from CME Reports
IV
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Notice
The development of this handbook has been funded wholly or in part by
the United States Environmental Protection Agency (U.S. EPA), under
contract number 68-01-7351 to Jacobs Engineering Group Inc. (Jacobs).
It has been subject to U.S. EPA peer review, and approved as a
supplemental handbook for use in RCRA training programs. The
contents may require modification according to Region-specific needs.
U.S. EPA guidance documents are referenced throughout the handbook.
Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
First Edition 1989
Second Edition 1990
Produced by Jacobs Engineering Group Inc. .""f
Chicago, Illinois
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1.0 INTRODUCTION
This Comprehensive Ground Water Monitoring Evaluation (CME)
Handbook is based on the RCRA Ground Water Monitoring Technical
Enforcement Guidance Document (TEGD), the RCRA Ground Water
Monitoring Compliance Order Guidance (COG), and the RCRA CME
Guidance Document. The TEGD describes in detail the essential
components of an efficient ground water monitoring system that would
be consistent with the regulatory requirements of the Resource
Conservation and Recovery Act (RCRA), as set forth by the U.S.
Environmental Protection Agency in 40 CFR Parts 264,265 and 270. It
should be noted that while the TEGD does not specifically discuss 40
CFR 264, the technical approach presented for ground water still applies.
While the TEGD constitutes guidance rather than regulatory
requirements, the TEGD and SW-846, Volume Two, Chapter 11 should
continue to be the main references used when evaluating the technical
aspects of a ground water monitoring system.
The COG is a companion guidance document to the TEGD. Its purpose
is to guide enforcement officials in developing administrative orders to
correct interim status ground water monitoring violations in a manner
that is consistent with the RCRA permitting process. The technical
guidance set forth in the TEGD and the COG were condensed to
develop the checklists in the RCRA Comprehensive Ground Water
Monitoring Evaluation Document (RCRA CME Document). This
guidance document is one of three found in the RCRA Ground Water
Monitoring Systems Manual, which is being used as the manual for this
training course. The other two documents hi the manual are the
Operation and Maintenance (O&M) Inspection Guide and the RCRA
Laboratory Audit Inspection (LAI) Guidance.
This CME Handbook has been developed as a training addendum to the
RCRA Ground Water Monitoring Systems Manual, particularly to the
RCRA CME Document. We are attempting to provide flexible guidance
where little or no official policy exists. Prepared by EPA Headquarters
and Regional Staff, as well as contractor personnel, it is intended for use
by EPA, State, and contractor personnel involved in the planning and
implementation of successful RCRA CME efforts.
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1.1 Purpose of the CME
A CME requires the performance of an independent, detailed evaluation
to determine whether an owner /operator has in place a groundwater
monitoring system which is adequately designed, operated, and
maintained to detect releases, and which will be able to define the rate
and extent of contaminant migration from a RCRA regulated unit. In
special cases, a CME may be required to evaluate groundwater
corrective action under 40 CFR 264, Subpart F. A regulated unit is
defined as a landfill, waste pile, surface impoundment, or land treatment
facility as described in 40 CFR Parts 264,265 and 270.
A CME begins in the office as an extensive evaluation of all available
relevant information. This aspect of a CME is discussed in Sections 2.0
and 3.0 in this handbook. The second portion of a CME is the field
inspection, which is utilized to evaluate the operation of ground water
monitoring systems. Field inspections are discussed thoroughly in
Sections 4.0 and 5.0 in this handbook. The final step in completing a
thorough CME is the compilation of a report which presents all relevant
information, as well as an evaluation of data gaps which could effect the
overall evaluation of the ground water monitoring system. CME
reporting requirements are addressed in Section 6.0 of this handbook.
The CME report is a legal document used as a foundation for the
development of regulatory actions concerning permitting or corrective
action associated with a facility's ground water monitoring system.
Because these regulatory actions may be based on the findings of the
CME, reporting must be factual, objective, complete, and well
documented.
12 Relationship of the CME to Other RCRA Inspections
A CME is required for the evaluation of a facility's RCRA compliance
with 40 CFR Parts 264 and 265 Subparts F, and 40 CFR 270.
Specifically, it requires an evaluation of a facility's ground water
monitoring system first in the office and then in the field. A CME can be
part of other types of RCRA inspections, or the impetus for initiating
enforcement action against a facility. Other RCRA inspections in
addition to the CME are as follows:
o A Compliance Evaluation Inspection (CEI) is an on-site evaluation
of the compliance of a generator, transporter or treatment, storage
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or disposal (TSD) facility with RCRA regulations and permits.
This type of inspection is intended to gather necessary information
to compel a facility's compliance with the regulations, or to support
an enforcement action. A CEI performed at a facility which has
land-based RCRA units includes a cursory check for compliance
with ground water requirements. For example, the inspector
confirms that a ground water monitoring system is place and notes
any deficiencies. Any problems concerning ground water
monitoring noted during the CEI would be deferred to the
appropriate RCRA staff for a future CME. A person who is
anticipating conducting a CME may wish to go along on the CEI to
familiarize him/herself with the facility. It is often well worth
seeing the location of the monitoring wells and the conditions at the
site. This information may greatly aid in the effectiveness of the
office assessment.
A Case Development Inspection (GDI) is an intensive
investigation based on agency files and data gathered on-site. The
intent is to gather sufficient information to support an
enforcement action. A case development inspection usually does
not address ground water monitoring issues as this can be directly
addressed under the permitting authority. However, there are
some cases where specific regulatory issues could be in question
regarding ground water monitoring, and a CDI subsequently
implemented.
An Operation and Maintenance Inspection (O&M) is a periodical
inspection of how well a ground water monitoring system
continues functioning once it is in place. Although not covered
directly in this training addendum, the O&M process is a subset
of the CME process. Consequently, anything addressed during an
O&M Inspection will also be addressed during a CME. This type
of inspection requires an in-house review of past CME reports, as
well as a field evaluation. Conducted between CMEs, it is
performed in order to evaluate whether the ground water
monitoring system is being operated properly in the field. The
O&M also evaluates whether deficiencies identified in the
previously performed CME have been addressed by the
owner/operator. However, many static items, such as
hydrogeology and site history, may not need re-evaluation during
an O&M. A CME or an O&M is currently required at one-third
of land disposal facilities every year, according to the Fiscal Year
1990 Agency Operating Guidance. This is subject to change under
future operating guidance.
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o A Laboratory Audit Inspection (LAI) is a review of the
owner /operator's laboratory analytical program. This type of
inspection is designed to ensure reliable analytical data is
provided by the laboratory performing the analyses of the samples
collected as a part of the facility's ground water monitoring
program. An LAI may be recommended if questions arise from a
CME concerning either analytical results or laboratory integrity.
This inspection closes the loop on guidance that is needed by
enforcement officials to review the design and operation of a
RCRA ground water monitoring system.
o A Land Disposal Restrictions Inspection (LDR) is a type of CEI
inspection intended to ensure compliance with 40 CFR Part 268.
This type of inspection has no direct relationship with a CME.
One question that often arises when performing a CME concerns its
relationship to releases from Solid Waste Management Units (SWMUs)
to groundwater, or activities under the RCRA Corrective Action
Program. Although the hydrogeological data from SWMU ground water
monitoring systems or other programs is extremely useful in performing
a CME, inspectors should not directly evaluate their adequacy. A CME
directly addresses ground water monitoring systems required for
regulated units at RCRA interim status and permitted facilities; if you
are inspecting a permitted facility, you are conducting your CME under
those specific permit conditions. However, other ground water
monitoring systems should be discussed as part of the CME, and the
data should be utilized as it relates to CME interpretations, conclusions
or recommendations. While conducting a CME, keep in mind that the
information you are gathering, and the monitoring system you are
evaluating or recommending, may impact other areas which could
undergo investigation later at the facility. Your actions or
recommendations may provide information to facilitate other activities at
the site, such as a RCRA Facility Assessment.
13 CME Training Versus TEGD/COG Training
This training course focuses specifically on the procedures for conducting
a successful RCRA CME, whereas alternative TEGD/COG training
provides technical guidance which supports the RCRA CME effort. The
TEGD provides specific guidance on the following technical elements of
a CME:
o Characterization of site hydrogeology
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o Location and number of ground water monitoring wells
o Design, construction, and development of ground water wells
o Content and implementation of the sampling and analysis plan
o Statistical analysis or other data interpretation of ground water
monitoring data(Statistical analysis has been updated since the
publication of the TEGD [U.S. EPA, Office of Solid Waste, April,
1989]).
o The content and implementation of the assessment plan
The COG provides guidance on the relationship between technical
ground water monitoring inadequacies and the regulatory requirements
of 40 CFR, Part 265 Subpart F, and Part 270. A summary of this concept
is found in Figure 43 in the COG, Relationship of Technical
Inadequacies to Ground Water Performance Standards in the RCRA
CME Document.
This CME training course is directed towards helping compliance and
enforcement personnel develop a complete evaluation of a RCRA
facility's topography, geology, hydrogeology, waste management
practices and ground water monitoring systems, in order to assess the
adequacy of that groundwater monitoring system. This course will
concentrate on the following elements:
o The scope of the CME
o Office evaluation of available facility information
o Technical assessment of available information from other
independent sources
o Pre-planning of a field inspection
o Conducting the field inspection
o Requirements for preparing and completing a CME report
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1.4 References
U.S. EPA, 1985, RCRA Ground Water Monitoring Compliance Order
Guidance (COG) Document, Final August 1985.
U.S. EPA, 1986, RCRA Ground Water Monitoring Technical
Enforcement Guidance Document (TEGD), Final September 1986,
OSWER 9950.1.
U.S. EPA, 1988, RCRA Ground Water Monitoring Systems, Final
September 1988, OSWER 9950.2-.4, which includes the CME,
O&M and LAI guidances.
SW-846, Test Methods for Evaluating Solid Wastes, Volumes One and
Two, 1986.
U.S. EPA, Office of Solid Waste, AprU 1989, Statistical Analyses of
Ground Water Monitoring Data at RCRA Facilities, Interim Final.
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2.0 SCOPE OF THE CME
The scope of a CME requires the completion of the following processes:
o Office evaluation
o Field sampling and analysis audits
o Report preparation
The team conducting the CME should have a substantial knowledge of
the following disciplines:
o Hydrogeology
o Well design
o Construction of monitoring systems
o Ground water sampling
o Chemistry
o Waste characteristics
o Fate and transport in ground water
o RCRA regulations and enforcement authorities
2.1 Office Evaluation
Prior to conducting the field audit, information is collected from EPA
and State files, as well as from other sources and subjected to an
evaluation. Page six of the RCRA CME Document lists seven elements
for which a technical evaluation must be conducted during an office
evaluation. These areas include the evaluation of an owner /operator's
interpretation of the site hydrogeology, as well as an evaluation of the
design, installation, and operation and maintenance of their ground
water monitoring system.
You will need to ask co-workers for their knowledge of facility
information when such material is not in the file room. Remember,
personnel from various sections such as RCRA Permits, Enforcement,
Environmental Services Division (BSD), National Pollution Discharge
and Elimination System (NPDES), and Comprehensive Environmental
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Response Compensation and Liability Act (CERCLA) may have the key
information you need for the CME... Ask around. In some states, both
the U.S. Geological Survey or State Geological Surveys, or the State and
Federal Oil and Gas Commissions, Land Boards, etc. may have key site
specific information.
The ten steps which should be undertaken when conducting an office
evaluation are as follows:
STEP 1: Collect and document all the information in the file which
relates to the RCRA status of the facility and the design,
installation, and past performance of the monitoring system(s).
The range of information that must be collected from the facility is very
broad; it includes any information that increases our understanding of
the facility's operation and the owner/operator's assessment of the site's
geology and hydrogeology, including identification and description of the
uppermost aquifer, potentiometric surface, vertical and horizontal
gradients, and hydraulic conductivity. Information must also be obtained
on the owner /operator's design, installation, and operation and
maintenance of the ground water monitoring system. During this step
you should identify for further evaluation any solid waste management
units (SWMUs) of concern.
Information which is critical to understanding the hydrology and geology
of the facility and the design, installation, and past performance of the
monitoring system must be included in the CME report in an narrative
and/or by inclusion of relevant diagrams, figures, and tables.
STEP 2: Collect and document any other available information such as
regional hydrogeologic information which relates to the
adequacy of the monitoring system.
You want to be able to answer these two questions before the office
evaluation portion of the CME report can be completed:
o Has the owner/operator collected enough information to: (1) have
a sufficient understanding to identify potential contaminant
pathways; (2) support the placement of wells capable of
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determining the facility's impact on the uppermost aquifer; and (3)
adequately characterize the site-specific hydrogeology?
o Did the owner/operator use appropriate techniques to collect and
interpret the information on the site's hydrogeology used to support
well placement?
STEP 3: Evaluate the adequacy of the information the owner/operator
relied on in designing the monitoring system.
o The TEGD stresses that it is not possible to ensure that a
monitoring system is adequately designed unless a thorough
hydrogeologic investigation has been made. It is therefore critical
that the adequacy of the hydrogeological and geological information
developed by the owner/operator be assessed during a CME and
that the CME report concludes with a clear determination as to the
adequacy of this inspection.
The owner/operator must have adequately evaluated and relied on the
hydrogeological information s/he obtained during design of the
monitoring system. You must review the owner/operator's
interpretation and use of the geologic information available to him, and
report the findings of this review in the CME report. You may
determine that the owner/operator's interpretation is inadequate or
incorrect. In any case, you should also develop your own interpretation
of the data (to the extent that the data allow) and present that
interpretation in the CME report as well. Chapter One of the TEGD
describes data interpretation techniques the owner/operator and the
reviewing geologist may use in interpreting and presenting the geologic
information that is gathered.
STEP 4: Evaluate whether the site stratigraphy has been defined to the
required detail, interpreted, and presented in the proper
format.
The site stratigraphy must be defined in adequate detail as a result of the
owner/operator's investigation program to give the reviewing geologist a
high degree of confidence that the subsurface at the site is understood
well enough to design a monitoring well system that will sample all
potential contaminant pathways. This information must be presented
clearly and concisely, with no apparent inconsistencies or unjustified
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extrapolations of data. The method of presentation of the stratigraphy
may vary, but should include:
o Geologic maps at a scale that will show all units present at the
facility
o Geologic cross-sections at a scale that will show the thickness of all
units present beneath the facility in sufficient detail to explain any
geologic features unique to each bed (faults, folds, solution cavities,
collapse features, intrusions, truncations, excavations, etc.).
STEP 5: Evaluate the owner/operator's identification of the uppermost
aquifer (as defined by EPA regulations, 40 CFR Part 260.10)
and judge the correctness of his/her conclusions.
Independently identify and evaluate the uppermost aquifer,
and evaluate possible intercommunication with other ground
water flow systems. Identify, if possible, the uppermost
confining layer beneath the uppermost aquifer.
The most important points here are to determine whether the
owner/operator understands the EPA definition of uppermost aquifer
and whether or not he/she has correctly identified the uppermost
aquifer. The latter depends on the owner /operator having collected
sufficient relevant information to enable him to correctly identify the
uppermost aquifer. There are three steps that you must take to make
this determination:
o Evaluate the adequacy of the information the owner/operator
relied on in identifying the uppermost aquifer.
o Evaluate the owner/operator's identification of the uppermost
aquifer and judge the correctness of his/her conclusions.
o Independently identify, if necessary and based only on readily
available information, the uppermost aquifer and the uppermost
confining layer beneath that aquifer, and include those
determinations in the CME report.
STEP 6: Evaluate the owner/operator's determination of the direction,
rate, and seasonal variation of groundwater flow at the facility,
and judge the correctness of his conclusions.
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Derive, if possible, an independent determination of the direction, rate
and seasonal and artificially induced variations of groundwater flow at
the facility. Note that this can only be done by constructing
potentiometric maps.
The TEGD states that the owner/operator must have:
o Established the direction of groundwater flow (including both
horizontal and vertical components of flow).
o Established the seasonal, temporal, and any artificially induced (i.e.,
off-site production well pumping, agricultural use) variations in
groundwater flow.
o Determined the hydraulic conductivities of the hydrogeologic units
underlying their site.
Other factors relating to groundwater flow (horizontal direction, rate,
variations, and hydraulic conductivities) must be determined by the
owner /operator. When conducting the CME you must examine the
owner/operator's evaluation of these parameters and report his/her
findings in the CME report. If the owner /operator's determinations are
inadequate, you must make your own independent determinations of
these factors (horizontal direction, rate, variations, and hydraulic
conductivities), to the extent the available data allow, and report his/her
determinations in the CME report.
STEP 7: Identify, locate on a site map, and describe each regulated unit
at the facility which is subject to ground water monitoring
requirements. Specify for each regulated unit the regulatory
status which requires detection, assessment, or permit
monitoring. Locate on a map other facility components which
may affect ground water quality (e.g., leaking tanks or process
lines).
The summary of the regulated units should be based on relevant
information collected with other information compiled during STEP 1.
The intent is to collect all of the information which relates to the
regulated units and other facility components so that it can be
summarized in a single narrative and depicted on a single drawing.
Specifically, the team conducting the CME should evaluate the
owner/operator designation of the type of ground water monitoring
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system in place and determine if the system is appropriate based on
regulatory requirements.
STEP 8: Locate on a site map, present the drilling logs (if available),
and describe the construction details of each monitoring well,
either in-place or proposed.
The summary of the monitoring wells is based on information which
should also be gathered in STEP 1. Frequently this information is
contained in contractors' reports, loose drilling logs, and other drawings
and narratives. The intent is to collect all of the information so that it
can be presented in a consistent format.
STEP 9: Evaluate the owner/operator's rationale for the placement
and construction details of the upgradient well(s), and judge
the adequacy of the well(s) installed or proposed.
Independently determine, if possible, appropriate locations
and design for upgradient wells at the facility.
Adequacy of the monitoring system(s) (installed or proposed) is the key
determination of a CME. All other information gathering and analyses
in the CME lead up to this one major conclusion. It is critical that this
determination and the basis for it, both use of facts and use of your
professional judgment, be explained in full. It is not sufficient to include
in the CME report only the conclusion of adequacy or inadequacy. What
is adequate about the system (and why), and what is not adequate about
the system (and why), must be explained in detail.
STEP 10: Evaluate the owner/operator's rationale for the placement
and construction (including construction materials) of the
downgradicnt wells, and judge the adequacy of the wells, as
installed or proposed. Independently identify and evaluate
probable appropriate locations and design for downgradient
wells at the facility.
The TEGD contains, hi Chapters Two and Three, much useful
information on proper placement, design and construction of
downgradient wells. This guidance document also notes several design
parameters for downgradient well networks which are highly desirable.
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Determine the regulatory status of the facility being examined, because
this determines the regulations which apply and thus the purpose of the
monitoring system. Some scenarios are:
o Interim status facility; in operation prior to November 8,1985; no
suspected releases; detection system required (40 CFR 265.90-92);
detection system in place. (This is the simplest type of situation).
o Interim status facility; no wells in place; interim status terminated
November 8, 1985; closure plan submitted (intending to clean close);
ground water monitoring system required to assess any impact on
ground water.
o Interim status facility; several units; detection systems (40 CFR
265.90-92) in all units; one unit in assessment monitoring in 40 CFR
265.93; assessment plan submitted; assessment wells not yet installed.
o Interim status; detection system (40 CFR 265.90-92) in place; Part B
application submitted (40 CFR 270.14), including proposed or
existing monitoring system.
For permitted facilities seeking permits, the ground water monitoring
systems either in place or proposed are more complex and specific than
systems outlined under interim status (40 CFR 265). These systems
include detection (40 CFR 264.98), compliance monitoring (40 CFR
264.99) and corrective action (40 CFR 264.100).
For permitted facilities, the design and operation of the system will be
outlined, under the owner/operator's permit. It is this permit that
should be the guidance for evaluation of ground water monitoring
requirements in addition to the TEGD.
Once the scope of the CME is determined, the evaluation of the in-place
and proposed downgradient wells can be undertaken. The wells must be
evaluated for number, placement, spacing, clustering, depth, screen
length, screen position (relative to significant stratigraphic features),
construction materials, and other construction details. Adequacy of the
system with regard to these site-specific variables, as well as the
justification for this system based on site-specificity, is a matter that will
be left to the professional judgment of the team conducting the CME.
However, Chapter Three of the TEGD provides general guidelines to
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consider when determining the adequacy of the well design and
construction.
Other pobts raised in the TEGD which must be explicitly evaluated
during the conduct of the CME are:
1) Number of wells. The TEGD notes that three downgradient wells
is rarely, if ever, enough. The team conducting the CME must
evaluate the number of wells in the system, and reach a conclusion
on adequacy of the number of wells, considering all site-specific
factors. The conclusion on adequacy/inadequacy along with the
rationale which supports it, must be documented and supported in
the CME report.
2) Location of the downgradient wells. When conducting the CME
you must evaluate the placement of the downgradient wells relative
to the regulated unit. For detection systems, the detection wells
should be placed as near as practicable to the regulated unit [40
CFR 265.91(a)(2), 40 CFR 264.95(a), 40 CFR 264.98(b) and 40
CFR 264.99(b)j. The team conducting the CME must assess the
location of the actual or proposed placement of the wells and their
effectiveness in detection of contaminants emanating from the
regulated unit. For assessment systems, wells are required to be
placed so they are able to determine the "rate and extent of
migration of hazardous waste and hazardous waste constituents in
the ground water" [40 CFR 265.93(a)(2)]. You must evaluate the
adequacy of the assessment well system relative to this standard and
site-specific conditions, and assess the effectiveness of the actual or
proposed placement of the assessment wells and their effectiveness
in assessing contaminant migration.
3) Screen length. The length of the well screen must be determined
based on site-specific conditions. During the CME, you should
assess the adequacy of the screen length used, given the geologic
setting of the particular facility, the probable behavior of potential
contaminants, and the extraction capabilities of the
purging/sampling device. The team conducting the CME must
explain in the CME report the basis for the determination of
adequacy or inadequacy.
4) Depth of screened intervals. Chapter Two of the TEGD suggests
that screens be placed in order to monitor the appropriate horizons
to provide immediate detection of a release. It also stresses that it
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is extremely important that upgradient and downgradient wells be
screened in the same stratigraphic horizon(s) for comparison
purposes. The team conducting the CME should assess the
screened intervals to determine whether or not the wells will
adequately monitor all stratigraphic horizons which may serve as
contaminant pathways. Conclusions on this matter must be
recorded in the CME report.
5) Use of cluster wells. The TEGD discusses at length the
geologic/contaminant scenarios which should "prompt the
owner/operator to use well clusters." The team conducting the
CME should assess the need for and use of cluster wells to
adequately monitor the ground water up or downgradient of the
regulated units. The CME should provide conclusions on the use
or proposed use of cluster wells at the facility.
In summary, the office assessment is the foundation for the CME report
and it is where you should spend the majority of your time. Obviously,
there are certain components of the office assessment which cannot be
completed until the site inspection is completed. It is the purpose of the
office assessment, however, to identify these gaps so that they can be
answered in the field.
If the office assessment is completed correctly, all pieces to the ground
water puzzle should come together upon completion of the field
inspection. Details of the office evaluation/technical assessment are
contained in Section One of the RCRA CME Document and in Section
3.0 of this handbook. With that in mind, the following discussion below
presents the general strategy of the Field Sampling and Analysis audits.
2 J Field Sampling and Analysis Audit
The field sampling and analysis audit begins with an evaluation of
existing information. In this evaluation you should define what field
samples have been taken in the past and note the contaminants found at
the various monitoring well locations. You should also assess the
method in which the monitoring wells were sampled, such as the use of
peristaltic, bladder, or submersible pumps, and stainless steel, Teflon, or
PVC bailers. The results of your evaluation will enable you to decide
whether split samples will be needed. During the field audit, you should
focus your attention on the sampling methods and techniques used,
parameters analyzed for, preservatives used, field measurements taken,
and the integrity of the monitoring wells. This portion of the CME is the
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assessment of a facility's compliance with their Sampling and Analysis
Plan.
As previously discussed, the field sampling and analysis audit is the CME
inspector's chance to collect additional data to complete the office
assessment. Information such as water level measurements,
photoionization measurements of the well headspace, and verification of
well locations can also be performed. Observations of surface water
bodies (i.e., ground water recharge'or discharge areas) or other features
which may explain or support hydrogeological interpretations in the
office assessment should be addressed.
Additional information on the field sampling and analysis audit is
discussed in detail in Sections Two through Four in the RCRA CME
Document and in Sections 4.0 and 5.0 of this course handbook.
23 Reporting Requirements
Once the information has been received from the facility during the field
inspection, all of the data must be re-evaluated. Quite likely you will find
new informational gaps that you may be required to assess through your
own interpretation. Whenever this occurs, you should document the
source of the information and your interpretation of it when preparing
the CME report.
The CME report is a stand-alone document. It must address the
technical components of the facility's groundwater monitoring system
and assess the facility's compliance with 40 CFR Parts 264 or 265
Subpart F and 40 CFR Part 270 requirements.
The CME report must accomplish four goals:
1) A documented assessment of the adequacy of information on which
the design of the ground water monitoring system is based.
2) A documented assessment of the adequacy of the design and
construction of the ground water monitoring system.
3) A documented evaluation of the facility's operation of the ground
water monitoring system.
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4) A documented evaluation of the facility's compliance with 40 CFR
Parts 264 or 265 Subpart F and 40 CFR Part 270 requirements.
Section 6.0 of this course handbook, Reporting Requirements, will
discuss in detail the contents of a CME report, office assessment report,
field inspection report, and variations which may be appropriate for the
CME report. Chapter 5 of the RCRA Inspector's Manual also discusses
reporting requirements. Although the Inspector's Manual generally
applies directly to CEIs, the information contained therein has a broad
application to other types of RCRA inspections.
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2.4 References
U.S. EPA, OSWER, RCRA Inspector's Manual, 9938.2A, Final March
1988.
U.S. EPA, 1985, RCRA Ground Water Monitoring Compliance Order
Guidance Document, Final August 1985.
U.S. EPA, 1986, RCRA Ground Water Monitoring Technical
Enforcement Guidance Document, Final September 1986, OSWER
9950.1.
U.S. EPA, 1988, RCRA Ground Water Monitoring Systems, Final
September 1988, OSWER 9950.2-.4, which includes the CME
guidance, O&M and LAI Directives.
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3.0 OFFICE EVALUATION
The office evaluation is the portion of the CME process undertaken to
determine the adequacy of a facility's ground water monitoring system.
It is an in-depth technical evaluation of the ground water monitoring
system and the information on which this system is based. Therefore,
the team performing a CME must include qualified professionals with
expertise in the areas of geology and/or hydrogeology. The team which
performs a CME must evaluate the available information as a first step
in determining:
o What information must be compiled for inclusion in the final
report.
o What technical evaluations of the monitoring system must be
conducted and included in the final report.
o What recommendations must be developed and included in the
final report.
o What constitutes a complete technical evaluation of the facility's
ground water monitoring system.
o What data gaps exist in the available information.
o Which areas the team conducting the CME may lack expertise.
(This information should be included in the final report.)
The initial step in the office evaluation process is the accumulation of
information about the facility and the surrounding area from a variety of
sources. The accumulated information should be reviewed, categorized,
interpreted, evaluated, and assembled throughout the entire process and
should be used as the basis for making technical decisions, conclusions
and recommendations.
Specific information should be obtained about the facility relating to the
past and present operations, and the basis for the monitoring system
design, construction and performance. This site-specific information will
normally be obtained from such sources as the facility itself, EPA files
and state agency files. Although the following list is by no means
exhaustive, this information should be gathered in order to make an
adequate assessment of the facility's potential impact on the ground
water system:
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o processes that produce waste(s)
o nature and volumes of the waste(s) produced
o past and present treatment, storage and/or disposal practices for
the facility's waste(s)
o history of the regulated unit(s) (e.g., date(s) installed, expanded
and/or modified; types of waste(s) managed in each unit; record or
evidence of any releases, etc.)
o facility maps
o subsurface hydrogeology and geology, including any drilling logs,
geophysical data, or regional interpretation
o land use (nearby factories, homes, etc.,)
o topography (past and/or present)
o man-made features which might affect ground water flow
o regional information collected by the owner /operator
o previous studies of hydrology and geology
o design and evaluation of existing monitoring wells
o laboratory results of physical or chemical characteristics of any
soil/rock samples during drilling operations
o piezometer readings and ground water elevation measurements of
on-site or off-site wells
o laboratory analytical results of ground water samples
o soil, geophysical, well location, surveys, etc.
A brief discussion of the various components of an office evaluation
which should be addressed follows.
3.1 Regulatory Status/History
The ultimate purpose of the office evaluation is to determine the
adequacy of a facility's groundwater monitoring system (either installed
or proposed) in meeting the regulatory requirements of 40 CFR Parts
264,265, and/or 270, as applicable. In order to do this, the office
evaluation focuses on the evaluation of the adequacy of the information
on which the monitoring system was based and of the actual design,
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construction of, and operation and maintenance procedures for the
system.
The facility's compliance with the appropriate groundwater monitoring
requirements should be based on the following policies:
o All in-place (installed) monitoring systems, either for detection or
assessment monitoring under interim status (40 CFR 265, Subpart
F); should be evaluated based on then- intended purpose. If a
facility has both detection and assessment monitoring systems, the
systems should be evaluated independently as to their adequacy.
o For facilities with interim status and which require assessment
monitoring, any proposed groundwater quality assessment
monitoring system (whether or not it has been previously approved
and/or is under construction) should be evaluated independently of
any in-place detection monitoring system(s).
o For facilities with no in-place monitoring system, the office
evaluation should consist of an evaluation of the proposed system
which is as thorough as the available data will allow.
o Any outline of a groundwater quality assessment program
submitted in accordance with 40 CFR 265.93(a) should be evaluated
based on the criteria contained in Section 265.93(a) (l)-(3).
o For facilities that have submitted Part B permit applications, the
review of a proposed monitoring program pursuant to 40 CFR
270.14(c) should be conducted as part of the permit application
review process. If the permit application review process is
underway and the review of a proposed monitoring system has been
completed, the review should be utilized as a source document
during the office evaluation.
o For facilities which have submitted Part B permit applications, the
proposed groundwater detection compliance and/or corrective
action groundwater systems which the owner/operator proposes to
operate under 40 CFR 264, Subpart F requirements should be
outlined in the Part B application. This proposed system should
also be evaluated to determine if the system will be adequate to
supply the following requirements:
1) Whenever contamination is detected in the groundwater
monitoring system under the detection program, the
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owner/operator must institute a compliance monitoring
program.
2) Whenever the groundwater protection standard which will
be established at the issuance of the facility's permit is
exceeded at the point of compliance, the owner/operator
must be able to institute a corrective action program in
accordance with 40 CFR 264.100.
3) For facilities which are operating under a Part B permit,
the actual permit conditions set forth for groundwater
monitoring under 40 CFR 264, Subpart F will outline the
appropriate programs. Any changes to the program should
be amended in the permit. As part of the CME, the permit
conditions for groundwater monitoring and actual
compliance with these conditions should be reviewed
during the office assessment. Do not assume that the
conditions set forth in the permit are the final word for
permitted groundwater monitoring systems. Groundwater
monitoring is very dynamic, as are the changing laws and
guidance on performing groundwater monitoring.
As part of the regulatory status/history evaluation of the office
assessment, it is always most useful to make a chronological list of all
permitting or compliance activities associated with the groundwater
monitoring system. For example, list such dates as installation of
detection wells, observation of any statistically significant increases or
decreases in analytical parameters (e.g., pH), installation of any
additional wells, notification of violations cited by the state or EPA, past
CMEs or O&M inspections, and any other pertinent groundwater
monitoring events.
The compliance history can be compiled and directly utilized in the CME
report. It is a great aid to those utilizing the report to have a summary of
the groundwater monitoring history at the site which provides a
framework for data used in the CME report. Once this compliance
history is compiled, it can be updated thereafter during future CME or
O&M inspections and can be an active chronology of events for the
facility's groundwater monitoring program.
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3.2 Characterization of Site Hydrogeology
Characterization of the subsurface geology. In order to adequately
define the subsurface geology of the site (the first step toward designing
a monitoring system), the owner/operator should have performed a
detailed investigation to identify the lithology and structural
characteristics of the subsurface, using direct methods supplemented by
indirect methods. In conducting the office evaluation, you should review
the investigatory techniques used, by the owner/operator to insure that
they were adequate to define the subsurface geology of the site.
(1) The following direct techniques must have been included in the
investigation as a minimum according to the RCRA CME
Document:
o Soil borings
o Survey of existing geologic information
o Material tests (grain size analyses, standard penetration tests,
etc.)
(2) The soil boring program must include the following as a minimum:
o Several borings that are drilled to bedrock or to a low
permeability layer defined as a confining layer.
o Continuous sample corings logged by a qualified geologist for
a sufficient fraction of the total borings. You will have to
assess, based on your own judgment, whether or not the
number of borings which were logged were a sufficient
fraction.
o Accurate and complete boring logs that present all relevant
data collected during the drilling process. You should also
interpret the data which were generated and compare your
interpretation with the interpretation obtained by the
owner /operator to assess whether the site geology has been
accurately characterized. This can be accomplished by
evaluating the adequacy of the presentations of the data
generated from the investigations. The preferred methods for
data presentation are:
(A) Narrative description of geology
(B) Geologjc/hydrogeologic cross sections
(C) Geologic or soil map (suggested)
(D) Boring logs with description of strata
(E) Raw data and interpretive analysis of material tests
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In most cases, the team conducting the CME will be required to
construct cross sections, fence diagrams or other interpretive techniques
to evaluate the hydrogeologic setting. Even if the facility has constructed
such diagrams, the team performing the CME should either verify the
diagrams through an independent evaluation or data or they should
independently evaluate data and present diagrams which best present the
hydrologic conditions. For example, it may be appropriate to add
borings to the cross sections or orient cross sections differently to
present different information or interpretations. Also, many times
owner /operators or their consultants will try to correlate hydrogeologic
data with too little information; this leads to faulty assumptions.
Identification of groundwater pathways. As part of the hydrogeologic
investigation conducted to characterize the site, the owner/operator
must adequately identify all groundwater flowpaths in addition to
characterizing the subsurface geology. You should review the
investigatory techniques to insure they were adequate to accurately
identify the groundwater flowpaths.
In order to have adequately identified the groundwater flowpaths, the
owner/operator must have:
o Established the direction of groundwater flow including both
horizontal and vertical components of flow. Identification of a
groundwater flow net and the recommended method for
determining vertical and horizontal flowpaths is described in the
TEGD on pages 22 through 30.
o Establish the seasonal, temporal and artificially induced (i.e., off-
site production well pumping, agricultural use) variations in
groundwater flow (TEGD, pages 30 and 31).
o Determine the hydraulic conductivities of the hydrogeologic units
underlying the site (TEGD, pages 31 through 34).
The following direct techniques must have been included in the
investigation as a minimum:
o Installation of piezometers and water level measurements at
different depths for evaluation of groundwater flowpaths.
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o Slug tests and/or pump tests for evaluation of hydraulic
conductivity.
You should independently interpret the data generated and compare
your interpretation with the interpretation obtained by the
owner/operator to insure the groundwater flowpaths under the site have
been accurately identified. This should be accomplished by evaluating
the presentations of the data generated from the investigation. The
preferred methods for data presentation are:
o Narrative description of groundwater movement with flow patterns
described in both the vertical and horizontal direction.
o Water table or potentiometric maps (plan view) with flow lines.
o Hydrogeologic cross section.
o Flow nets.
In defining flow paths or groundwater flow direction, the geologic
information gathered during the site characterization plays a very
important role in this evaluation. For example, it may be determined
that groundwater is flowing in one direction, but contaminated flow
paths may be in other directions based on the hydrogeology. In some
cases, sands or other permeable strata may have been deposited such
that their slope or dip is in the opposite direction of groundwater flow
(i.e., beds dip to the south and groundwater flows to the north). In these
cases, identification of groundwater flow paths may be highly dependent
upon the transport of site specific contaminants. Therefore, when
defining potential contaminants or groundwater pathways, geologic,
hydrogeologic and geochemical data must all play a part in this
interpretation.
Identification of the uppermost aquifer. Since the owner/operator is
required to monitor the uppermost aquifer, the adequacy of the
owner/operator's identification of the uppermost aquifer must be
evaluated. In addition, a determination of whether or not the
owner/operator understands the definition of the uppermost aquifer is
inherent to this evaluation. On July 26,1988, the definition of an
uppermost aquifer was proposed as, "Groundwater in any saturated zone
below the facility that can act as a contaminant transport pathway". This
is the current EPA interpretation of the uppermost aquifer and it is what
you should consider to be the appropriate definition during your
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evaluation. The following five tasks should be accomplished during this
evaluation:
o Determine (either explicitly or implicitly), if possible, the definition
of the uppermost aquifer that the owner/operator used in designing
the monitoring system.
o Examine and assess the adequacy of the information the
owner/operator relied on in identifying the uppermost aquifer.
o Examine and judge the correctness (based on your own
independent research) of the information the owner/operator
relied on in identifying the uppermost aquifer.
o Examine and judge the correctness of the owner/operator's
evaluation of that information and subsequent identification of the
uppermost aquifer.
o Independently identify, if possible, the groundwater in any saturated
zone below the facility that can act as a contaminant transport
pathway.
To obtain this information, you must do two things. First you must try to
extract from the existing documents what the owner/operator has
defined as the uppermost aquifer. Do not assume that because the
owner /operator wells are in the shallow alluvium that he/she has
defined the uppermost aquifer as the shallow alluvium. In hydrogeologic
reports, the owner/operator or his/her consultants will probably not
come right out and say "this is what we believe to be the uppermost
aquifer". Second, you must speak directly with the owner/operator or
his/her consultant either over the phone during the office evaluation or
during the field inspections and ask bun/her directly what he/she
considers to be the uppermost aquifer. Before you call, do you
homework and consider all other hydrogeologic units which may be
hydraulically connected. Find out what the owner/operator's rationale
was for not including other units or aquifers which you may feel are
hydraulically connected.
Information on the definition and identification of the uppermost aquifer
can be found in the TEGD on pages 34 through 43.
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33 Complex Hydrogeologic Conditions
The TEGD describes several instances where complex hydrogeology may
influence the ability of the facility to adequately characterize the
uppermost aquifer underlying the site (pages 36 through 43).
Specific instances of complex hydrogeologic conditions which can cause
problems in groundwater monitoring include:
o Bedrock conditions/dipping beds.
o Structurally controlled groundwater movement; such as faults, folds,
fractures, jointing, etc. (i.e., secondary permeability and anisotropic
conditions).
o Karst terrains (limestone).
o Artificially induced changes in groundwater conditions (e.g.,
pumping wells, rivers, lakes, flood irrigation, etc.).
o Confined aquifer conditions
It should be noted that there are no such things as simple hydrogeologic
conditions. Even areas where homogeneous conditions appear to exist
have complex components. In other words, do not assume that it is as
simple as the data appear to dictate.
3.4 Well Design and Installation
The appropriateness of the decisions made by the owner/operator
regarding the number and locations of monitoring wells is crucial to
determining whether or not the monitoring system is adequate and meets
the requirements of the regulations. This determination is the focus of
the office evaluation. It is critical that your assessment and the basis for
it (e.g., objective, professional judgment, etc.) be explained in detail.
Well design and installation is discussed in the TEGD in Chapters Two
and Three.
The discussion in the TEGD is general guidance for well design and
installation and in no way should be applied directly to a site without
careful consideration. Each site is a dynamic set of variables which
require specific well design and construction techniques. In order to
review and evaluate well design, you must have a clear understanding of
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the site-specific hydrogeologic conditions and the chemical behavior of
the contaminants for which monitoring is required.
Upgradient well(s). In order to determine the appropriateness of the
owner/operator's groundwater monitoring system you should:
o Examine the owner /operator's rationale for placement and design
of the upgradient well(s) and judge the adequacy of the horizontal
placement and screening of the well(s), either installed or proposed.
o Independently determine, if possible, your assessment of the
appropriate location(s) and design parameters of the upgradient
well(s) at the facility.
o Identify any additional hydrogeologic investigations that should be
required before appropriate locations and design parameters can be
accurately specified for upgradient wells at the facility.
The following questions should be answered during this evaluation
regarding placement and design of upgradient wells:
o Has the owner/operator located background wells far enough away
from waste management areas to prevent contamination from the
regulated unit or from other activities at the facility?
o Has the owner/operator installed enough wells, screened at
appropriate depths, to adequately account for spatial variability in
background water quality?
While making this evaluation, you should consider the following:
o It will be an extremely unusual circumstance in which having only
one upgradient well would be considered adequate. It will be left to
the professional judgment of the team conducting the office
evaluation to determine the adequacy of the appropriate number
and location of the upgradient wells. The number of background
wells needed should be evaluated based on the number required to
determine the spatial variability of background water quality.
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o The upgradient well(s) should be screened at depths which
correspond to the geologic formations to be sampled in the
downgradient wells for comparison purposes.
o It will not usually be acceptable for the owner/operator to screen
upgradient wells over the entire thickness of the uppermost aquifer,
as this may allow dilution of contamination that may be present.
Appropriate screen lengths must be evaluated by the team
conducting the office evaluation, based on the information
compiled.
o It should be determined whether or not the upgradient well(s) are
in fact upgradient and secure from being contaminated by the
unit(s) being monitored.
Downgradient wells. The evaluation of the placement and design of the
downgradient wells (either installed or proposed) should be
accomplished based on the purpose of the monitoring system (detection,
assessment compliance or corrective action) and assessed as to its
compliance with the regulations. In order to assess the adequacy of the
placement and design of the downgradient wells, you should:
o Examine the owner/operator's rationale for the placement and
design of the downgradient wells and judge the adequacy of the
horizontal placement and screening of the wells, either installed or
proposed.
o Independently determine the appropriate location and design for
the downgradient wells at the facility.
o Identify any additional hydrogeologic investigations thai should be
required before appropriate locations and design can be accurately
specified for the downgradient wells at the facility.
The following specific items regarding downgradient wells will be
evaluated as to adequacy based on professional judgment and guidance
contained in the TEGD:
Number of wells. Although the regulations require only three
downgradient as a minimum number of wells, in almost all cases
three downgradient wells will not be enough. Only in the simplest
of geologic settings with a very shallow aquifer above bedrock and a
very small regulated unit, would there be a possibility that three
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downgradient wells be considered sufficient. Your evaluation of the
facility-specific geology and facility's groundwater monitoring plan
must include the determination of the adequacy of the number of
downgradient wells.
o Spacing of wells. The adequacy of the spacing of the downgradient
wells should be determined based on the site specific conditions.
You must independently evaluate previously gathered information
in order to ultimately determine the adequacy of the spacing of the
downgradient wells.
o Location of wells. The placement of the downgradient wells must
be evaluated in terms of their location relative to the regulated
unit(s) and of their intended purpose; (i.e., detection, compliance
assessment or corrective action monitoring). For detection
monitoring, the wells should be placed as near as practical to the
regulated unit(s). The evaluation as to how close the wells must be
placed in relation to the regulated unit(s) must be made by you
based on the information on the site which you have been able to
obtain. For assessment monitoring, the wells should be placed so
that the owner/operator can determine the rate and extent of
migration of hazardous waste and hazardous waste constituents in
the groundwater. The adequacy of the assessment monitoring
system relative to this criterion must be determined.
o Use of cluster wells. Based on the conditions at the site, the need
for and use of cluster wells should be evaluated in regard to
adequate monitoring of the groundwater in a downgradient
direction from the regulated unit(s). A determination of the
adequacy or inadequacy of the use of cluster wells, either in place
or proposed, must be made.
o Construction materials. The adequacy of the materials used in the
construction of the wells should be judged in terms of the effect of
the materials on the quality of groundwater samples (such as
adsorption, leaching and reaction with groundwater) and the long-
term structural integrity of the material.
o Screen length. The adequacy of screen length in the downgradient
wells should be determined based on site-specific aquifer and
contaminant characteristics. A determination must be made as to
whether the wells are screened adequately for detection of
contaminants in the aquifer.
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Depth of screened interval. The adequacy of the screen interval
depth must be determined based on site-specific conditions and
must insure that the wells will adequately monitor the stratigraphic
horizons most likely to serve as pathways for contaminant migration
from the regulated unit.
Well construction. The adequacy of the well construction
techniques should be assessed based on the guidance presented in
the TEGD.
Details of the groundwater monitoring system should be obtained and
summarized for inclusion with the final report. As a minimum, the
monitoring wells should be located on a site map, individual drilling logs
should be obtained, if possible, and the construction details of each well
should be obtained and evaluated.
3.5 Evaluating Past Analytical Results
As part of the office evaluation, evaluation of past analytical results plays
an extremely important role in the evaluation of a groundwater
monitoring system, In order to accurately evaluate historical analytical
results, the geologist or geochemist must understand several issues.
These issues are as follows:
o Contaminant fate and transport.
o Variability of naturally occurring groundwater.
o Data interpretation techniques.
The owner/operator should have some type of data management
program hi place which he utilizes to monitor or interpret data from
each quarter, or another pre-determined frequency, but this is not always
the case.
Contaminant Fate and Transport. The first and foremost important
issue in evaluating past analytical results is the understanding of the types
of wastes managed in the regulated units which are being monitored by
groundwater monitoring systems.
We must fully understand the waste characteristics, such as specific
gravity, density, immiscibility or solubility, volatility (Henry's law
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constant) and degradation products so that we know in what chemical
state each constituent will exist in the groundwater. In order to
understand this approach, it is best that we present several examples:
Example 1: Petroleum Refinery
At a petroleum refinery where API separator sludges were managed in a pit,
a groundwater monitoring system is in place. We know that the hazardous
waste constituents associated with these sludges include volatile and semi-
volatile organics, lead and hexavalent chromium. We also know that both
light phase immiscible oils and potentially heavy ended petroleum
distillates may be present. Lead and chromium mobility is dependent upon
both soils and the effects ofpH of the soil water or the groundwater. A
lower pH (acidic) could increase solubility of the metals and thus increase
mobility.
Based on this knowledge of the waste constituents, monitoring wells
should be placed accordingly. For example, shallow wells should be
completed to intercept the top portion of the water table and to detect
light immiscibles and deeper wells should be completed to detect heavier
constituents.
Example 2: Silicon Chip Manufacturer
At this chip manufacturing company, trichloroethylene (TCE) and
hydrochloric acid are utilized to clean silicon cylinders prior to and after
cutting chip disks. The waste water which contains waste TCE and
neutralized hydrochloric acid is managed in a surface impoundment prior
to being treated in the facility's waste water treatment plant.
We know that TCE is extremely mobile in aqueous environments due to its
ionic charge and inability to absorb in soils or aquifer media. In many
cases it travels at rates greater than groundwater velocities. Also, the
density of TCE is such that it will sink, or is a "sinker", if found in fairly
high concentrations. In the case of indicator parameters, we know that
both TOC and TOX will show increased levels if TCE is present due to the
chlorinated carbon chains and halogenated organic structures.
For hydrochloric acid, we know that corrosivity is the major waste
characteristic such thatpH indicators in groundwater may detect the
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presence of this acid. Also, hydrochloric acid in solution will show
extremely high chloride concentrations in groundwater if leached, thus
chlorides provide for a good indicator of releases to groundwater.
In siting monitoring wells, we need to be concerned with dense phase
immiscible or soluble TCE and the detection of chlorides. Thus,
monitoring wells should be placed at depth in the aquifer and in
predominant contaminant or groundwater pathways.
In summary, you can see from these examples that fate and transport of
contaminants dictates how the wells are designed, at what depths they
are completed and what constituents or indicator parameters we would
expect to be elevated from releases of wastes from a regulated unit.
Variability of Naturally Occurring Groundwater. Because downgradient
water quality is also compared to background or upgradient water
quality, it is important to understand variations in concentrations and
what may be contributing to these variations.
This interpretation can become extremely complex if the upgradient
groundwater is contaminated and you are trying to determine if a release
has occurred from a regulated unit by evaluating concentrations of
contaminants in downgradient wells versus those in upgradient wells.
This often requires some type of fingerprinting investigations.
When evaluating upgradient or background groundwater quality there
are several interpretative methods which can be employed. These
include:
Evaluating seasonal or cyclic trends
plots of concentrations versus time
plots of variance(s) between each quarter or other sampling
events
analyzing summary tables
Statistical Evaluations
calculating arithmetic means
standard deviations or variances
ranges of data; i.e., high/low
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In order to understand variations or seasonal or cyclic trends in data, you
should look for repeated patterns during certain periods of time. These
data can be plotted against water level data also and you can evaluate
whether or not concentration fluctuations can be attributed to variations
in water levels.
Obviously, you should first evaluate how the owner/operator has
established background concentrations in order to compare them with
downgradient wells. Then the team performing the CME can review the
owner/operator's data and can independently evaluate the data using
their own interpretation.
Data Interpretation Techniques. The techniques previously discussed for
evaluating the variability of naturally occurring groundwater are also
applicable here. Generally, under the detection groundwater monitoring
programs (40 CFR 264 and 265 Subparts F) the owner/operator will
have determined statistical analytical methods for interpreting whether
statistically significant increases in groundwater quality are occurring, or
have occurred. In most cases, you should review the statistical methods
and calculations performed by the owner/operator to confirm the quality
of his/her calculations. You should then independently calculate
statistics for one or two downgradient wells to verify the
owner/operator's data.
If an owner/operator is in an assessment, compliance or corrective
action program for groundwater monitoring, the data analysis techniques
are somewhat different and are left up to the owner/operator to
implement. Groundwater analytical results are meaningless unless they
are interpreted so that conclusions can be drawn on these data.
The following is a list of several data interpretation techniques which
should be utilized by the owner/operator to present/interpret data, or by
the team performing the CME to independently evaluate the
owner/operator data.
o Data plots of concentrations
o Summary statistical tables
Tabulated data
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Calculated arithmetic mean
Standard deviation or variance
Range
o Trend analysis using linear regression
o Comparison Plots
Downgradient well concentrations versus upgradient well(s)
Downgradient well concentrations versus regulatory standards
o Geostatistics
Kriging
Others
A thorough analysis of past analytical results is critical, as groundwater
data interpretation will ultimately dictate the regulatory direction that
the owner/operator's groundwater program takes.
3.6 Defining Regulatory Versus Technical Deficiencies
Figure 4.3 in the RCRA CME Document (pages A-26 through A-31)
gives examples of how technical inadequacies, such as not fully
characterizing the uppermost aquifer, relates to the regulatory
requirements of 40 CFR Parts 265 and 270. Also, while you are
summarizing deficiencies identified during the office assessment, you
should complete the checklist in Appendix A of the RCRA CME
Document in as much detail as possible prior to performing the field
inspection. The Groundwater Monitoring Compliance Order Guidance
(COG) Document explains in further detail the types of information the
CME inspector must document to support a regulatory citation.
Many EPA Regions require that conclusions in CMEs distinguish
between regulatory and technical deficiencies in the groundwater
monitoring systems. Other Regions take this one step further and
include all deficiencies under a regulatory citation. In many cases the
COG makes this possible, but the level of detail required to document a
regulatory citation versus a technical deficiency as defined in guidance
documents (i.e., TEGD) can be very cumbersome.
In certain cases, it will not be possible to relate a technical deficiency to a
regulatory citation. For example, it may be determined that
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photoionization measurements provide useful data at the well head at
sites where volatile organics occur. This recommendation or technical
deficiency can not be related to a regulatory citation.
In Figure 4-3 in the CME Guidance document, the groundwater
requirements under 40 CFR 264 Subpart F are not discussed, nor are
technical versus regulatory citations summarized for these regulations.
You must rely on the regulations in general, and interpretations from
Regions or Headquarters on the intent of each subpart and section. You
may also wish to reference the Memorandum dated December 21,1987
from the Assistant Administrator, EPA Headquarters, to Regional
Administrators concerning policy on when enforcement actions must be
taken. This policy is also known as the "Timely and Appropriate
Document".
3.7 Available Information Sources
Site specific information should be obtained from the facility's files.
Other sources which may be tapped to gain additional information to
augment the site-specific information obtained from or about the facility
are in Table 1. Examples of commonly available information are:
o USGS topographic maps
o aerial photographs
o hydrogeologic information from the USGS water resources, state
geological survey state groundwater associations, independent
studies such as theses at universities, etc.
o regional geologic studies and information
o well logs from water wells or other borings in the area near the
facility obtained from the state engineers office or other sources.
The EPA, State and local environmental/health agencies may have the
most useful site-specific information. It helps to check various
sections/departments within one agency to gather all pertinent material
relating to your site.
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TABLE 1
DATA COLLECTION INFORMATION SOURCES*
Information
Source
FKilltr-
SpecUlc
iBforautioB
Hydrogcoloor/Geolocr
Information
Source
U.S. EPA Files
Site Visit Reports
Photographs
Preliminary Assessment
Report
Field Investigation
Analytical Data
FIT/TAT Reports
Site Inspection Report
Owner/Operator Files
Permit Applications
Academic Institutions
VS. Geological Survey
U.S. DOA - Soil Conservation Service
U.S. DOA - Agricultural
Stabilization and
Conservation Service
U.S. DOI - Bureau of
Reclamation
U.S. Army Corps of
Engineers
Federal Emergency
Management Agency
U.S. DOD Installation
Restoration Program
' Adapted from: U.S. BPA, (fujdance on Remedial Invgrfiyalions Under CERCLA.
EPA/540/G-85/002
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TABLE 1 CONTINUED
DATA COLLECTION INFORMATION SOURCES*
Information
Source
Faclllty-
Speclflc
Information
Hydrogeology/Gtology
Information
Source
State Environmental
Protection or Public
Health Agencies
Stale Geological Survey
State Highway Department
Local Planning Boards
County or City Health Depts.
Town Engineer or Town Hall
Local Chamber of Commerce
Local Library
Local Well Drillers
Regional Geologic and
Hydrologic Publications
Court Records of Legal Action
Department of Justice Files
State Attorney General Files
Facility Records
Facility Owners and Employees"
Citizens Residing Near Site"
Waste Haulers and Generators'*
' Adapted from: U.S EPA. Guidance on Remedial Investigation
Under CERCLA. EPA/540/G-85/002.
Interviews require EPA concurrence.
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3.8 References
EPA, 1988, RCRA Comprehensive Groundwater Monitoring Evaluation
Document, Final September 1988.
EPA, 1986, RCRA Groundwater Monitoring Technical Enforcement
Guidance Document, Final September 1986.
EPA, 1985, RCRA Groundwater Monitoring Compliance Order
Guidance Document, Final 1985.
"Timely and Appropriate Document", U.S. EPA Assistant Administrator
to Regional Administrators, Memorandum on Enforcement
Response Policy, December 21,1987.
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4.0 FIELD INSPECTION PRE-PLANNING
The second phase of a CME is the field sampling inspection, during
which the facility is evaluated as to the adequacy of their sampling
procedures, and their compliance with then- Sampling and Analysis Plan.
This is also when the integrity of the monitoring wells in the monitoring
system can be assessed.
Before the visit to the facility, you must determine whether or not
collection of split samples is desired and, if so, what monitoring wells the
splits will be collected from. The preparation for the facility visit must
include the preparation of a Health and Safety Plan, a Quality Assurance
Project Plan and Sampling and Analysis Plan (if split sampling is to be
conducted), arrangements with the laboratory must be made (if
necessary), the facility must be notified of your inspection, and the
necessary equipment and supplies must be gathered.
Another important component of field inspection pre-planning is the
evaluation of the data gaps identified in the office evaluation and the
determination of what information may be readily obtained at the
facility. In most cases the CME inspector will have a list of information
that he/she must either request or obtain from the owner/operator or
his/her groundwater monitoring consultant.
Remember, use this pre-planning stage to organize your thoughts and
inspection strategy, such that the field inspection goes smoothly and you
take up as little time as possible from the owner/operator's busy
schedule.
Finally, make sure that if you are collecting split samples that you make
arrangements with the owner/operator well in advance and schedule a
date, time, and plan for confirmation phone calls.
4.1 Split Sampling
As stated in the RCRA CME Document, split samples should be taken
during the field audit if contamination of the wells has been determined
or is suspected, or if there is a question of the validity of the analytical
results. Taking split samples during the facility's sampling event enables
the inspector to check the facility's field measurement techniques and
equipment, their preservation and sample handling techniques, and the
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adequacy of their sampling equipment decontamination as well as the
adequacy of the laboratory used by the facility. Since the sample
collection and handling procedures are critical for generating data that
are valid and truly representative of the in-situ groundwater, the
consistency of the methods, equipment and procedures is essential and
should be thoroughly evaluated. EPA or the State Enforcement Section
may also collect samples from the facility's monitoring wells at any time,
without waiting for the facility's scheduled sampling event. However, this
does not allow the inspector to compare data obtained from the sampling
with the facility's data, nor does it afford the opportunity to assess the
facility's adherence to the Sampling and Analysis Plan and the adequacy
of their sampling techniques.
42 Choosing Monitoring Wells and Analytes for Sampling
Monitoring well sampling. The specific monitoring wells to be sampled
(i.e., samples split with the facility for comparative analyses) should be
determined based on the total number of wells in the monitoring
network. A monitoring network must contain a minimum of one
upgradient well and three downgradient wells from the regulated unit,
but in actuality probably will consist of considerably more wells. For
monitoring networks consisting of the minimum number of wells (i.e.,
four wells), it is recommended that split samples be obtained from all of
the wells.
In choosing the wells to split sample, careful consideration should be
given to the following:
o Evaluate the wells' hydraulic locations (upgradient versus
downgradient) and review the completion details to ensure that
representative groundwater samples can be obtained. (This should
be completed during the office evaluation.)
o After reviewing and evaluating which wells will yield representative
samples, utilize information from your review during the office
evaluation of past analytical results and determine which wells, if
any, are showing signs of degradation. It is those wells where
contamination exists or where critical regulatory decisions will be
made that sph't samples should be collected.
o Wells containing hard-to-sample parameters (e.g., volatile organics)
are preferable, since they require special sampling techniques to
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maintain sample integrity. This will allow evaluation of the facility's
sampling techniques for such special conditions.
Sample parameters. The specific parameters to be analyzed for, from
the samples collected, need to be established in order to inform the
laboratory so that space can be reserved for quick turnaround of the
analysis, and so that you can obtain the necessary sample containers,
preservatives, and equipment for taking field measurements, and prepare
the necessary documentation for use during the sampling effort (e.g.,
field sheets, sample tags, chain-of-custody forms). The specific
parameters to be sampled for during any inspection are established
based on the regulatory requirements. For comparability purposes, it is
often desirable to analyze for all of the constituents for which the facility
is analyzing.
Using the rationale above for selection of wells and analytes, you may
choose the wells from which to split samples with the facility in the
following manner:
Surface Impoundment No. 1.
There are five RCRA designated wells installed for detection
monitoring. The wells chosen for split sampling activities, along
with the rationale for which each well was chosen, are described
below.
MW4 Located hydraulicalfy downgradient and situated east of the
surface impoundment. Past sampling results have shown the
presence of elevated total organic carbon (TOC), specific
conductivity and slightly elevated sodium and manganese
concentrations. Additionally, this well is completed in
unconsolidated material which appears to be representative of
the uppermost shallow aquifer.
MW5 Located hydraulicalfy upgradient and situated west of the
surface impoundment. Past sampling results have shown the
presence of elevated TOXandpH. No geologic data are
available.
MW6 Located hydraulicalfy downgradient, at the northeast comer of
the surface impoundment. Past sampling results show the
presence of elevated TOX, specific conductivity, and manganese.
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Tliis well is completed in shale bedrock and appears to provide
good representation of water in the bedrock aquifer.
43 Identifying Required Field Verification
Since the field inspectors are likely to be very busy while conducting the
sampling audit, it is desirable to outline before the site visit any items
which must be verified while at the site. Some of the things which may
be required to be field-verified are the locations and integrity of the
monitoring wells, the accuracy of any facility maps which may be
referenced during the CME, and the general site conditions.
Any other issues concerning site-specific information which were
unresolved as a result of the office evaluation should be verified while at
the facility. Additional information should be collected while at the
facility to support your findings in the office evaluation or to fill any data
gaps which you have identified. This is also the time to check the
facility's records, so any data gaps for which information may be in the
facility's files should also be determined before the site visit.
4.4 Contacting the Facility
Inspections should be scheduled to coincide with the facility's regularly
scheduled sampling events. Contact with the facility should be made as
soon as possible after the facility has been identified for a CME in order
to confirm that the sampling event will occur during the quarter and so
you may determine the anticipated dates that the work will be done.
The facility should be informed as to the purpose of the site visit, the
authorities under which the CME is being conducted, the procedures the
inspectors will be following, and the information the inspectors expect to
obtain at the facility. The facility should be informed that the inspector
will be taking split samples and conducting field measurements, and that
photographs will be taken of the monitoring wells and the sampling
procedures, bottle filling, sample filtering and field measurement
techniques.
The inspector should determine the individual(s) to contact upon arrival
at the facility and should ask about the facility's health and safety
requirements (hard hat, respirator, ear plugs, etc.).
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If the facility does not have a date set upon which the sampling will be
conducted, a date should be established with them at this time. You
should not leave the sampling date open-ended, as the facility may
conduct the sampling without informing you far enough in advance for
you to prepare adequately for the field.
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4.5 References
EPA, 1988, RCRA Comprehensive Groundwater Monitoring Evaluation
Document, Final September 1988.
EPA, 1986, RCRA Groundwater Monitoring Technical Enforcement
Guidance Document, Final September 1986.
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5.0 FIELD INSPECTIONS
The inspection process will normally consist of the following major
elements: initial conference, general site evaluation, pre-sampling
activities, sampling activities and exit conference. The inspection
checklist as found in Appendix A of the RCRA CME Document
(September 1988), or a Region-authorized version should be completed
during the inspection process to insure that specific items are addressed
and all the necessary information is obtained. You may also wish to
consult SW-846, Test Methods for Evaluating Solid Wastes, Chapter 11,
which discusses groundwater monitoring systems.
Initial Conference. Upon arrival at the facility, as prearranged with
facility representatives, you should contact the responsible official and
properly identify yourself by presenting EPA/State credentials, even if
these are not asked for. The initial conference should be conducted with
the facility's participants to outline the purpose and scope of the CME.
o A tentative schedule to accomplish the inspection tasks should be
discussed and agreed upon to preclude any problems arising during
the inspection process.
o Any specific concerns or requirements of the facility, (e.g., signing
in or out of the facility, visitors' passes, delineations of restricted
areas, limitations on the use of cameras, health and safety concerns,
etc.), should be discussed, clarified and resolved.
o A copy of the facility's sampling and analysis plan should be
obtained (if not available prior to the inspection), reviewed,
discussed and critiqued with the facility representatives. Specific
procedural deficiencies should be pointed out for correction. Don't
get bogged down here. You want the sampling to proceed as
planned. Major points of contention should be saved for the exit
conference.
Information obtained during CME preparation should be verified
for correctness and completeness. Any specific issues requested to
be addressed by the person(s) who conducted the office evaluation
should be discussed as appropriate.
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5.1 CME Versus O&M Inspection
As stated in the RCRA CME Document (September 1988), a CME is
performed to assess the adequacy of a facility's groundwater monitoring
system based on design and installation, operation, and maintenance of
the monitoring wells in order to detect the rate and extent of
contaminant migration from a regulated unit. An Operation and
Maintenance Inspection (O&M) is an interim (in between CMEs)
inspection set up to evaluate how well the facility's monitoring system is
operating and is a subset of a CME, therefore is a less resource intensive
inspection than a CME. One-third of the commercial land disposal
RCRA facilities are to have a CME or an O&M every year. The
frequency of CMEs for a land disposal unit may be once every three
years with an O&M yearly in between. A land disposal unit which
receives CERCLA wastes must receive a CME or an O&M within the
year prior to the receipt of CERCLA wastes. For current requirements
for CMEs and O&Ms, refer to the Fiscal Year 1990 Agency Operating
Guidance (OSWER, March 1989) which is revised yearly.
The field inspection portion of either type of inspection may be the same,
except during the O&M any activities that have been completed since the
last CME should be evaluated (e.g., any new monitoring wells installed).
Split samples may be collected for either type of inspection, depending
upon the results obtained from the last CME (e.g., if the facility's
sampling and analysis plan was deficient).
52 Sampling and Analysis Audits
The sampling and analysis audit should focus on the facility sampling
personnel's field procedure, their adherence to the sampling and analysis
plan, their field measurement techniques, sample documentation, and
sample preservation and handling. The following are also components of
the field audit:
Measurement of well head space. As soon as the monitoring well is
uncapped, the head space should be monitored for volatile organics with
a field instrument such as a photoionization detector(PID, e.g. HNu) or
a flame ionization detector (FID, e.g., OVA). Volatile components are
often concentrated in the well head space. This measurement allows the
inspector to both evaluate health and safety protocol and assess whether
volatiles are likely to be found in the groundwater.
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Static water level measurements. Prior to pre-sampling evacuation of
each well, the water level in the well must be determined by actual
measurement. The measurements should be to the nearest 0.01 foot.
The measurements must be taken on all of the wells prior to any purging.
In some cases, the waste constituents at a site may require the
owner/operator to measure for immiscible phases (i.e., light oils or
gasoline, or dense oils such as creosotes or pentachlorophenol) during
the time of water level measurements. Even if the owner/operator does
not measure for immiscibles and the waste constituents suggest that an
immiscible phase could be present, the CME inspector should obtain
such a measurement prior to well evacuation. This measurement should
be obtained with an oil/water interface probe such as the Interface
Probe manufactured by Groundwater Recovery Systems Inc. (R). At this
time, there are very few such instruments on the market. In order to
evaluate the adequacy of the water level measurements, for your logbook
documentation you should:
o Observe the procedures used to make these measurements and
note the type of water level measurement device used.
o Make an independent water level measurement of the monitoring
wells, utilizing your own equipment for comparison.
o Determine if reference elevations of the ground surface at the well
or at the top of the well casings have been established by a reliable
survey to the nearest 0.01 foot. All of the reference elevations
should be obtained for converting water levels to elevations such
that potentiometric maps can be constructed for inclusion in the
CME report.
o Determine the adequacy of the decontamination procedures. The
parts of the water level measurement device that come into contact
with the groundwater during use must be thoroughly cleaned and
decontaminated between wells to avoid cross-contamination. As a
matter of practice, the water level measurements should be made
sequentially from the non-contaminated or least contaminated well
to the most contaminated well.
o Determine the adequacy of the maintenance and calibration
procedures (if any) and when the last calibration was performed for
the water level measurement device.
Well depths/sediment accumulation. Well depths should be measured
by sounding the bottoms with a weighted stainless steel measuring tape
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or other suitable measuring device. The differences in as-built depths
and measured depths of the monitoring wells generally indicate sediment
accumulation resulting from improperly designed and/or constructed
wells. Properly designed and constructed wells contain graded filter pack
materials and well screens with openings sized to preclude sediment
accumulation.
Evacuation of monitoring wells. The purpose of well evacuation prior to
sample withdrawal is to remove stagnant water which may not be
representative of in-situ groundwater quality. Changes in chemical
characteristics that may occur in water standing in a monitoring well are
well documented in published literature; therefore, it is critical that this
procedure be accomplished in an acceptable manner prior to sample
collection. In order to assure the collection of samples that are
representative of the in-situ groundwater quality, pre-sampling
evacuation of all standing water is preferred (any immiscible layers
should be sampled prior to evacuation). If the recovery rate is sufficient,
the well should be completely evacuated a second time and allowed to
recover prior to sampling. Complete evacuation may not be possible
from wells installed in high yield aquifers; therefore, the adequacy of the
evacuation procedures should include the evaluation of several factors,
including the type of equipment used for evacuating the wells (bailers or
pump), the discharge rate of the pump, and the location of the intake for
the pump in the well (above or within the screened interval). As a
general rule, three to five casing volumes should be evacuated or the well
should be evacuated until the measurements for pH, specific conductivity
and temperature have stabilized, and the well should be allowed to
recover prior to sampling. The inspector should observe the evacuation
procedures and record the following information:
o Type of evacuation equipment and types of materials of which it is
constructed, including delivery lines or lines used to lower
equipment into the well.
o Whether or not wells are completely evacuated, and, if so, the
number of times they are evacuated.
o Volumes evacuated from all wells.
o Methods used to determine volumes evacuated.
o Procedures for collection, management and disposal of evacuated
water.
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o Whether or not individual wells have dedicated evacuation
equipment, and the identification of this equipment.
o Decontamination and cleaning procedures for equipment used in
more than one well.
o Physical properties of evacuated water; i.e., color, odor, turbidity
and presence of oil and grease.
The TEGD discusses well evacuation on pages 102 through 104.
Sampling Activities. The inspector should observe sampling procedures,
obtain split samples (if necessary) for comparative analyses and perform
field measurements.
Sample Withdrawal. The major consideration for sample withdrawal
procedures is insuring that samples are not altered or contaminated
during the process. Sampling equipment must be constructed of
materials compatible with known or suspected (potential) contaminants.
These materials must neither leach nor absorb constituents of interest.
Sampling equipment must be dedicated to individual wells or be capable
of being fully disassembled and decontaminated between wells. Lines
used to lower equipment into the well, as well as discharge piping, must
also be constructed of materials compatible with contaminants. Sample
withdrawal may be accomplished with bailers or pumps. Bailers are
simple to operate, inexpensive, require no external power source, and
may be constructed from fluorocarbon resin or stainless steel, as
recommended in the TEGD (page 106). Pumps are available hi a wide
variety of types and may or may not be suitable for particular monitoring
well sample withdrawal operations. The TEGD recommends the use of
a bladder pump for withdrawal of a sample (page 106). The inspector
should observe sample withdrawal and record the following information
hi the field logbook:
o Type of sampling device.
o Type of materials of which sampling device, lowering lines and
discharge piping are constructed.
o Depths at which samples are recovered.
o Whether or not sampling equipment is dedicated to individual wells.
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f
o Decontamination procedures for equipment used in more than one
well.
o Whether or not samples are withdrawn and collected to minimize
absorption, agitation (aeration) and volatilization,
o Physical characteristics of samples; e.g., color, odor, turbidity and
presence of oil and grease.
o Sequence in which samples are collected.
o Sequence in which wells are sampled.
Sample containers/preservation. The type of sample container used for
each parameter to be analyzed must be made of materials compatible
with the parameter. The preservation of the samples taken for analysis
of specific parameters must be in accordance with established
procedures as outlined in the RCRA CME Document (Table 1) or EPA
SW-846. At a minimum, you should document the sample containers
and preservatives used for each constituent for which the sample is to be
analyzed.
Field measurements. You should observe the procedures used by the
facility personnel when performing measurements. You should also
perform independent field measurements (i.e., pH, specific conductance
and temperature) for comparison of results.
In regard to field measurements performed by facility personnel, you
should insure that the analytical method is an accepted procedure for
analysis of each parameter and that it is performed in an acceptable
manner. The type of field instrument utilized and the adequacy of the
calibration and maintenance procedures should also be noted.
Independent instantaneous determinations of pH, temperature, and
specific conductance should be performed on as many well samples as
time allows during the sampling event. These determinations should be
performed on a portion of the same representative aliquot that the
facility uses. These samples should be discarded after the
determinations are made and are not intended to be sent to the
laboratory for analysis. The values obtained by the inspector and the
facility should both be recorded in the field logbook.
Decontamination. Equipment and/or equipment components used in
well measurements, well evacuation or sample withdrawal should be
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decontaminated between wells to preclude contamination and/or cross-
contamination of wells. The inspector should observe and record the
decontamination procedures. Recommended decontamination
procedures are found in the RCRA CME Document on page 20. To
avoid the inadvertent contamination of the equipment, it should not be
permitted to come in contact with the ground after cleaning or prior to
use. Some type of protection such as plastic-lined buckets or plastic
sheeting (e.g., polyethylene) should be placed on the ground for use as
the work surface for sampling and measurement operations.
Documentation. The facility should maintain documents to adequately
record information obtained during a groundwater monitoring sampling
event. The inspector should review and evaluate the documents utilized
by the facility for their completeness and consistency with the sampling
and analysis plan. Copies of the specific documents relating to field
procedures and measurements should be obtained for inclusion with the
final CME report to be prepared in the office.
Specific chain-of-custody procedures and documentation should
adequately provide for a record which traces the possession and handling
of individual samples from the time of collection through laboratory
analysis. Chain-of-custody procedures are required to preserve the
integrity of individual samples.
The facility should maintain adequate field records to describe the
sampling event. The facility's completed field log book should contain
the following information:
o Identification of well
o Well depth
o Static water level depth and measurement techniques
o Presence of immiscible layers and detection method
o Well yield; i.e., high or low
o Collection method for samples of immiscible layers and sample
identification numbers
o Well evacuation procedures/equipment
o Sample withdrawal procedures/equipment
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o Decontamination procedures (if using non-dedicated equipment)
o Date and time of well evacuation and sample collection
o Well sampling sequence
o Types of sample containers used and sample identification numbers
o Preservatives used
o Parameters requested for analyses
o Field analytical methods and results
o Laboratory used and transporter of samples to lab
o Field observations during sampling event
o Name(s) of sample collector(s)
Sample Analysis. The facility should analyze the samples or have the
samples analyzed by a private laboratory in accordance with EPA
approved analytical methods for each parameter. One method should be
specified for each parameter in the facility's sampling and analysis plan.
EPA, 1986, Test Methods for Evaluating Solid Wastes (SW-846) should
be used for determining the adequacy of the analytical methods used.
Note that when analyzing and comparing split samples, it is imperative
that analytical methodologies be identified between the owner/operator
and the inspector.
If the samples are sent to a private laboratory for analyses, the inspector
should obtain information about sample shipment, analytical methods,
etc., to insure that proper procedures are followed. The name and
address of the private laboratory should be recorded in the field logbook.
Quality Assurance. You should evaluate the adequacy of the quality
control/quality assurance procedures incorporated into the sampling
event. Specifically, the facility should include field blanks, duplicate
samples and other quality control samples as needed, such as equipment
blanks if non-dedicated sampling equipment is used. In addition to
evaluating the facilitys field procedures, you may wish to use audit
samples to check laboratory accuracy for specific parameters. Although
this can be included as part of a CME, this procedure is most often
performed as part of an LAI.
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Exit Conference. Upon completion of all of the tasks involved in
conducting the inspection, an exit conference should be held with the
facility representatives as a means of providing them with a summary of
the preliminary findings of the inspection. Some of the thugs you should
accomplish during the exit conference or briefing are:
o A receipt for samples and documents should be prepared and
signed. You should keep a copy of the completed form for
inclusion in your final CME Sampling and Analysis Report.
o Critique the facility's field measurement and sampling procedures,
documentation, and other issues pertinent to the groundwater
sampling process. Specific technical recommendations should be
presented as a means of enhancing the quality of the facility's
program. Any specific regulatory requirements not being met by
the facility should be discussed, but you should point out that
additional compliance issues may result from further evaluation of
their procedures, following the inspection.
You should establish with the facility how you are going to obtain their
analytical results from the sampling event. All of the raw analytical data
from the analyses of the field samples, quality control samples and any
audit samples should be obtained in order to completely evaluate the
quality of the results. In addition, if you have not obtained them during
the inspection, you should obtain all of the facility's results from the field
measurements at this time.
53 Collecting Split Samples
If you plan to take split samples, you should supply the containers for
your own samples. These containers should be in accordance with those
required by the laboratory to which you are sending your containers and
with SW-846. The containers and preservatives should be specified in
your Sampling and Analysis Plan.
During the sampling event, you should request that any samples taken
for volatile organic analyses (VOAs) be collected first, without
alternating of the sample containers, so that agitation and volatilization
will be minimized. These samples should be collected in 40 milliliter
VOA vials and should be filled so that a meniscus is formed on the neck
of the bottle. The bottles should be carefully capped and inverted, then
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tapped to inspect for air bubbles. If air bubbles are detected, the bottle
should be emptied and the sample taken again in the same manner until
no air bubbles are present in the sample.
The remainder of the samples should be taken so that the samples are
collected hi order of most volatile to least volatile (i.e., VOA, total
organic halogen (TOX), Base Neutral/Acid Extractables (BNAs)), then
the rest of the parameters in any order. These samples should be split hi
the following manner (note: volatile parameters - VGA's and TOX
should be filled independently and not by this method):
Both the facility's and your own sample containers should be ready
for sample collection. The facility should fill their containers for a
specific parameter from one-half of the bailer, then you should fill
your container with the second half. The second bailer should be
used to first fill your container, then the facility's and so on. The
bailers should be alternated in this manner until all of the
containers are filled.
Field measurements should be taken at the same time the facility collects
theirs, and the analyses should be conducted immediately, since the field
parameters are temperature dependent.
Your samples should be preserved according to the method specified by
the laboratory for the specific analytical method. This method should be
in accordance with Table 1, Sampling and Preservation Procedures for
Detection Monitoring found in the RCRA CME Document.
5.4 Collection of Additional Field Data
Additional information should be obtained while in the field in order to
evaluate the integrity of the monitoring system and its ability to
adequately detect groundwater contamination at the facility. This is also
a chance to verify some of the information discovered during the office
evaluation, specifically any information which may have been previously
supplied by the facility.
General Site Evaluation. During the course of the inspection, you should
conduct a general evaluation of the site and regulated units to provide
further information and/or indications of actual or potential releases of
hazardous material from regulated units. The specific details will
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depend on the type of regulated unit(s), but the following items should
be observed:
o Evidence of leakage through impoundment dikes or landfill covers
(e.g., seeps).
o Evidence of seepage, (e.g., damp or wet spots or pools of standing
liquid, absent, dead or dying vegetation in isolated areas, unusually
lush vegetation growth, aquatic vegetation growth hi perennial
seeps).
o Evidence of impoundment overflowing, (e.g., insufficient freeboard
dikes and/or areas downstream denuded of vegetation, erosion of
dikes and/or downstream areas).
o Vegetation stress, (e.g., dead or dying trees and other vegetation)
over general area which may indicate contamination of the
unsaturated zone.
o Excessive erosion of landfill covers, of impoundment dikes, and
from active portions of land treatment facilities.
o Slope instability and/or failures in impoundment dikes and landfill
trench excavations.
o Surface water degradation.
Any of the above features which are observed during the course of the
inspection should be photographed and described in the final CME
Sampling and Analysis Audit inspection report.
Pre-Sampling Activities. This portion of the inspection includes
verification of the monitoring well locations, observation of the integrity
of the monitoring wells, observation of the facility personnel taking their
water level measurements and their evacuation procedures, and the
talcing of your own measurements of water levels and well depths.
Monitoring well descriptions. You should visually inspect all of the
monitoring wells for verification of the following:
o Well casing material type and diameter
o Condition of surface seal
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o Protective casing material and condition
o Evidence of damage to the protective casing or well
o Security measures (Is cap locked? Are guard posts installed around
the protective casing?)
Monitoring well locations. The locations of all of the monitoring wells
should be verified for correctness. If a detailed facility map showing the
well locations and other surface features (including the regulated units)
is available, the accuracy of the map should be verified by actual field
measurements and observations. If a detailed map is not available, a site
map showing the locations of regulated units and wells should be
prepared from field measurements and observations. At least two
reference measurements are necessary to determine a well's location in
the horizontal plane. This can be accomplished by measuring horizontal
distances in different directions to fixed surface features, by determining
compass bearings to surface features, or by a combination of both
methods.
5.5 Documenting the Audit
All of the information gathered during the Sampling and Analysis Audit
must be documented. This documentation should include the bound
field logbook, the Comprehensive Groundwater Monitoring Evaluation
Worksheet (Appendix A of the RCRA CME Document or a Regionally-
authorized version), and site photographs.
Field Logbook. Each inspector should keep a separate logbook, which
should be bound and have consecutively numbered pages. Each person
who makes an entry in the logbook must sign the page containing that
entry. All entries must be in indelible ink and any corrections must be
made by marking out the mistake with one line and initialling the mark
out.
Things which should be recorded in the field logbook:
o General site conditions
o Weather
o Persons present at the sampling
o Monitoring well placement (measurements)
56
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o Static water levels (both the facility's and the inspector's)
o Total depth measurements (both the facility's and the inspector's)
o Evacuation procedures
o Field instrument calibration
o Field measurements and times taken (both the facility's and the
inspector's)
o Sample collection procedures
o Sample collection order, times taken and preservatives used
o Field filtering techniques
o Any discrepancies either the facilities or the inspector's with
sampling and analysis plans
o Well integrity
o Type of equipment (water level indicator, pH and specific
conductivity meters, etc.)
o Decontamination procedures
o Type of pump or bailer used for evacuation/sampling of the well
Photographs. Site photographs are an excellent way to document
sampling procedures, well integrity, condition of the sample, etc.
Photographs should be taken with a 35mm camera with a standard lens
(SO mm) or with a Polaroid instant developing camera. Site photographs
should be recorded on a photo log or in the field logbook. The following
information should be recorded for each photo taken:
o Facility
o Date
o Time
o Photographer
o Direction in which photograph was taken
o Witness to the photograph
o Camera, focal length of lens, film type and ASA
o Subject
57
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The checklist should be completed on-site to verify that all the necessary
information is gathered and documented. This checklist should be
included in the Sampling and Analysis Audit Report.
5.6 Defining Regulatory Versus Technical Deficiencies
Appendix A of the RCRA CME Document (September 1988) contains
Figure 4.3, which outlines the technical deficiencies and how they relate
to regulatory deficiencies. Item No. 7 (pages A-29 through A-31)
concentrates on the regulatory deficiencies that would result from a
facility's incorrect field sampling and laboratory analysis procedures.
The discussion in Section 3.6 of this handbook regarding regulatory
versus technical deficiencies also pertains to this section.
58
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5.7 References
EPA, 1986, Test Methods for Evaluating Solid Wastes - 3rd Edition,
Volumes la, Ib and Ic and Volume 2, Chapter 11 (SW-846).
September, 1986.
EPA, 1988, RCRA Comprehensive Groundwater Monitoring Evaluation
Document, Final September 1988.
EPA, 1986, RCRA Groundwater Monitoring Technical Enforcement
Guidance Document, Final September 1986.
59
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60
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6.0 REPORTING REQUIREMENTS
6.1 The CME Report
The CME Report consists primarily of the Office Assessment Report
(Technical Assessment) and the Field Inspection Report (Sampling and
Analysis). Included in Appendix A are several example outlines and
tables of contents which may be used for future CME reports. Although
CME reports may combine the Office Evaluation and the Field
Inspection Reports, authorized States should consult with their Regions
to agree on a consistent and complete report format in meeting the
Region's or State's needs. The CME Guidance Document and the
RCRA Inspector's Manual, Chapter 5, may be helpful in such
discussions.
62 Office Assessment Report
This section of the report must establish the adequacy or inadequacy of
the facility's groundwater monitoring system based on their
characterization of the site's geology and hydrogeology, the placement of
the facility's monitoring wells, the adequacy of the facility's
characterization of the uppermost aquifer, and the adequacy of the
facility's well design and construction. As can be noted in the example
tables of contents (Appendix A), a very important section which must be
included in the report is a complete discussion of all incomplete or
missing data or information which may be needed to fully evaluate the
adequacy of the facility's monitoring system. A section detailing
incomplete or missing data must be included for each point which the
CME is evaluating. Additional detail which is specific to each region will
be discussed during the training course.
63 Field Inspection Report
This section of the report should evaluate the facility's compliance with
the Sampling and Analysis Plan, and should describe well evacuation,
sampling techniques, field measurement techniques, field monitoring
equipment calibration, sample preservation, sample handling, chain-of-
custody, and decontamination of the sampling equipment. This section is
also referred to as the QA/QC Operation Evaluation Report (See
Appendix A). Additional detail which is specific to each region will be
discussed during the training course.
61
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6.4 Variations of CME Report
The CME report may vary in format, organization, and information
detail, depending on the complexity of the site. Any of the outlines
presented in Appendix A may be used or a variation of these, as long as
the minimal information is presented. The identification of data gaps
must be included in the reports in order for the CME to have been
adequately completed.
The essential elements of compliance with the groundwater monitoring
requirements for RCRA regulated facilities, and which must be included
in a CME report at a minimum, are summarized below. These factors
represent the current status of required activities as suggested by the
Technical Enforcement Guidance Document.
1. Introduction
a. Facility's operational history
b. Facility's regulatory history
c. Facility's current RCRA status
Complete Characterization of Site's Geology and Hydrogeology
a. Subsurface geology.
b. Vertical and horizontal components of groundwater flow.
c. Hydraulic conductivity of each formation present beneath the
site.
d. The vertical extent of the uppermost aquifer to the first
confining layer beneath the facility.
3. Placement of Monitoring Wells
a. The number of wells and well clusters adequate to
immediately detect any releases or to define the rate and
extent of contamination emanating from the regulated unit.
b. The spacing of the detection monitoring well system must be
adequate to immediately detect any release from that
regulated unit.
4. Monitoring Well Construction
a. The type of materials used for the monitoring well system
must be adequate to both perform satisfactorily for a period of
62
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at least thirty years and to not interfere with the chemical
quality of the groundwater to be analyzed.
b. Proper documentation of the materials and the installation
procedures used.
5. Sampling and Analysis Program Evaluation
a. Sample collection procedures.
b. Sample preservation and handling.
c. Chain-of-Custody control.
d. Analytical procedures.
e. Field and lab quality assurance/quality control.
6. Assessment Monitoring
a. Complete hydrogeologic description of the site.
b. Determination of the vertical and horizontal extent, and rate
of migration.
c. Complete evaluation of the detection monitoring system.
7. Anticipated Action
a. Identified violations
b. Recommended enforcement response
6.5 Data Gaps and Missing Information
In order for the CME to be complete, the CME inspection must cover
all the information which was discussed and evaluated during the Office
Evaluation, as well as the Field Audit. Equally important is the inclusion
of a discussion of what information is missing and which may have an
impact on the completeness of the CME.
As has been discussed in previous sections, the most effective way to
present information in which data were not available is to present these
deficiencies in each subsection. For instances, if facility information on
the construction of their monitoring wells is unavailable, your evaluation
of the adequacy of their monitoring system is not complete. This lack of
pertinent information should be discussed in the office evaluation
sections of the report.
63
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6.6 References
EPA, 1986, Test Methods for Evaluating Solid Wastes - 3rd Edition,
Volumes la, Ib and Ic (SW-846). September, 1986.
EPA, 1988, RCRA Comprehensive Groundwater Monitoring Evaluation
Document, Final September 1988.
EPA, 1986, RCRA Groundwater Monitoring Technical Enforcement
Guidance Document, Final September 1986.
U.S. EPA, OSWER, March 1990, Agency Operating Guidance for Fiscal
Year 1990.
U.S. EPA, OSWER, RCRA Inspector's Manual, Final
March 1988.
6.7 Other References
Driscoll, Fletcher G., ed., Groundwater and Wells, Second Edition,
Johnson Div, St. Paul, Minn., 1986.
Freeze, R. Allan and John A. Cherry, Groundwater, Prentice-Hall, New
Jersey, 1979.
U.S. EPA NEIC, Manual for Groundwater and Subsurface
Investigations at Hazardous Waste Sites, EPA 330/9-81-002, July
1981.
U.S. EPA, Statistical Analysis of Groundwater Monitoring Data at
RCRA Facilities, Interim Final Guidance, April 1989.
Illinois State Water Survey, Dept. of Energy and Natural Resources,
Guide to the Selection of Materials for Monitoring Well
Construction and Groundwater Sampling, August 1983.
U.S. EPA, Robert S. Kerr Environmental Resources Laboratories,
Practical Guide to Groundwater Sampling, 600/2-85/104,
September 1985.
64
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APPENDIX A
EXAMPLE TABLES OF CONTENTS
FOR CME REPORTS
-------
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Page 1 of 4
OFFICE ASSESSMENT REPORT
TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1
1.1 Purpose of the Report 1
1.2 Documents and Reference Used 1
1.3 Facility Description • 3
2.0 EVALUATION OF THE OWNER/OPERATOR'S
HYDROGEOLOGIC ASSESSMENT 8
2.1 Methods Used by the Owner/Operator 8
2.2 Adequacy of Methods Used,
Sample and Analysis Plan; Field Methods 10
2.3 Missing/Incomplete Information 12
3.0 CHARACTERIZATION OF THE SITE'S SUBSURFACE GEOLOGY 14
3.1 Methods Used to Characterize Subsurface Geology 14
3.1.1 1982.. 15
3.1.2 Late 1984 - Early 1985.. 17
3.1.3 Late 1985 ..22
3.1.4 1986.. 27
3.1.5 1987 - 1988..27
3.2 Methods Used to Verify Geological Data 30
3.3 Methods Used to Present Geologic Data 32
3.4 Missing/Incomplete Information 33
4.0 CHARACTERIZATION OF UPPERMOST AQUIFER 35
4.1 Methods Used by the Owner/Operator
to Character!*ze the Uppermost Aquifer 35
4.2 Brief Characterization of the Uppermost Aquifer 49
4.3 Missing/Incomplete Information 50
iii
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Page 2 of 4
TABLE OF CONTENTS
(Cont.)
Page
5.0 EVALUATION OF THE FACILITY'S GROUNDUATER MONITORING
WELL DESIGN AND CONSTRUCTION 51
5.1 Characterization of Drilling Methods,
Well Construction Materials,
Well Intake Design,
Well Development and Annular Space Seals 51
5.1.1 MU-1 Through MW-4..54
5.1.2 MW-A Through MU-0 .. 55
5.1.3 MU-P Through MU-Z and MW-5 Through MU-10 . 56
5.1.4 MW-87-01 Through MW-87-41 ..61
5.1.5 MU-88-01 .,62
5.2 Monitoring Well Inspection,
Location Verification 63
5.3 Miss ing/Incomplete Information 68
6.0 EVALUATION OF THE OWNER/OPERATOR'S GROUNDWATER
MONITORING PROGRAM 70
6.1 Assessment Monitoring Program 70
6.2 Missing/Incomplete Information 76
7.0 TECHNICAL CONCLUSIONS 78
7.1 Adequacy of the Subsurface Geology
Characterization and Identification
of Related Data Gaps 78
7.2 Adequacy of the Uppermost Aquifer
Characterization and Identification
of the Related Data Gaps 78
IV
-------
TABLE OF CONTENTS
(Cont.)
Page 3 of 4
Page
7.3 Adequacy of the Groundwater Monitoring Well
Design and Construction
and Identification of Related Data Gaps 79
7.4 Adequacy of the Groundwater Monitoring Program
and Identification of Related Data Gaps 80
8.0 REGULATORY CONCLUSIONS 81
9.0 REFERENCES 82
FIGURES
Figure 1.1 Location of the Oil Patch Refinery 4
Figure 1.2 Location of SUMUs and Other Areas of Concern
at the Oil Patch Refinery 7
Figure 3.1 Locations of Monitoring Wells
Installed in 1982 16
Figure 3.2 Locations of Monitoring Wells
Installed in 1984 18
Figure 3.3 Locations of Monitoring Wells
Installed in 1985 24
Figure 3.4 Locations of Monitoring Wells
Installed in 1987-1988 29
Figure 4.1 Water Table Hydraulic Head Map, January 1988...40
Figure 4.2 Contour Map of Water Table
Elevations in the Till 41
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Page 4 of 4
EXHIBITS
Exhibit 1.1 SWMUs and AOCs Identified
in Preliminary Assessment ,
APPENDIX I - Office Evaluation Worksheet
APPENDIX II - Photograph Log
VI
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Page 1 of 3
COMPREHENSIVE GROUNDWATER MONITORING EVALUATION
OFFICE ASSESSMENT REPORT
ABC CORPORATION
FLAT ROCK, OKLAHOMA
EPA I.D. NUMBER OKOOOOOOOOO
PREPARED FOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION VI
1445 ROSS AVENUE
DALLAS, TEXAS 75202
PREPARED BY
CONSULTANTS LTD.
MAIN STREET
ANYTOUN, USA
CONTRACT NO. 68-01-7777
WORK ASSIGNMENT NO. 1
JUNE 1989
vii
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Page 2 of 3
OFFICE ASSESSMENT REPORT
TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1
1.1 Purpose of the Report 1
1.2 Documents and References Used 1
2.0 EVALUATION OF THE OWNER/
OPERATORS HYDROGEOLOGIC ASSESSMENT 2
2.1 Methods Used by the Owner/Operator 3
2.2 Adequacy of Methods Used, 4
Sample and Analysis Plan; Field Methods
2.3 Missing/Incomplete Information 8
3.0 CHARACTERIZATION OF THE SITE'S SUBSURFACE GEOLOGY 10
3.1 Methods Used to Characterize Subsurface Geology 10
3.2 Methods Used to Verify Geological Data 13
3.3 Methods Used to Present Geologic Data 13
3.4 Missing/Incomplete Information 14
4.0 CHARACTERIZATION OF UPPERMOST AQUIFER 16
4.1 Methods Used by the Owner/Operator
to Identify Flow Direction,
Fluctuations in Groundwater Level,
Hydraulic Conductivity
and the Identification of the Uppermost Aquifer 16
4.2 Brief Characterization of the Uppermost Aquifer 20
4.3 Missing/Incomplete Information 22
Vlll
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Page 3 of 3
TABLE OF CONTENTS
(Cont.)
Page
5.0 EVALUATION OF THE FACILITY'S GROUNDUATER MONITORING
WELL DESIGN AND CONSTRUCTION 21
5.1 Characterization of Drilling Methods,
Well Construction Materials, Well Intake Design,
Well Development and Annular Space Seals 23
5.2 Missing/Incomplete Information 24
6.0 EVALUATION OF THE OWNER/OPERATOR'S GROUNDUATER
MONITORING PROGRAM 26
6.1 Assessment Monitoring Program ..26
6.2 Missing/Incomplete Information 29
7.0 TECHNICAL CONCLUSIONS 30
7.1 Adequacy of the Subsurface Geology
Characterization and Identification
of Related Data Gaps 30
7.2 Adequacy of the Uppermost Aquifer
Characterization and Identification
of the Related Data Gaps 30
7.3 Adequacy of the Groundwater Monitoring Well
Design and Construction and Identification
of Related Data Gaps 31
7.4 Adequacy of the Groundwater Monitoring Program
and Identification of Related Data Gaps 32
8.0 REGULATORY CONCLUSIONS 33
9.0 REFERENCES 34
IX
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Page 1 of 6
FINAL COMPREHENSIVE GROUNDWATER MONITORING EVALUATION
OIL PATCH REFINERY
DENVER, COLORADO
EPA I.D. NUMBER COOOOOOOOOO
PREPARED FOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
999 18TH STREET, SUITE 1300
DENVER, COLORADO 80202-2405
PREPARED BY
CONSULTANTS LTD.
MAIN STREET
ANYTOUN, USA
CONTRACT NO. 69-01-7777
WORK ASSIGNMENT NO. 2
MARCH 1989
XI
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Page 2 of 6
TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1-1
1.1 Description, Objective and Scope 1-1
1.2 Documents and Reference Used 1-1
1.3 Components of the Comprehensive Groundwater
Monitoring Evaluation 1-2
1.4 Facility Description and Operation 1-2
1.5 History of Regulatory Status of Oil Patch 1-10
1.5.1 Status of Permit
Process for Oi I Patch 1-11
1.5.2 Current Groundwater Monitoring
Status of Oil Patch 1-11
2.0 KEY FINDINGS 2-1
3.0 DISCUSSION OF THE OFFICE EVALUATION AND FIELD
EVALUATION FOR OIL PATCH 3-1
3.1 Office Evaluation 3-1
3.2 Field Evaluation 3-4
4.0 ANALYTICAL RESULTS 4-1
5.0 SUMMARY AND CONCLUSIONS 5-1
5.1 Office Evaluation 5-1
5.1.1 Adequacy of the Characterization
of Subsurface Geology and
Identification of Related Data Gaps... 5-1
Xll
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Page 3 of 6
5.1.2 Adequacy of the Characterization
of the Uppermost Aquifer
and Related Data Gaps 5-2
5.1.3 Adequacy of the Groundwater Monitoring
Well Design and Construction
and Related Data Gaps 5-4
5.1.4 Adequacy of the Groundwater Monitoring
Programs and Related Data Gaps 5-13
5.2 Field Evaluation 5-16
5.2.1 Adequacy of Sample
Collection Procedures 5-16
5.2.2 Adequacy of Sample Preservation and
Handling Procedures 5-18
5.2.3 Adequacy of Chain-of-Custody Procedures5-19
5.2.4 Adequacy of Quality Assurance,
Quality Control Program 5-19
5.2.5 Integrity of Monitoring Wells
at the Surface .5-19
5.3 Regulatory Conclusions 5-21
6.0 REFERENCES 6-1
APPENDIX A - OFFICE EVALUATION WORKSHEET
APPENDIX B - FIELD EVALUATION WORKSHEET
APPENDIX C - PHOTOGRAPH LOG
APPENDIX D - FIELD LOG
APPENDIX E - ANALYTICAL RESULTS
xiii
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Page 4 of 6
LIST OF FIGURES
Page
Figure 1-1 Denver Location Map 1-3
Figure 1-2 Site Location Map 1-4
Figure 1-3 Oil Patch Refinery Operating Area 1-6
Figure 1-4 Location of Hydrocarbon Plumes
Detected at the Water Table 1-8
Figure 1-5 Location of Hydrocarbon Plume in
the Lower Sand Unit 1-9
Figure 1-6 Location of Monitoring Wells
Installed in 1982 1-12
Figure 1-7 Location of Monitoring Wells
Installed in 1984 1-13
Figure 1-8 Location of Monitoring Wells
Installed in 1985 1-14
Figure 1-9 Location of Monitoring Wells
Installed in 1987-1988 1-15
XIV
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Page 5 of 6
LIST OF TABLES
Page
Table 2-1 Technical Deficiencies Which May
Constitute Violations 2-2
Table 3-1 SUMUs and AOCs Which May Have Impacted
Groundwater Quality at Oil Patch 3-5
Table 3-2 Analytes Collected for Analysis and
Sample Containers Used During the
Oil Patch Field Evaluation 3-9
Table 3-3 Light-Phase Immiscible Samples Collected
at Oil Patch, Colorado 3-U
Table 4-1 Analytes for Each Volatile Organic
Groundwater Sample Collected at
Oil Patch, Colorado 4-3
Table 4-2 Volatile Organic Analysis Results for
Groundwater Samples Collected at
Oil Patch, Colorado 4-4
Table 4-3 Analytes for Each Semi-Volatile Groundwater
Sample Collected at Oil Patch, Colorado 4-5
Table 4-4 Semi-Volatile Results for Groundwater
Samples Collected at Oil Patch, Colorado 4-6
Table 4-5 Dissolved Metals Results for Groundwater
Samples Collected at Oil Patch, Colorado 4-7
XV
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Page 6 of 6
Table 4-6 Volatile Organic Results for Light
-Phase Immiscibl Samples Collected
at Oil Patch, Colorado ,
4-8
Table 4-7 Analytical Results for Light-Phase Immiscible
Sanples Collected at Oil Patch, Colorado 4-9
Table 5-1 Design and Construction of Groundwater
Monitoring Wells at Oil Patch, Colorado 5-6
XVI
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Page 1 of 6
JACOBS ENGINEERING CUE OUTLINE
Page
1.0 INTRODUCTION (purpose) 1/2 pg.
2.0 FACILITY DESCRIPTION
Location 1/4 pg.
2.1 Operations, Processes, Products 1 pg.
2.2 Waste Management Practices
2.2.1 Nature and Volume of Wastes 1/2 pg.
2.2.2 Past and Present Treatment,
Storage and/or Disposal Practices
for Wastes 1/2 pg.
2.2.3 Description of Regulated Units
Dates Installed - Construction Details,
Dates of Expansion/modification unit
Types of Wastes Managed in the Units,
Site Map 1 pg.
2.3 Description of Other Facility Components
That Could Effect Groundwater Quality
(reference to site map) 0 - 1 pg.
2.4 Regulatory Compliance
2.4.1 Chronology (by dates;
note any releases) 1 pg.
2.4.2 Regulatory Status Which Applies
to Each Unit (detection, assessment
or permit requirements) 1 pg.
xvii
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Page 2 of 6
3.0 REGIONAL GEOLOGY/HYDROGEOLOGY
3.1 Owner/Operator Information
3.1.1 Stratigraphy and Water-Bearing
Characteristics ................. 1 1/2 pg.
- regional setting
- depth, area I extent and thickness of
water bearing and confining units
- stratigraphic cross
section(geologic/hydrologic) ...... 1 pg.
3.2 Other Available Information
(Only as it supplements 3.1 with
necessary data, or contradicts)
3.1 in important aspects (e.g., substantial
difference in reported thickness of
water-bearing formations) ................. 0-1 pg.
3.3 Adequacy of the Owner/Operator Information
(If 3.2 confirms 3.1, leave out
section 3.2 and state here that the other
background information confirms the
owners information) ....................... 1/2 pg.
4.0 SITE GEOLOGY/HYDROGEOLOGY
4.1 Owner/Operator Information
xviii
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Page 3 of 6
4.1.1 Stratigraphy and Water-Bearing
Characteristics 2 pg.
- site setting
- depth, areaI extent and thickness
of water-bearing and confining
units,including uppermost aquifer
and aquitard
- stratigraphic cross section
(geologic/hydrogeologic) 1 pg.
- well logs (Appendix)
- potentiometric surface maps 2 pg.
- seasonal fluctuations 1/4 pg.
- flow direction 1/2 pg.
- flow rate
- artificially induced variations
in flow 0-1 pg.
4.1.2 Uppermost Aquifer Parameters
- pump/slug test data and
interpretation, including
transmissivity, storage,
and leakage 1-2 pg.
- hydraulic conductivity/permeability1/4 pg.
- grain size 1/4 pg.
• specific capacity 1/2 pg.
- yield
- hydraulic connection between
aquifers/surface waters
(river gauge elevations) 1/2-1 pg.
4.1.3 Uppermost Aquitard Parameters 1 pg.
4.1.4 Background Water Quality 2-3 pg.
XIX
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Page 4 of 6
4.2 Other Available Informal ion/Independent
Assessment (Only as it supplements 4.1
with necessary data or contradicts 4.1
in important aspects. Hay include,
if necessary): 0-3 pg.
- independent identification
of the uppermost aquifer
- independent identification
of the uppermost aquitard
beneath the uppermost aquifer
• independent determination of
detection, rate, seasonal
and artificially induced
variations of groundwater flow
4.3 Adequacy of Owner/Operator Information
(If 4.2 confirms 4.1, leave out section
4.2 and state here that other available
background information confirms
the owner's information) 1-2 pg.
5.0 GROUNDWATER MONITORING SYSTEM EVALUATION
(Detection and Assessment)
5.1 Design 2 pg.
- number and placement of upgradient
and downgradient wells map
- well clusters (if applicable) 0-1 pg.
XX
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5 of 6
5.2 Construction Details 2-4 pg.
- drilling methods and logs (Appendix)
- depth
- diameter
- casing and screen materials
• screen lengths
- depths of screened intervals
- installation details and construction materials
(filter pack, grouting, security caps, etc.)
- well development methods
5.3 Past Performance 2-4 pg.
- analytical data
5.4 Adequacy of Detection Monitoring System
- will or will not immediately detect any
release from any regulated unit, and why,
or available information is insufficient
to assess adequacy, and why 1/2-1 pg.
- additional information required
5.5 Adequacy of Assessment Monitoring System
- will or will not determine the rate
and extent of migration
of hazardous waste/constituents in
groundwater, and why, or available
information is insufficient
to assess adequacy, and why 0-1 pg.
- additional information required 0-1 pg.
xxi
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Page 6 of 6
6.0 CONCLUSIONS AND RECOMMENDATIONS
- sunroary list of deficiencies ................... 1-3 pg.
- requirements for adequacy
REFERENCES
APPENDIXES
XXI1
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Page 1 of 3
CHE REPORT OUTLINE
I. Purpose and Description of CHE
A. Office Evaluation Component (TEGD)
B. QA/QC Operation Evaluation Component
II. Office Evaluation
A. Introduction
1. Facility name
2. Location
3. General description of operations,
processes and products
B. Hazardous Wastes
1. Part A
2. Wastes managed in units subject
to groundwater monitoring
C. Waste Management Units
1. Description of units subject
to groundwater monitoring
2. Construction details
a. liners
b. leachate collection
c. berms
3. History of failures or releases
xxiii
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Page 2 of 3
Regulatory Status
1. Indicator evaluation monitoring
2. Assessment monitoring
3. -Closure
a. clean closure for grounduater assessment
b. closure with post-closure monitoring
4. Corrective Ac"*ion
E. Compliance History
F. Information and Data Sources
G. Regional Geology ' -
1. Facility's description of regional geology
a. deficiencies'"
b. requirements for adequacy
H. Site Geology
1."' ' Explorations 'program
.'-3 " • >ai> deficiencies
b. requirements of adequacy
2. Presentation of data
a. deficiencies
\ •':,-• .^ :••,- b.;*eqirtrements of adequacy '
I. Groundwater Hydrology -'«!
1. Aquifer determinatibns
2. Aquitard determinations
3. Hydraulic cofidUctfvfty- tests* ' -
a. laboratory
b. field' '••'••'"• • '"-
4. .IJetepfflW1at1^rv of floM-rater an* directions
5. Deficiencies
d L ••>. -.1 s. ' ''Requirements^foT^adequacy > -
XX v
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_ Page 3 of 3
J. Monitoring Wells -_^ —v <>
1. , Upgradient
a. locations ^
b. construction materials f
•»„ c. screen lengths
;oti!., •• d. screen intervals
e. deficiencies. .... . _,.
f. requirements for adequacy
2. Downgradient
a. locations ,, ... ,
b. construction materials
c. screen lengths : .,»
,t • , d. screen intervals r <
e. deficiencies ,, .r
f. requirements for adequacy
K. Conclusions
1. Adequacy of information and data
2. Adequacy of, monitoring.well system
i -:. •
III. QA/OC Operation Evaluation.Report ; \
• 7 I • • * •:
IV. Summary list of deficiencieg/jand requirements for adequacy
V. Attachments - > t t
A. Topographic Hap ,,<- , . , .
B. Site Plan , ,s -- ,<.;_' .1
C. Piezojnetrif CpntoMPs. -.., ,(
0. Well Logs ,„, i . ,
E. Well Construction Drawings • •
st> F; y>>i Geologic Cross-Sections, and;Profiles ,
;. '• • -i,
* Summaries of deficiencies, and adequacy requirements, would be lists
of items written so that they could be directly incorporated into
NOD'S/LOW'S, Compliance Orders, etc. by permit or compliance staff.
XXV
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xxvi
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