OSWER995O2
RCRA COMPREHENSIVE
GROUND-WATER
MONITORING EVALUATION
DOCUMENT
(RCRA Ground-Water Monitoring Systems)
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RCRA COMPREHENSIVE
GROUND-WATER
MONITORING EVALUATION
DOCUMENT
(RCRA Ground-Water Monitoring Systems)
FINAL
RCRA Enforcement Division
Office of Waste Programs Enforcement
U.S. Environmental Protection Agency
March 1988
U.S. EPA Hegion III '
FI.f3gi0I/.&1 Center for Environmental
JI&ibnnation
l(jGO Arch Street (3PM52)
l~hll~Hll;lphia. PA 19:tOR
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9950.2
FINAL RCRA COMPREHENSIVE GROUND-WATER
MONITORING EVALUATION GUIDANCE DOCUMENT.
Table of Contents
Section
Page
In.ttoduction .. . . .. . . . . . . .. .. .. . . . . . . . ~ .. .. .. .. . . . . . . . . . .. . .. ,'. .. .. .. . . . . .. . . . . . . .. . . . . . . .. . . . . . . 2
. .
1.0 Summary of Approach and Office Evaluation.........................4
2.0 Field Evaluation and Verification Preparation. . . . . . . . . . . . . . . . . . . . . . . 13
3.0 Field Evaluation and Verification Activities. . . . . . . . .. .. . . . . . . . . . .. .. 15
4.0' Sampling and Analysis.. ...... .... ... .. .. .. .. .. . . .. .. .. .. .. .. .. .. .... ..30
5.0 Conclusions and Recommendations ....... .......... ................30
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Appendix A-Comprehensive Ground-Water Monitoring Evaluation
W ork.sheet . . .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. A-1
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FINAL RCRA COMPREHENSIVE GROUND-WATER
MONITORING EV ALUA TION GUIDANCE DOCUMENT
Introduction.
Several types of inspections and evaluations have been developed by the
United States Environmental Protection Agency (EP A) to assist the Regions
and States in detennining the degree of compliance with the Resource .
Conservation and Recovery Act (RCRA) regulations of owners and operators
of hazardous waste management facilities. These inspections/evaluations
cover all aspects of the RCRA requirements for all types of facilities. . They are
performed by people of various backgrounds throughout the country. It is the
purpose of this guidance to provide a framework within which
inspections/evaluations may be performed, and to promote, therefore, a
nationally consistent approach to that performance. Among the benefits are a
clearer understanding among regulators and the regulated community of the
scope of each inspection/evaluation, and the compilation of a reliable,
reproducible data base. Site specific conditions will determine within the
scope, the extent of the evaluation at a particular site. A consistent approach to
conducting inspections/evaluations removes a source of artificial variability,
and so focuses more attention on the fmdings rather than the methods.
Clearly, the fmdings of inspections/evaluations are integrally important to the
enforcement process. The Compliance Evaluation Inspection, Case
Development Inspection, Comprehensive Ground-Water Monitoring
Evaluation, Follow-Up Evaluation, Sampling Inspection, Citizen Complaint,
Part B Call-In, Withdrawal Candidate, Closed Facility and Other-General. At
this point in time, OWPE intends to develop guidance for six (6) of them:
1. Com»1iance EnJuation fnsJ>ection (CEll is an on-site evaluation of
the compliance of a facility with RCRA regulations and permits
intended to gather infonnation necessary to support an enforcement
action.
2.
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3. Comprep,ensive Ground-Water Monitoring EYaluation (CMEj is a
detailed evaluation of the adequacy of the design and operation of
ground-water monitoring systems at RCRA facilities.
4. l.&.borat01Y Aud.i1]nspection (LAn is a review of the
owner/operator's laboratory analytical program.
5. Operation and..,Maintenance Jnspection (O&Ml.is a periadoc
inspection of how well a ground-water mon itoring system continues.
to function once it is in place. .
6. LmllLDisposaLRestrictions Inspection (Ll2Rl.is an inspection
intended to ensure compliance with the land disposal restirctiom
requirements.
Guidance for conducting Sampling Inspections will be integrated with CEI,
O&M, CDI and CME guidance for Follow-Up Evaluations will be part of CDI
guidance.
This document is a detailed exploration of the scope of and methods for.
conducting a Comprehensive Ground-Water Monitoring Evaluation (CME).
It is divided into two major parts, the text which explains in detail the scope
and methods, and a checklist for use by the person conducting the evaluation.
This document is supported by guidance on the other inspections/~valuations,
the RCRA Ground-Water Monitoring Technical Enforcement Guidance
Document, the RCRA Ground-Water Monitoring Compliance Order Guide,
and a health and safety manual. .
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Section One
Summary of Approach and Office Evaluation
The objective of a Comprehensive Ground-Water Monitoring Evaluation
(CME) is to determine whether an owner/operator has, in -place, a ground-
water monitoring system which is adequately designed, operated and
maintained to detect releases or to defme the rate and extent of contaminant
migration from a regulated unit (landfill, land treatment facility, or surface
impoundment) as required under 40 CFR Parts 265 and 270.
A CME involves extensiye office as well as field work and should be done by
- technical enforcement staff with the involvement of a professional experienced
in geology. The individual conducting the evaluation should have substantial
knowledge of hydrogeological site characterizations, the design and
construction of ground-water monitoring systems, ground-water sampling,
waste characteristics, solute transport, RCRA regulations and enforcement
authorities; and site history. The office component is performed largely by an
experienced hydrogeologist or geotechnical engineer who is part of technical
enforcement staff or available to it. A chemist would often be a valuable asset.
The field component requires the participation of the same level individual
assisted, if necessary, by a field inspector. The average level of effort for a
CME is fo~ (40) man days. A summary of the CME process follows:
The CME Process
Aili!i.U .
Pre-CME Planning
~
. technical enforcement staff
. professional experienced in
geology
. field inspector
CME office evaluation of
I .
. professional experienced in
system design hydrogeology
. technical enforcement staff
/
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The CME Process, Continued
A.Wri.U
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CME field evaluation of
. system operation/verification
of system design
CME report preparation
. professional experienced in
hydrogeology/engineering
. technical enforcement staff
. field inspector .
. experienced hydro geologist or
geotechnical engineer, and
chemist ( where necessary)
. technical enforcement staff
Review of CME report
. experienced hydrogeologist or
. geotechnical engineer, and
. chemist ( where necessary)
. field inspector
Follow-up inspection'
. technical enforcement staff
I . hydrogeologist
CMEs should focus on evaluating system design if system design is not
sufficiently known in order to assess its adequacy. Where design of the
system is already understood, the CME should evaluate system O&M
(operation and maintenance).more th,oroughly. The rationale for setting these
priorities is that until system design is adequately understood, little may be '
gained from a detailed scrutiny of system operation. Conversely, once an
adequate evaluation of system design has be~n completed, further examination
of statiC, site characteristics during subsequent CMEs becomes superfluous. .
It should be noted that re-evaluation of various site characteristics may be
necessary (e.g., seasonally influenced characteristics, new wells,. .
redevelopment of existing wells). Further, those conducting this evaluation.
should not hesitate to take samples when contamination is observed or .
suspected. The CME should be scheduled to coincide with a round of
sampling at the.facility in order to observe the implementation of the sampling
and analysis plan, and to facilitate the collection of split samples if deemed
necessary. EPA initiated samples may be taken at any time. A summary of
the activities of the office and field components of a CME process. follows:
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A. Office Evaluation
1. Technical evaluation of the site geological characterization includmg
geomorphology and structural 'geology, stratigraphy, petrology,
geochemistry beneath the site and any solid waste management
units (SWMU s) close enough to be of concern.
2. Technical evaluation of the site ground-water hydrological
characterization, including identification and description of the
uppermost aquifer, potentiometric surface, vertical and horizontal.
gradients, and hydraulic conductivity beneath the site and any
SWMU s close enough to be of concern.
3. Technical evaluation of the criteria for horizontal well placem.ent and
screen lengths of detection monitoring wells" up gradient and
downgradient.
4. Technical evaluation of the criteria for horizontal well placement and
screen lengths of assessment monitoring wells.
5. Technical evaluation of the criteria for drilling method and
monitoring well ~esign and construction.
6. Technical evaluation of the ~ssessment plan or outline.
7. Technical evaluation of the sampling and analysis plan.
To the extent possible, the enforcement official should use existing
infonnation to evaluate the design of the owner-operator's ground-water
monitoring system.
B. Field Evaluation
1. Technical evaluation of the implementation of the sampling and
analysis plan.
2. Field verification of the number, locations and screen depths of .
ground-water monitoring wells and peizometers, and water levels
(where deemed necessary).
3. Possible collection of samples for analysis by a contract laboratory or
EP NState laboratory to assist in the verification of analytical
precision and methodology of facility procedures. Sampl~s may
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either be owner-operator splits if the Agency approves of the
sampling procedure, or EP A-collected.
4. Possible implementation of confirmatory geophysical methods to
verify facility assessment of hydrogeology or contaminant
distribution.
C. Information Sources
ACME peilIlits the determination of the adequacy of ground-water
monitoring systems through a detailed technical appraisal of site
hydrogeology, morn to ring well placement, monitoring well design and
construction, sampling and analysis plan, data presentation, and, where
. appropriate, assessment plan.
The detailed technical evaluation of system design should be initiated by
locating the source(s) of information pertinent to the facility to be
inspected. Sources of information include, but are not limited to:
1. U.S. EP A Regional Offices;
2. State regulatory agencies;
3. U.S. Geological Survey (hydrogeologic information);
4. State geological surveys, state conservationist county soil surveys;
5. Owner-operator files; .
6. Academic institutions;
7. State water surveys; and
8. Aerial photographs.
The following documents are valuable sources of information which
. contain the following pertinent information:
1. Part A of the RCRA Permit Application:
a. A list of activities conducted by the applicant which require a RCRA
permit.
b. Primary Standard Industrial Codes (SIC) which best reflect the
. principal products handled or services provided by the facility.
c. A description of the processes used for treating, storing, and
disposing of hazardous waste. . .
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d. Specification of the hazardous wastes designated under 40 CFR Part
261 to be treated, stored, or disposed of at the facility, and an
estimate of the quantity and delivery timing of such wastes.
2. Part B of the RCRA Pennit Application:
a. A general description of the facility.
b. Chemical and physical 'analyses of the hazardous wastes
handled at the facility.
c. A copy of the waste analysis plan.
,d. A, copy of the general inspection sched~e.
e. A topographic map (scale: 1" = 200'). .
f. Aerial photographs. . , .
g. Geologic and hydrogeologic characterization infonnation.
h. Description of the ground-water monitoring system.
i. Sampling and analysis plan.
j. Ground-Water Quality Assessment Plan Outline.
k. Monitoring well construction details. ' .
1. Information about nearby ground-water and surface water usage.
Parts A apd B'ofthe RCRA permit application should be available at
sources 1, 2, and 5. . "
3. Contractor geotechnical reports:
a. Description of waste handling procedures.
b. Geologic and hydrogeologic data (site-specific and regional).
c. Description of ground-water monitoring system.
d. Facility layout.
e. Monitoring well construction details.
f. 'Results of geophysical tests.
g. Recommendations to facility operator.
Contractor reports may be available at source numbers 1,2, and 5.
4. Regional geologic, soil, and/or ground-water reports.
a~ Regional geologic infonnation.
b. Regional soil maps. .
c. Regional hydrogeologic data. ,
d. Information on ground-water usage.
e. Geochemical data.
f. Climatic data, precipitation, evapo-transpiration.
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5. Inspection reports, O&Mreports, findings, or other records of
correspondence related to the facility's compliance status.
a. . Records of past violations.
b. Copjes of complaints, administrative orders or case referral
packages. . . '
c. HWDMS reports (compliance monitoring and enforcement log).
d. Correspondence. ' ,
Reports may be available at source numbers 1 and 2.
6. Sampling and Analysis Plan.
a. Sample collection procedures including measurement of static water
level evaluation, detection of immiscible layers, well evacuation,
sample withdrawal, and in situ or field analyses.
b. Sample preservation and handling procedures including sample
containment, preservation, and special handling considerations. '
c. Chain-of-custody procedures including description of sample labels
and seals, field logbook layout, descriptions of chain-of-custody
record, sample analysis request sheet and laboratory logbook.
d. Analytical procedures, and detection limits.
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e. Field and laboratory quality assurance/quality control.
f. Evaluation of the quality of ground-water data, including reporting of
low and zero concentration values, significant digits, missing data
values, outliners and units of measure. ' .
Note: The Sampling and Analysis Plan should be kept at the facility and
therefore available to the inspector upon request.
7. Ground-Water Quality, Assessment Plan
a. A description of the detection monitoring system.
b. Discussion of hydrogeologic conditions at the facility.
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c. Sampling and analytical methods for those hazardous wastes or
hazardous waste constituents previously detected at the facility.
d. A description of the evaluation procedures, including the use of
previously gathered ground-water quality data, the owner/operator
will use to make the fIrst determination.
e. Description of the approach the owner/operator will use to fully
characterize rate and extent of contamination migration (e.g.,.test
borings, mathematical modeling).
f. Discussion of the number, location, and depth of monitoring wells
the owner/operator will install to define the contaminant migration (in
order to defme horizontal and vertical dimensions of the contaminant
plume).
g. A description of monitoring well construction techniques.
h. A schedule of implementation of all phases of the assessment
program. .
Assessment plans should be ~vailable at source numbers 1 and 2.
, Assessment plan outlines should be kept at the facility.
When performing the field evaluation, the enforcement official(s) will
attempt to fill data gaps with observations.
D. Elements of Office Evaluation of System Design
1. The enforcement official should review the owner/operator's
characterization of site hydrogeology and make a determination
whether or not the owner/operator has collected enough 'information
on which to base. the design of a monitoring program.
a. Boring and well logs.
b. Geotechnical laboratory test results (e.g., permeability,
geochemical composites).
c. Contractor geotechnical reports.
d. Results of geophysical tests.
e. Static water level data.
f. In situ permeability tests (horizontal).
g. In situ permeability tests (vertical).
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E. Conclusions that should be reached from the technical office
evaluation are: .
1. . Is the site hydrogeological characterization adequately detailed
to identify preferential contaminant migration pathways?
2.
Are the horizontal placement, screen lengths and depths of
detection monitoring wells theoretically adequate to
immediately detect the release of hazardous waste constituents
from the regulated unit, and hazard constituents from regulated
units subject to ~270.14(c)(iv)?
3.
Are the horizontal placement and screen lengths of a~sessment
monitoring wells theoretically adequate to detennine the rate
and extent of migration and chemical composition of any .
contaminantplurnes?
Can the detection monitoring system theoretically differentiate .
nearby SWMU releases from regulated unit releases?
4.
5.
Are the design and construction criteria for detection ground-
water monitoring wells sufficient to provide long-tenn,
unbiased samples of ground-water?
6.
Are the design and construction criteria for assessment
monitoring wells theoretically adequate to characterize releases
of hazardous waste constituents in the case of a regulated unit
subject to ~270.14(c)(iv)?
7.
Is the sampling and analysis plan theoretically adequate to
provide accurate and precise ground-water quality data?
8.
Are ground-water quality data presented in a manner that
. pennits an assessment of their significance?
9.
Is the statistical method used consistent with the regulatory
requirement? .
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10. Is the assessment plan or outline theoretically adequate to
permit determination of the chemical composition, and rate and
extent of migration of a release from the regulated unit(s), and
to differentiate that contamination from any originating from
SWMUs?
. * Where it is not possible to differentiate i.e., where SWMUs and
regulated units are very close together, any releases would be
addressed under 265 assessment monitoring or an analogens
requirements under a 3008(h) order.
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. Section. Two
Field Evaluation and Verification Preparation
Prior to performing the field evaluation component, it is necessary for the
evaluation team to complete a number of preliminary tasks. These tasks
include:
1. Development of .a site'safety plan for the field evaluation. Prior to
arriving at the facility, the field evaluation team personnel should
have determined the level of protection, decontamination
procedures, and other safety precautions necessary.
.2. All evaluation team personnel should have credentials or
identification that describe their Federal or State agency affiliation.
, .
3. The following equipment is recommended to conduct the fiefd
. evaluation:
. Bound field notebook;
. Camera;
. Pocket calculator;
.. Watch with sweep second hand (or stop watch);
. Compass; .
, . Weighted tape measure and water indicator (made of inert
material), or electronic interface probe to measure static water
levels and total depth of monitoring wells and detect immiscible.
layers; . '
. Deionized water, hexane (or laboratory strength cleaner), and
sterile, disposable paper towels or gauze for decontamination of
tape measure or probe;
. Sampling equipment, e.g., bailer (made of inert material),
monofilament line, properly cleaned;
. All appropriate.forms, e.g., chain-of-custody; and
. Safety equipment.
4. Determmation of whether or not samples will be collected. After the
technical evaluation of the ground-water monitoring system is
completed, the utility of extensive sampling by the evaluating team
can be ascertained. '. .
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Samples should be taken when contamination is observed or
. suspected. The team should develop a project plan prior to entry
and may use the facility's sampling equipment if i~ is found to be
adequate. Inspection personnel should do appropriate field analyses
(pH, specific conductance, temperature) with their own portable
field equipment to verify results of facility d~terminations. The
samples will be analyzed to assess the operation of the monitoring
system and! analytical procedures utilized by the facility.
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Section Three
Field Evaluation and Verification Activities
The following elements of the ground-water monitoring system design should
be verified in the field:
. location of regulated units,
. number and location of monitoring wells or clusters; .
. spacing of monitoring wells or clusters;
. static water level measurements (where deemed necessary);
. well elevators, 'physical condition, labeling (where deemed
necessary).
The following elements of the ground-water monitoring system design and
operation should be verified and evaluated:
. determination of the presence, where appropriate, of light and dense
phase immiscible layers (where deemed necessary); .
. sample collection, preservation, and handling procedures,
implementation of the sampling and analysis plan;
. determination of total well depths; .
. surface well construction;
. general site conditions; and
. . sketch design.
The office evaluation component identifies deficiencies in the design of
ground-water monitoring systems, either detection or assessment. The {ield
evaluation and verification component of a.CME serves a dual purpose. It
first identifies discrepancies between system design as presented and
constructed. Second, the field component of the CME is an ev~uation of
system operation and an opportunity to collect data neCessary to draw
conclusions about the adequacy of the ground-water monitoring program
(detection of assessment), e.g., a reassessment of site hydrogeological
characterization using direct and/or indirect techniques. The following are key
considerations in conducting the field evaluation. .
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A.
During the evaluation, the evaluation team should verify that the total
number of wells. that are described in the assessment plan outline or plan
are found in the field, and that all wells are adequately maintained.
Approximate locations of each well should be field checked against those
presented on site maps in the owner/operator's Part B pennit application.
To accomplish this, the distance betWeen wells and other features may be
accurately measured using a surveyor's chain, .while other measurements
may be approximated either by pacing or visual inspection in the case of
closely-spaced wells. (Note any scale on the o.wner/operator's site map, if
applicable, and measure using ail engineer's scale). .
Facilities under detection monitoring must have a sufficient number of
wells to identify the presence of a release of contaminants from the
hazardous waste management area. Up gradient wells should be positioned
so that they are not affected by the facility's operations and provide.
background ground-water quality data. Areas of low or variable hydraulic
gradient and/or upgradient sources of contamination are common in.parts
of the country and c~ pose problems in establishing the up gradient quality
of ground-water. In those situations, the emphasis of the field work
shoUld be detennining whether a release has occurred. Downgradient
wells must be located along the edge of the waste management area so that.
the owner/operator can immediately detect leakage (refer to TEGD for
detail). Other wells located within the facility boundaries should be
identified ,on a facility map.
B.
A facility in assessment monitoring will have additional well clusters
located downgradient from the waste unit or along contaminant migration
pathways that vary from ground-water flow direction to defme the .
contaminant concentrations and plume configuration. Each well cluster
may have several wells,each screened at various intervals to provide
vertical extent of migration.
The evaluation team should verify the locations and vertical sampling
intervals of assessment wells or clusters.
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c.
The inspector should detennine, for each well, the depth to standing water.
Measurements are taken from reference point on well casing down to the
static water level. Measurements must be accurate to + 0.01 foot. It is .
recommended that levels be recorded using electronic sounding devices of
M-scope, otherwise a stainless steel (or other inert material) measuring tape
with a weighted end may be used. The tape is coated for the last foot with
a water indicator and lowered into the water a few tenths of a foot and the
nearest 0.01 foot at the measuring-point recorded. The depth to water is
obtained by subtracting the wetted length from the nearest foot reading at
the measuring point. .
Measurements are generally recorded in hundredths of feet. To convert
from inches to feet:
inches x 0.0833 = feet
Should the owner/operator's Sampling and Analysis Plan, waste analysis
or historical data indicate thepresenee of light or dense phase immiscible
layers, an interface probe should be, used to register the top of the organic
layer, and establish the thickness of the immiscible layer overlying the
organic/water interface. Dense phase immiscible layers can be measured
by lowering the interface probe to the bottom of the well where the probe
registers and location of an organic/water interface.
Note: Engineering chain tapes are usually graduated to the nearest 0.01
foot for the flfStfoot only. .
D.
Sample collection should be divided into three phases:
1. sampling of light/dense phase immiscibles (where necessary),
2. well evacuation, and .
3. sample withdrawal.
Depending on the waste characteristics, the owner/operator's Sampling and .
Analysis Plan may not have provisions for sampling of light/dense phase
immiscibles. Where light and/or dense phase immiscibles are present, the
owner/operator must obtain discrete samples of them. The well should be
designed to capture light phase immiscibles "floating" at the specific
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screened intervals, and to collect "sinkers" within dense phase sampling
cups at the bottom of the well.
. Sampling of Dense Phase Immiscibles (May not be applicable to the
facility)
Sampling for light immiscible fractions must precede well evacuation. A
bottom filling fluorocarbon resin or stainless steel 316, 304 or 2205 bailer
should be lowered to the predetermined levels for collection. Care must be
taken to avoid actions which may disturb the interface between the organic
and aqueous phases. Plastic sheets should be laid out next to the well to
protect from surface contaminants when the bailer is being assembled.
. Sampling of Dense Phase hnmiscibles (May not be applicable to the .
facility) . .
[
,
i .
[
Collection of dense phase irnmiscibles should be done before well
evacuation. Either a clean positive gas displacement bladder pump or
bottom filling fluorocarbon resin or stainless steel 316, 304 or 2205 bailer
is lowered gently to collect a discrete sample from the bottom dense phase
sampling cup. Any motions that agitate the standing water should be .
restricted. Pumping rates should be kept to 100 m1/min or less to avoid
turbulence. .. .. .
. Well.Evacuation
The owner/operator must remove standing water from the well and filter
pack to obtain a representative formation sample. Important points to
consider during evacuation are: . .
1. All well evacuation materials entering the well should be composed
. of inert refractory materials (i.e., fluorocarbon resins or stainless
steel 316, 304, or 2205).
2. Note the type of purging equipment used. Peristaltic pumps, gas
lift pumps, centrifugal, pumps and venturi pumps may increase
volatilization and cause high pressure differentials that can result in
fluctuations in many analytical parameters, but are acceptable for
purging provided that sufficient time be allowed for water to
stabilize prior to sampling. .. .
3. Nondedicated sampling equipment must be thoroughly
decontaminated, cleaned, and rinsed between wells. This is
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especially important where interface probes are used to detect
viscous organics. .
4. Sampling personnel should wear clean gloves during all purging
and sampling activities.
5. Discharge rate should be accurately measured.
6. LOw yielding wells should be evacuated to practical dryness (some
water may remain below the pump intake or from discharge lines
not equipped with check valves). .
7. High yielding wells should have a minimum of three casing
volumes removed prior to sampling or that quantity sufficient to
remove stagnant water from the well and filter pack.
8. Wells should be protected from surface contaminants entering
during evacuation and sampling. .
9. The following table may be helpful in determining the volume of
water contained in a one-foot casing section:
...1P (incnes)
0.50
0.75
1.00
1.50
2.00
3.00
4.00
6.00
8.00
10.00 .
Gallons
0.01
0.02
0.04
0.09
0.16
0.37
0.65
1.47
2.61
4.08
Metric
37.8 ml
75.8ml
15.5 cl
34.09 cl
60.61 cl
1.40 liter
2.46 liter
5..56 liter
9.89 liter
15.45 liter
10. All ground-water evacuated from a well which is suspected of .
being hazardous should be properly managed. To obtain the total
volume of water contained in the well, simply multiply by the
height (in feet) of the water column. It may be necessary to verify
the diameter of the well casing.
( ~~AU~. ) ~ ~~(~:~'~l \ .~~
~ ~~~, I'.~~ ~,=\'Z.) . ~t~~u.o~t
~It~t.~l
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E.
, '
The inspector should look for any sampling technique that may
result in the procurement of a contaminated or otherwise altered
sample. The following points should be kept in mind during
sampling: ' ,
, '
1. Sampling devices should be composed of fluorocarbon resins or
stainless 304, 316 or 2205.
. '
2. Where dedicated pumps are not used, pump equipment and probes
must be thoroughly cleaned between wells. Equipment should first
be wiped to remove excess contaminants and to improve cleaning
efficiency. Subsequent cleaning procedures should entail:
When Inorganic Constituents are Suspected:
O.IN HCL or HN03 rinse
Distilled or deionized water rinse
When Organic Constituents are Suspected:
-Nonphosphate detergent wash
-Tap water rinse
-Distilled water rinse
I
-Acetone ~e \ ~A: )lwt-~ll~
-Hexane nnse '-'\ '~\ ~ '1~
, -:-Adequate drying time. l ~~ Q131RS-:::" Op
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9950.2
6. Sampling equipment (especially bailers) should never be dropped
into the well as this will cause degassing of the water on impact.
7. The bailer's contents should be transferred to a suitable sample
container in a way that will minimize agitation and aeration. *
* Filling the VOA containers from the bottom of the bailer causes le~s
turbulence than pouring its contents from the top. It is .
. recommended, therefore, to fill the containers from the bottom of the
bailer whenever possible.
8. Samples should not be composited in one large container and later
transferred to others.
9. Clean sampling equipment should' not be placed directly on the
ground or other contaminated surfaces prior to insertion into wells.
10. Sampling in low yielding wells should be performed as soon as
there is enough water present to collect the sample.
11. Volatile.parameters should be collected fIrSt.
12. Probes used for in-situ analyses should not be inserted into sample
containers. '
F.
Physically and chemiCally labile parameters must be tested either in the
borehole using a probe (in-situ) or immediately upon withdrawal using a
field test kit.
1. Analyses must be performed both after well evacuation and sample
collection. .
2. Field instruments should be calibrated according to manufacturer's
specifications and be consistent with SW -846 (Test Methods for
Evaluating Solid Waste-PhysicaVChemical Methods).
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G.
Samples must be contained and preserved by approved methods to
maintain the integrity of the sample. Improper preservation and handling,
may alter parameter levels in the sample. Key points to note during the
inspection include: "
1. Procured samples should be transferred directly into the container
specifically prepared for that given parameter or set of compatible
parameters, (e.g., dissolved metals). Samples should not be '
composited into a common container to be subsequently split in the
laboratory.' ,
2. Samples should be collected in a manner that minimizes turbulence'
and agitation.
3. Volatile Organics Analysis (YOA) vial should be poured so that it
oyerflows leaving no headspace or'bubbles in the vial. Its cap
should be lined with a fluorocarbon resin.
4. Samples for metals analysis can be collected in polyethylene
containers with polypropylene caps, or in glass bottles with
, fluorocarbon resin lined caps. '
5. Samples for organic analysis should be collected in glass bottles with
fluorocarbon resin.
H.
Orianics
1. Samples must not be filtered.
2. Samples must not be transferred from one container to another.
~
1. Samples collected for metals analysis should be split into two
samples. One portion filtered through a 0.45 u filter for'
dissQlved metals and the second portion remaining unfiltered for
total metals analysis. Samples should be filtered as soon as
possible to minimize the impacts of pH and Eh changes.
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9950.2
2. Both samples should be preserved with nitric acid to pH <2.
The recommended procedures for sampling and preservation are
presented in Table 1.
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Table 1.
Sampling and Preservation Procedures for Detection Monitoring
Recommended Maximum Minimum Volume
Parameter Containe"" . Preservative Holding Time. Required for Analysis
Indicators of Ground-Water Contamination"
pH T,P,G Field Detemrinabon None 25rnl
Specific Conductance T,P,G Field Detemrinabon None lOOrnl
TOe G, teflon-lined cap Cool 4°C, HCI to pH <2 28 days 4 x 15m1
TOX G, amba', Teflon- Cool 4°C, add Imiofl.lM 7 days 4 x 15rnl
lined cap sodimn sulfite
Ground-Water Duality Characteristics
Chloride T,P,G. 40C 28 days 50m1
Iron T,P Field Acidfied to pH <2 6 months 200rnl
Maganese with UNO,
Sodium
Phenols G 4OC~S04 to pH <2 28 days 500rnl .
Sulfate T,P,G CooL. 4°C 28 days 50m1
EPA Interim Drinkin~ Water Charactertistics
Arsenic T,P Totals Metals 6 months l,OOOmI
Barimn Field acidfied to pH <2 with
Cadmium UNO,
Chromimn 6 months l,OOOmI
Lead Dissolved Metals
Mercury . 1. Field f1Itration (0.45 micron)
Selenimn
Silver Dark Bottle 2. Acidify to pH <2 with UNO,
FIomide T,P Field Acified to pH <2 with UNO, 28 days 300m1
Nitrate T;P,G 4°ClHzSO 4 to pH <2 14 days I,OOOmI
-------
Table 1, Continued.
Sam piing and Preservation Procedures for Detection Monitoring
Endrin
Lindane
Methoxychlor
ToXaphene
2,4,D
- 2,4,5 TP Silvex
T,G
Cool, 4°C
7 days
Minimum Volume
Required for Analysis
2,000m1
Parameter
Recommended
Container" .
Preservative
Maximum
Holding Time
Radium
Gross Alpha
Gross Beta
Colifonn Bacteria
P,G
Field acified to pH <2 with HN03
6 months
1 gallon
Volatiles
Other Ground-Water Characteristics of Interest
P,G Cool, 40C, NaOH to pH >12 14 days 500ml
G only Cool, 4°C, 1\504 to pH <2 28 days lOOml
T,G Cool, 4°C 14 days 60ml
G. T -lined Cool, 4°C 14 days 60ml
Cyanide
Oil and Grease
Sernivolati1e,
NonvoJatiJe organics
"References:
Test Methodsfo, EvallUJling Solid Waste-PhysicallChemical Methods, SW-846.2nd Edition, 1982.
Me/hods fo, Chemical AMlysis of Wille, and Wastes, EPA-600/4-79-020.
Standard Mel!wds fo, the Exilminotion of Wille, and Wastewaler, 16th edition, 1985.
"Container Types:
P = Plastic (polyethylene)
G = Glass
T = Teflon
PP = Polypropylene
eBased on the requirementS for detection monitoring G265.93). the owner/operator must collect a sufficient volwne of gr01md-water to allow for the analysis of four
separate rep1icaIioos. . .
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9950.2 '
I.
To ensure the reliability of field-generated data, the owner/operator's
Sampling. and Analysis Plan should incorporate the use of trip and
equipment blanks during sampling to verify that sample collection and
handling processes have not affected the quality of the field samples. Field
verification of quality control procedures will include:
1. The use of trip and equipment blanks.
-Trip blanks: Used to determine if contamination wa's introduced
from the sample containers through normal handling. .
-Equipment blanks: Used to detennine if contamination may be a
, result of improper cleaning. .
2. Calibration of monitoring and sampling equipment.
3. Proper decontamination and cleaning of nondedicated equipment.
J.
Field verification of the owner/operator's chain-of-custody procedures will
contain the following elements: .
1. Sample labels for proper identification.
2. Sample seals to ensure integrity of the collected .samples until they
are reopened. .
3. Field logbook to record ground-water monitoring program
llUonnation. . .
4. Chain-of-custody record to track sample possession.
K.~
Ideally, sample labels should contain the following information:
1. Sample identification number (mandatory).
2. Name of collector.
3. Date and time of collection.
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9950.2
, 4. Monitoring well.
5. Parameter(s) requested.
L. Sample Seab
Seals may be important in the event that samples leave the
owner/operator's immediate control through shipment to laboratory. Seals
thus provide assurance that samples have not been disturbed or tampered
with.
M.~
An owner/operator or the individual designated to perform ground-water
monitoring operations should keep an up-to-date field logbook which
documents the following:
1. Identification of well
2. Well depth'
3. Static water level depth and measurement technique
4. Presence of immiscible layers. and detection method
5 . Well yield-high or low.
6. Collection method for immiscible layers and sample
identification numbers '
7. Well evacuation procedure/equipment
8. Sample withdrawal procedure/equipment
9. Date and time of collection '
10. Well sampling sequence
11. Types of sample containers used and sample identification
numbers
12. Preservative(s) used
13. Parameters requested for analysis
14. Field analysis data and method(s)
15. Sample distribution and transporter
16. 'Field observations on sampling ,event
17. Name of collector '
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9950.2
N.
To establish the documentation necessary to trace sample possession from
. time of collection, a chain-of-custody record should be filled out and
accompany every sample. The record should contam the following type of
unormarion: . .
1. Sample number
2. Signature of collector .
3. Date and time of collection
4. Sample type (e.g., ground-water, immiscible layer)
5. Identification of well
6. Number of containers
7. Parameters requested for analysis
8. Signature of person(s) involved in the chain of possession
9. Inclusive date of possession
10. Total Well Depth
During well evacuation and/or purging, the total well depth should be
verified for each well in the monitoring system. It is recommended that the .
use of sounding devices or weighted stainless steel measuring tape be used
in the event the well cannot be pumped or bailed to dryness. Measurements
are taken from the top of the well casing and should be acc~rate to + 0.01
foot. .
P.
n
Visual inspection of surficial well construction and condition
will aid in determining the adequacy of the owner/operator
ground-water monitoring system design. Important considerations
include:
1. Wells adequately maintained (not overgrown by vegetation or
impaired by neglect or misuse), and properly labeled'. .
2. Wells protected and secured with steel protective cap and lock
3. Wells sealed properly at surface to prevent surface
contaminants from entering the. well
4. Casing material -
5. Top of casing elevation
6. Turbidity of collected samples
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9950.2
While in the field it is important to record as many obselVations as
'possible. Site characteristics should include:
1. Topographic relief-Lay of the land, slopes, etc.
2. Water Bodies-Direction and distance to streams, rivers,
ponds,lakes, estuaries, ocean, etc.
3. Surface Features-Soil type, rock outcrops, leachate surface
seeps, dominant vegetation types, if applicable. .
4. Man-Made Features (particularly ones affectmg
hydrogeology~ Nearby industrial wells, drainage ditches,
underground conduits and drains, impoundments, also note
area water supply sources.
R.~
A map of the site should be available to the inspector from the Part B
permit application materials. If a copy of the site map is not available at the
. time of the field inspection, the inspector should sketch the facility. The
sketch should include:
1. Location of regulated units
2. Location of wells
3. Location of major buildings and important surface features
4. Drainage pattern and ground-water flow direction'
5. Location of drains and seepage areas .
6. North arrow and rough scale
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9950.2
Section Four
Sampling and Analysis
When .the owner/operator's ground-water monitoring system design .
has been detennined to be satisfactory, subsequent CMEs focu,s on system
operation and, therefore, may involve sampling and analysis of ground-water
samples collected at the facility. If the owner/operator sample preparation
procedures are deemed inconsistent with EPA-approved methods, the
inspector should request that the owner/operator sample according' .
to recommended procedures described in Section 3.2.3 in addition to the
methods employed by the owner/operator, with the sample results. analyzed
and compared. Additionally, the inspector should send a duplicate (split)
sample, collected and prepared using EP A-approved methods, to the
enforcement authority's laboratory for analysis. .
Section Five
Conclusions and Recommendations
tI Has the owner/operator adequately characterized site hydrogeology?
tI Is the detection monitoring system adequately designed and
constructed to imnlediately detect any contaminant release from the
regulated unit(s) and differentiate where possible, such releases
from nearby SWMU releases? .
tI Are the procedures used to make a first detennination of
contamination adequate?
tI Is the operation of the ground-water monitoring system adequate to
pennit immediate de~ction of a release of contaminants from
~azardous waste management areas? . .
. tI Do the assessment monitoring wells, given site
hydrogeologic conditions, define the extent and concentration of
contamination in the horizontal and vertical planes? .
tI Ate the assessment monitoring wells adequately designed and
constructed? .
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t/' Are the sampling and analysis procedures adequate to provide
representative samples of ground-water in the uppennost aquifer?
t/ Do the procedures used for evaluation of assessment monitoring
data result in detenninationS of the rate of migration, extent of
migration, and hazardous waste constituent composition of the
contaminant plume?
t/ Are the data collected at sufficient duration and frequency to
adequately determine the rate of migration?
t/ Is the schedule of implementation adequate?
t/ Is the owner/operator's assessment monitoring plan adequate?
t/ If the owner/operator had to implement his assessment monitoring
plan~ was it implemented satisfactorily?
Based on the results of the evaluation, deficiencies in network design,
infonnation gaps, and operational inadequacies can be clearly identified and
listed. In order to assist the various enforcement authorities involved in
bringing the facility into compliance, the deficiencies may be categorized into
major'ot: minor areas of noncompliance. Major deficiencies would involve
shortcomings in network design or gross inadequacies in sampling and/or
analysis that would seriously impair detection or assessment monitoring
functions. Minor deficiencies, though important, may not necessitate case
development, but rather issuance of deficiency notices to bring about desired
changes.
Based on conclusions gained from the CME, the evaluation team members
should clearly defme the recommendations. These recommendations will thus
provide appropriate guidance toward obtaining more infonnation that may be
required for administrative or judicial action.
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I .
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APPENDIX A
. . .
Comprehensive Ground-Water
Monitoring Evaluation Worksheet
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, 9950.2
l~ ")PENDIX A
COMPREHENSIVE GROUND-WATER MONITORING
EVALUATION WORKSHEET
The following worksheets have been designed to assist the enforcement officer/
technical reviewer in evaluating theground-water monitoring system an owner/operator
uses to collect and analyze samples of ground water. The focus of the worksheets is
technical adequacy as it relates to obtaining and analyzing representative samples of
ground water. The basis of the worksheets is the final RCRA Ground . Water Monitoring
Technical Enforcement Guidance Document which describes in detail the aspects of
ground-water monitoring which EPA deems essential to meet the goals of RCRA.
Appendix A is not a regulatory checklist. Specific technical deficiencies in the
monitoring system can, however, be related to the ,regulations as illustrated in Figure 4.3
taken from the RCRA Ground-Water Monitoring Compliance Order Guide (COG)
(included at the end of the appendix). The enforcement officer, in developing an
enforcement order, should relate the technical assessment from the worksheets to the
regulations using Figure 4.3 from the COG as a guide.
Comprehensive Ground-Water Monitoring Evaluation Y/N
I. Office Evaluation Technical Evaluation of the Design of the
Ground-Water Monitoring System
A. Review of Relevant Documents
. 1. What documents were obtained prior to conducting the inspection:
a. RCRA Part A pennit application?
b. RCRA Part B pennit application?
c. Correspondence between the owner/operator and appropriate agencies or
citizen's groups?
d. Previously conducted facility inspection reports?
e. Facility's contractor reports?
f. Regional hydrogeologic, geologic, or soil reports?
g. The facility's Sampling and Analysis Plan?
h. Ground-water Assessment Program Outline (or Plan, if thefacility is in
assessment monitoring)?
i. Other (specify)
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Y/N
B. Evaluation of the Owner/Operator's Hydrogeologic Assessment
1. Did the owner/operator use the following direct techniques in the hydrogeologic
assessment:
a. Logs of the soil borings/rock corings (documented by a professional geologist,
soil :ientist, or geotechnical engineer)?
b. Materials tests (e.g., grain size analyses, standard penetration tests, etc.)?
c. Piezometer installation for water level measurments at different depths?d. Slug
tests?
e. Pump tests?
,1. Geochemical analyses of soil samples?
g. Other ~specify) (e.g., hydrochemical diagrams and wash analysis)
2. Did the owner/operator use the following indirect technique to supplement direct
techniques data:
a. Geophysical well logs?
b. Tracer studies?
c. Resistivity and/or electromagnetic conductance?
d. Seismic Survey?
e. Hydraulic conductivity measurements of cores?
f. Aerial photography?
g. Ground penetrating radar?
h. Other (specify)
3. Did the owner/operator document and present the raw data from the site
hydrogeologic assessment?
4. Did the owner/operator document methods (criteria) used to correlate and analyze
the information?
5. The owner/operator prepare the following:
a. Narrative description of geology?
b. Geologic cross sections?
c. Geologic and soil maps?
d. Boring/coring logs?
e. Structure contour maps of the differing water bearing zones and confining layer?
f. Narrative description and calculation of ground-water flows?
\
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Y/N
g. Water table/potentiometric map?
h. Hydrologic cross sections?
6. Did the owner/operator obtain a regional map of the area and delineate the facility?
If yes, does this map illustrate:
a. Surficial geology features?
b. Streams, rivers, lakes, or wetlands near the facility?
c. Discharging or recharging wells near the facility?
7. Did the owner/operator obtain a regional hydrogeologic map?
If yes, does this hydrogeologic map indicate:
a. Major areas of recharge/discharge?
b. Regional ground-water flow direction?
c. PotentIometric contours which are consIstent WIth observed water level
elevations?
8. Did the owner/operator prepare a facility site map?
If yes, does the site map show:
a. Regulated units of the facility (e.g., landfill areas,impoundments)?
b. Any seeps, springs, streams, ponds, or wetlands?
c. Loca.ion of monitoring wells, soil borings, or test pits?
d. How many regulated units does the facility have?
If more than one regulated umt then,
. Does the waste management area encompass all regulated units?
Is a waste management area delineated for each regulated unit?
C. Characterization of Subsurface Geology of Sit~
1. 'Soil boring/test pit program:
a. Were the soil borings/test pits performed under thesupervision of a qualified
professional?
b. Did the owner/operator provide documentation for selecting the spacing for
borings?
c. Were the borings drilled to the depth of the first confining unit below the
uppermost zone of saturation or ten feet into bedrock?
d. Indicate the method(s) of drilling:
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Y/N
, Auger (hollow or solid stem) -
Mud rotary
Reverse rotary .
Cable tool
Jetting -
Other (specify)
e. Were continuous sample corings taken?
f. How were the samples obtained (checked method[sD
. Split spoon -
. Shelby tube, or similar -
. Rock coring -
. Ditch sampling -
. Other (explain)
g. Were the continuous sample corings logged by a qualified professional in ,
geology?
h. Does the field bonng log Ihclude the fol~owmg information:
. Hole name/number?
. Date started and finished?
. Driller's name?
. Hole location (Le., map and elevation)? I
. Drill rig type and bit/auger size?
. Gross petrography (e.g., rock type) of each geologic unit?
. Gross mineralogy of each geologic unit?
. Gross structural interpretation of each geologic unit and structural features
(e.g., fractures, gOQge material, solution channels, buried streams or valleys,
identification of depositional material)?
. Development of soil zones and vertical extent and description of soil type?
. Depth of water bearing unit(s) and vertical extent of each?
. Depth and reason for termination of borehole? ,
. Depth and location of any contaminant encountered in borehole?
. Sample location/number?
. Percent sample recovery?
. Narrative descriptions of:
-Geologic observations?
-Drilling observations?
L Were the following analytical tests performedon the core samples:
. Mineralogy (e.g., microscopic tests and x-ray diffraction)?
. Petrographic analysis:
-degree of crystallinity and cementation of matrix?
-degree of sorting, size fraction (Le., sieving), textural variations?
-rock type(s)?
,
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, Y/N
-soil type?
-approximate bulk geochemistry?
-existence of microstructures; that may effect or indicate fluid flOW?
Falling head tests?
. Static head tests?
. Settling measurements?
. Centrifuge tests? .
~ Column drawings7
D. Verification of Subsurface Geological Data
1. Has the owner/operator used indirect geophysical methods to supplement geological
conditions between borehole locations?
2. Do the number of borings and analytical data indicate that the confining layer
displays a low enough permeability to impede the migration of contaminants to any
stratigraphically low water-bearing units?
3. Is the confining layer laterally continuous across the entire site?
4. Did the owner/operator consider the chemical compatibility of the site-specific
waste types and the geologic materials of the confining layer?
5. Did the geologic assessment address or provide means for resolution of any
information gaps of geologic data?
6. Do the laboratory data corroborate the field data for petrography?
7. Do the laboratory data corroborate the field data for mineralogy and subsurface -
geochemistry?
E. Presentation of Geologic Data
1. Did the owner/operator present geologic cross sections of the site?
2. :Do cross sections:
a. identify the types and characteristics of the geologic materials present?
b. define the contact zones between different geologic materials?
c. note the zones of high permeability or fracture?
d. give detailed borehole information including:
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Y/N
. location of borehole? '
. depth of tennination?
. location of screen (if applicable)?
. depth of zone(s) of saturation?
. bacld:l11 procedure'!
3. Did the owner/operator provide a topographic map which was constructed by a
licensed surveyor?
4. Does the topographic map provide:
a. contours at a maximum interval of two-feet? '.
b. locations and illustrations of man-made features (e.g., parking lots, factory
buildings, drainage ditches, storm drain, pipelines, etc.)? .
c. descriptions of nearby water bodies?
d. descriptions of off-site wells?
e. site boundaries?
f. individual RCRA units?
g. delineation of the waste management area(s)?
h. well and boring locations?
5. Did the owner/operator provide an aerial photograph depicting the site and adjacent
off-site features?
6. Does the photograph clearly show surface water bodies, adjacent municipalities, and
residences and are these clearly labelled?
F. Identification of Ground-Water Flowpaths
1. Ground-water flow direction
a. Was the well casing height measured by a licensed surveyor to the nearest 0.01
. .
feet? I
b. Were the well water level measurements taken within a 24 hour period?
c. Were the well water level measurements taken tQ the nearest 0.01 feet?
d. Were the well water levels allowed to stabilize after construction and
development for a minimum of 24 hours prior to measurements?
e. Was the water level information obtained from (check appropriate one):
. multiple piezometers placed in single borehOle?
vertically nested piezometers in closely spaced separate
. boreholes?
. monitoring wells?
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V/N
f. Did the owner/operator provide construction details for the piezometers?
g. How were the static water levels measured (check method[sD.
. Electric water sounder
. Wetted tape
. Air line
. Other (explain)
h. Was the well water level measured in wells with equivalent screene~ intervals at
an equivalent depth below the saturated zone?
i. Has the owner/operator provided a site water table (potentiometric) contour map?
If yes,
. Do the potentiometric contours appear logical and accurate based on
topography and presented data? (Consult water level data)
. Are ground-water flow-lines indicated?
. Are static water levels shown?
. Can hydraulic gradients be estimated?
j. Did the owner/operator develop hydrologic cross sections of the vertical flow
component across the site using measurements from all wells?
k. Do the owner/operator's flow nets include:
. piezometer locations?
. depth of screening?
. width of screening?
. measurements of water levels from all wells and piezometers?
2. Seasonal and temporal fluctuations in ground-water
a. Do fluctuations in static water levels occur? If yes, are the fluctuations caused bY
, '. any of the following:
-Off-site well pumping
-Tidal processes or other intermittent natural
variations (e.g., river stage, etc.) .
-On-site well pumping
-Off-site, on-site construction or changing land use patterns
-Deep well injection
-Seasonal variations
-Other (specify)
b. Has the owner/operator documented sources and patterns that contribute to or
affect the ground-water patterns below the waste management?
c. Do water level fluctuations alter the general ground-water gradients and flow
directions?
d. Based on water level data, do any head differentials occur that may indicate a
vertical flow component in the saturated zone?
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Y/N
e. Did the owner/operator implement means for gauging long term effects on water
move.ment that may result from on-site or off-site construction or changes in
lanq-use patterns?
3. Hydraulic conductivity
a. How were hydraulic conductivities of the subsurface materials detennined?
. Single-well tests (slug lests)?
. . Multiple-well tests (pump tests)
. Other (specify)
b. If single-well tests were conducted, was it done by:
. Adding or removing a known voluI11e of water?
Pressurizing well casing?
c. If single well tests were conducted in a highly permeable formation, were
pressure ttansducers and high-speed recording equipment used to record the
rapidly changing water levels?
d. Since single well tests only measure hydraulic conductivity in a limited area,
were enough tests run to en~ure a representative measure of conductivity in each
hydrogeologic unit?
e. Is the owner/operator's slug tes.t data (if applicable) consistent with existing.
geologic information (e.g., boring logs)?
f. Were other hydraulic conductivity properties detennined?
g. If yes, provide any of the following data, if available:
. Transmissivity
. Storage coefficient
. Leakage
. permeability
. poroSity
. . Specific capacity
. Other (specify)
4. Identification of the uppermost aqUifer
. a. Has the extent of the uppermost saturated zone (aquifer) in the facility area been
defined? If yes,
. Are soil boring/teSt pit logs included?
Are geologic cross-sections included?
b. Is there evidence of confining (competent, unfractured, continuous, and low
permeability) layers beneath the site? If yes,
. how was continuity demonsttated?
c. What is hydraulic conductivity of the confining unit (if present)? CM/Sec How
was it determined?
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Y/N
d. Does potential for other hydraulic communication exist (e.g., lateral incontinuity
between geologic units, facies changes, fracture zones, cross cutting structures,
or chemical corrosion/alteration of geologic units by leachage? If yes or no, what
is the rationale?
G. Office Evaluation of the Facility's Ground-Water Monitoring System-
Monitoring Well Design and Construction:
These questions should be answered for each different well design present at the
facility.
1. Drilling Methcxls
a. What drilling method was used for the Well?
Hollow-stem auger o.
. Solid-stem auger 0
. Mud rotary 0
. Air rotary 0
. Reverse rotary O.
. . Cable tool 0
. Jetting 0
. Air drill w/ casing hammer C1
. Other (specify)
b. Were any cutting fluids (including water) or additives used during drilling? If
yes, specify:
. Type of drilling fluid
. Source of water used
. Foam
. Polymers
. Other
c. Was the cuttinl't fluid, or additive, identified?
d. Was the drilling equipment steam-cleaned prior to drilling the well? -
. Other methcxls
e~ Was compressed air used during drilling? If yes,
. was the air filtered to remove oil?
f. Did the owner/operator document procedure for establishing the potentiometric
surface? If yes,
. how was the location established?
g. Formation samples
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9950.2
Y/N
. Were fonnation samples collected initially during drilling?
. Were any cores taken continuous?
. If not, at what interval were samples taken?
. How were the samples obtained?
-Split spoon
-Shelby tube
-Core drill
-Other (specify)
. Identify if any physical and/or chemical tests were perfonned on the
fonnation samples (specify)
2. Monitoring Well Construction Materials
a. Identify construction materials (by number) and diameters (ID/OD)
Material Diameter \
. Primary Casing
. Secondary or outside casing
(doubleconstruction)
\ . Screen
b. How are the sections of casing and screen connected?
. Pipe sections threaded
. Couplings (friction) with adhesive or solvent
. Couplings (friction) with retainer screws
. Other (specify)
c. Were the materials steam-cleaned prior to installation?
. If no, how were the materials cleaned?
3 . Well Intake Design and Well Development
a. Was a well intake screen installed?
. What is the length of the screen for the well?
. Is the screen manufactured?
b. Was a filter pack Installed'!
. Wh~t kind of filter pack was employed?
. Is the filter pack compatible with formationmaterials?
. How was the filter pack installed?
OWPE
A.10
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9950,2
Y/N
. What are the dimensions of the filter paCk?"
. Has a turbidity measurement of the well water ever been made?
Have the filter pack and screen been designed for the in situ materials?
c. Well development
. Was the well developed?
. What technique was used for well development?
-Surge block -
-Bailer -
-Air surging
-Water pumping
-Other (specify)
4. Annular Space Seals
a. What is the annular space in the saturated zone directly above the filter pack
filled with:
-Sodium bentonite (specify type and grit)
-Cement (specify neat or concrete)
-Other (specify)
b. Was the seal installed by:
-Dropping material down the hole and tamping
-Dropping material down the inside of hollow-stem auger
- Tremie pipe method
-Other (specify)
c. Was a different seal used in the unsaturated zone? If yes,
. Was thIS seal made WIth'r
-Sodium bentonite (specify type and grit)
-Cement (specify neat or concrete)- Other (SPecify)
. Was this seal installed by?
-Dropping material down the hole and tamping
-Dropping material down the inside of hollow stem auger
-Other (specify)
d. Is the upper portion of the borehole sealed with a concrete cap to prevent
infIltration from the surface?
e. Is the well fitted with an above-ground protectivedevice and bumper guards?
f. Has the protective cover been installed with locks to prevent tampering?
OWPE
A.11
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9950.2
Y/N
H. Evaluation of the Facility's Detection Monitoring Program
1. Placement of Downgradient Detection Monitoring Wells
a. Are the ground-water monitoring wells or clusters located immediately adjacent
to the waste management area?
b. . How far apart are the detection monitoring wells? .
c. Does the owner/operator provide a rationale for the location of each monitoring
well or cluster?
d. Does the owner/operator identified the well screenlengths of each monitoring
well or clusters? '
e. Does the owner/operator provide an explanation for the well screen lengths of
each monitoring well orcluster?
f. Do the actual locations of monitoring wells orclusters correspond to those
identified by the owner/operator?
/
2. Placement of Upgradient Monitoring Wells
a. Has the owner/operator documented the location of each upgradient monitoring
well or cluster?
b. Does the owner/operator provide an explanation fonhe location(s) of the
upgradient monitoring wells?
c. What length screen has the owner/operator employed inthe background
monitoring well(s)?
d. Does the owner/operator provide an explanation for the screen length(s)
~hosen?
e. Does the actual location of each background monitorin~ well or cluster
correspond to that identified by the owner/operator?
I. Office Evaluation of the Facility's Assessment Monitoring Program
1. Does the assessment plan specify:
-
a. The number, location, and depth of wells?
b. The rationale for their plac~ment and identifr the basis that will be used to select
subsequent sampling locations and depths in later assessment phases?
2. Does the list of monitoring parameters include all hazardous waste constituents
from the facility?
OWPE
A-12
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9950.2
I'
Y/N
,a. Does the water quality parameter list include other important indicators not
classified as hazardous waste constituents?
b. Does the owner/operator provide documentation for he listed wastes which are
not included?
.
3. Does the owner/operator's assessment plan specify the procedures to be used to
determine the rate of constituent migration in the ground-water?
4. Has the owner/operator specified a schedule of implementation in the assessment
plan?
5. Have the assessment monitoring objectives been clearly defined in the assessment
plan?
a. Does the plan include analysis and/or re-evaluation to determine if significant
contamination has occUITedin any of the detection monitoring wells?
b. Does the plan provide for a comprehensive program of investigation to fully
characterize the rate and extent of contaminant migration from the facility?
c. Does the plan call for determining the concenttations of hazardous wastes and
hazardous waste constituentsin the ground water?
d. Does the plan employ a quarterly monitoring program?
6. Does the assessment plan identify the investigatory methods that will be used in the
assessment phase?
a. Is the role of each method in the evaluation fully described?
b. Does the plan provide sufficient descriptions of the direct methods to be used?
c. Does the plan provide sufficient descriptions of the indirect methods to be used? .
d. Will the method contribute to the further characterization of the contaminant
movement?
7. Are the investigatory techniques utilized in the assessment program based on ,direct
methods?
a. Does, the assessment approach incorporate indirect methods to further support
direct methods?
,b. Will the planned methods called for in the assessment approach ultimately meet
performance standards for assessment monitoring?
c. AIe the procedures well defmed?
d. Does the approach provide for monitoring wells similar in design and
consf!Uction as the detectionmonitoring wells?
,OWPE
Aa13
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9950.2
Y/N
e. Does the approach employ taking samples during drilling or collecting core.
samples for further analysis?
8. Are the indirect methods to be used based on reliable and accepted geophysical
techniques?
a. Are they capable of detecting subsurface changesresulting from contaminant
. .
migration at the site?
b. Is the measurement at an appropriate level of sensitivity to detect ground-water
quality changes at the site?
c. Is the method appropriate considering the nature of the subsurface materials?
d. Does the approach consider the limitations of these methods?
e. Will the extent of contamination and constituent concentration be based on direct
methods and sound engineering judgment? (Using indirect methods tofurther
substantiate the findings.)
9. Does the assessment approach incorporate any mathe-matical modeling to predict
contaminant movement?
a. Will site specific measurements be utilized toaccurately portray the subsurface?
b. Will the derived data be reliable?
c. Have the assumptions been identified?
d. Have the physical and chemical properties of the site-specific wastes and
hazardous waste constituentsbeen identified?
J. Conclusions
1. Subsurface geology .
a. Has sufficient data been collected to adequately define petrography and
petrographic variation?
b. Has the subsurface geochemistry been adequately defined?
c. Was the boring/coring program adequate to definesubsurface geologic variation?
d. Was the owner/operator's narrative description complete and accurate in its
interpretation of the data? '
e. Does the geologic assessment address or provide means to resolve any
. .
information gaps?
2. Ground-water flowpaths
a. Did the owner/operator adequately establish the hori-zontal and vertical
components of 2I'ound-water flow?
OWPE
A.14
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9950.2
I YIN
b. Were appropriate methods used to establish ground-water flowpaths?
c. Did the owner/operator provide accurate documentation?
d. Are the potentiometric surface measurements valid?
e. Did the owner/operator adequately consider the seasonal and temporal effects on
the ground-water?
f. Were sufficient hydraulic conductivity tests performed to document lateral and
vertical variationin hydraulic conductivity in the entire hydrogeologic subsurface
below the site?
3. Uppermost Aquifer
a.Did the owner/operator adequately define the upper-most aquifer?
4. Monitoring Well Construction and Design
a. Do the design and construction of the owner/operator's ground-water monitoring
wells permit depth discrete ground-water samples to be taken?
b. Are the samples representative of ground-water quality?
c. Are the ground-water monitoring wells strUcturally stable?
d. Doe~ the ground-water monitoring well's design and construction permit an
accurate assessment of aquifer characteristics?
5. Detection Monitoring
a. Downgradient Wells
. Do the location, and screen lengths of the ground-water monitoring wells or
clusters in the detection monitoring system allow the immediate detection of a
release of hazardous waste or constituents from the hazardous waste
management area to the uppermost aquifer?
b. Upgradient Wells
. Do the location and screen lengths of the upgradient (background) ground-
water monitoring wells ensure the capability of collecting ground-water
samples representative of upgradient (background) ground-water quality
including any ambient heterogenous chemical characteristics?
6. Assessment Monitoring
a. Has the owner/operator adequately characterized site hydrogeology to determine
contaminant migration?
b. Is the detection monitoring system adequately designed and constructed to
immediatelv detect any contaminant release?
OWPE
A.15.
[.
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9950.2
I
I .
I
Y/N
c. Are the procedures used to make a fIrst determinationofcontamination adequate?
d. Is the assessment plan adequate to detect, characterize, and track contaminant
migration?
e. Will the assessment monitoring wells, given site hydrogeologic conditions,
define the extent and concentration of contamination in the horizontal and
vertical planes?
f. Are the assessment monitoring wells adequately designed and constrUcted?
g. Are the sampling and an~ysis procedures adequate to provide trUe measures of
contamination? I
h. Do the procedures used for evaluation of assessment monitoring data result in
determinations of the rate of migration, extent of migration, and hazardous
constituent composition of the contaminant plume?
i. Are the data collected at sufficient frequency and duration to adequately
determine the rate of migration?
j. Is the schedule of implementation adequate?
k. Is the owner/operator's assessment monitoring plan adequate?
. If the owner/operator had to implement hisassessment monitoring plan, was it .
implemented satisfactorily?
II. Field Evaluation
A. Ground-Water Monitoring System
1. Are the numbers, depths, and locations of monitoring wells in agreement with those
reported in the facility's monitoring plan? (See Section 3.2.3.)
B. Monitoring Well Construction
1. Identify constrUction material material diameter
a. Primary Casing
b. Secondary or outside casing
2. Is the upper portion of the borehole sealed with conrete to prevent inf11tration from
the surface?
3. Is the well fItted with an above-ground protective device?
4. Is.the protective cover fItted with locks to prevent tampering? If a facility utilizes
more than a single well design, answer the above questions for each well design?
OWPE
A-16
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9950.2
V/N
In. Review of Sample Collection Procedures
A. Measurement of Well Depths /Elevation
1. Are measurements of both depth to standing water and depth to the bottom of the
well made?
2. Are measurements taken to the 0.01 feet?
3. What device is used?
4. Is there a reference point established by a licensed surveyor?
I
5. Is the measuring equipment properly cleaned betweenwlliocations to prevent cross
con tamination?
B. Detection of Immiscible Layers
1. Are procedures used which will detect light phase immiscible layers?
2. Are procedures used which will detect heavy phase immiscible layers?
C. Sampling of Immiscible Layers
1. Are the immiscible layers sampled separately prior to well evacuation?
2. Do the procedures used minimize mixing with watersoluble phases?
D. Well Evacuation
1. Are low yielding wells evacuated to dryness?
2. Are high yielding wells evacuated so that at least three casing volumes are removed?
3. What device is used to evacuate the wells?
4. If any problems are encountered (e.g., equipmenttnalfunction) are they noted in a
field logbook?
OWPE
A.17
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9950.2
Y/N
E. Sample Withdrawal
1. For low yielding wells, are samples for volatiles, pH, and oxidation/reduction I
potential drawn first after the well recovers?
. .
2. Are samples withdrawn with either flurocarbon/resins or stainless steel (316, 304 or
2205) sampling devices?
3. Are sampling devices either bottom valve bailers or positive gas displacement
,
. bladder pumps?
4.' If bailers are used, is fluorocarbon/resin coated wire, single strand stainless steel
wire, or monoftlament used to raise and lower the bailer?
5. If bladder pumps are used, are they operated in acontinuous manner to prevent,
aeration of the sample?
6. If bailers are used, are they lowered slowly to prevent degassing of the water?
7. If bailers are used, are the contents transferred to the sample container in a way that
minimizes agitation and aeration?
8. Is care taken to avoid placing clean sampling equipment on the ground or other
contaminated surfaces prior to insertion into the well?
9. If dedicated sampling equipment is not used, is equipment disassembled and
thoroughly cleaned between samples?
10. If samples are for inorganic analysis, does the cleaning procedure include the
following sequential steps: .
a. Dilute acid rinse (HN03 or HC1)?!!. If samples are for organic analysis, does
the cleaning procedure include the following sequential steps:
, .
11. If samples are for inorganic analysis, does the cleaning procedure include the
following sequential steps:
a. Nonphosphate detergent wash?
b. Tap water rinse?
c. Distilled/deionized. water rinse?
d. Acetone rinse?
e. Pesticide-grade hexane rinse?
OWPE
A.18
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9950.2
Y/N
12. Is sampling equipment thoroughly dry before use?
13. Are equipment blanks taken to ensure that sample cross-contamination has not
occurred?
14. If volatile samples are taken with a positive gas displacement bladder pump, are
pumping rates below 100 mVmin?
F. In-situ or Field Analyses
1. Are the following labile (chemically unstable) parameters determined in the field:
a.pH?
- b. Temperature?
c. Specific conductivity?
d. Redox potential?
e. Chlorine?
f. Dissolved oxygen?
g. Turbidity?
h. Other (specify)
2. For in-situ determinations, are they made after well evacuation and sample removal?
3. If sample is withdrawn from the well, is parameter measured from a split portion?
4. .Is monitoring equipment calibrated according to mannufacturers' specifications and
consistent with SW-846?
5: Is the date, procedure, and maintenance for equipment calibration documented in the
field logbook?
IV. Review of Sample Preservation and Handling Procedures
'
A. Sample Containers
1. Are samples transferred from the sampling device directly to their compatible
containers?
,
OWPE
A-19
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9950.2
I
I.
V/N
2. Are sample containers for metals (inorganics) analyses polyethylene with
polypropylene caps?
3. Are sample containers for organics analysis glass bottles with tluorocarbonresin-
lined caps?
4. If glass bottles are used for metals samples are the caps tluorocarbonresin-lined?
5. Are the sample containers for metal analyses cleanedusing these sequential steps:
a. Nonphosphate detergent wash?
b. 1: 1 nitric acid rinse?
c. Tap water rinse?
d.' 1: 1 hydrochloric acid rinse?
e. Tap water rinse?
f. Distilled/deioni'Zed 'water rinse?
6. Are the sample "containers for organic analyses cleaned using these sequential steps:
a. Nonphosphate detergentlhot water wash?
b. Tap water rinse? I
c. Distilled/deionized water rinse?
d. Acetone rinse?
e. Pesticide-grade hexane rinse? I
"
7. Are trip blanks used for each sample container type to verify cleanliness?
B. Sample Preservation Procedures
1. Are samples for the following analyses cooled to 40C:
a. TOC?
b. TaX?
c. Chloride?
d. Phenols?
e. Sulfate?
f. Nitrate?
g. Coliform bacteria?
h. Cyanide?
i. Oil and grease?
j. Hazardous co~stituents (}261, Appendix VIll)?
OWPE
A.20
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9950.2
Y/N
2. Are samples for the following analyses field acidified to pH <2 with HN03:
a. Iron?
b. Manganese?
c. Sodium?
d. Total metals?
e. Dissolved metals?
f. Fluoride?
g.Endrin?
h. Lindane?
i. Methoxychlor?
j. Toxaphene?
k. 2,4, D?
1. 2,4,5 TP Silvex?
m. Radium'!
n. Gross alpha?
o. Gross beta?
3. Are samples for the following analyses field acidfied to pH <2 with ~S04:
a. Phenols?
b. Oil and grease?
4. Is the sample for TOC analyses field acified to pH <;2 with HCI?
5. Is the sample for TOX analysis preserved with 1 ml of 1.1 M sodium sulfite?
6. Is the sample for cyanide analysis preserved with NaOH to pH> l2?
C. Special Handling Considerations
1. Are organic samples handled without filtering?
2. Are'samples for volatile organics transfered to the appropriate vials to eliminate
headspace over the sample?
3. Are samples for metal analysis split into two portions?
4. Is the sample for dissolved metals filtered through a 0.45 micron filter?
5. Is the second portion not fUtered and analyzed for total metals?
6. Is one equipment blank prepared each day of ground-water sampling?
OWPE
A.21
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.9950.2
Y/N
V. Review of Chain-of-ClIlstody Procedures
;
A. Sample Labels ..
1. Are sample labels used?
. 2. Do they provide the following information:
a. Sample identIfication number? .
b. Name of collector?
c. Date and time of collection?
d. Place of collection '1
e. Parameter(s) requested and preservitives used?
3. Do they remain legible even if wet?
B. Sample Seals
1. Are sample seals placed on those containers to ensure samples are not altered?
C. Field Logbook
1. Is a field logbook maintained?
2. Does it document the following:
a. Purpose of sampling (e.g., detection or assesment)?
b. Location of well(s)?
c. Total depth of each well?
d. Static water level depth and measurement technique?
e. Presence of immiscible layers and detection method?
f. Collection method for immiscible layers and sample identification numbers?
g. Well evacuation procedures?
h. Sample withdrawal procedure?
i. Date and time of collection?
j. Well sampling sequence?
k. Types of sample containers and sample identification number(s)?
1. Preservative(s) used?
m. Parameters requested?
n. Field analysis data and method(s)?
o. Sample distribution and transponer?
p. Field observations?
OWPE
A-22.
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9950.2
Y/N
-Unusual well recharge rates?
-Equipment malfunction(s)?
-Possible sample contamination?
-Sampling rate?
D. Chain-or-Custody Record
1. Is a chain-of-custody record included with each sample?
2. Does it document the following:
a. Sample number?
b. Signiture of collector?
c. Date and time of collection?
d. Sample type?
e. Station. location?
f. Number of containers?
g. Parameters requested?
h. Signatures of persons involved in chain-of-custody?
i. Inclusive dates of custody?
E. Sample Analysis Request Sheet
1. Does a sample analysis request sheet accompany each sample?
2. Does the request sheet document the following:
a. Name of person receiving the sample?
b. Date of sample receipt?
c. Duplicates?
d. Analysis to be performed?
IV. Review of Quality Assurance/Quality Control
,
A. Is the validity and reliability of the laboratory and field generated data ensured
by a QAlQC program?
B. Does the QAlQC program include:
1. Documentation of any deviation from approved procedures?
f
OWPE
A-23
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9950.2
Y/N
2. Documentation of analytical results for:
a. Blanks? i
b. Standards?
c. Duplicates?
d. Spiked samples?
'e. Detectable limits for each parameter being analyzed?
C. Are'approved statistical methods used?
D. Are QC samples used to correct data?
E. Are, all data critically examined to ensure it has been properly calculated and
reported?
VII. Surficial Well Inspection and Field Observation
A. Are the wells adequately maintained?
B. Are the monitoring wells protected and secure?
(
C. Do the wells have surveyed casing elevations?
D. Are .the ground-water samples turbid?
E. Have all physical characteristics of the site been noted in the inspector's field
notes (i.e., surface waters, topography, surface features)?
. . ,
F: Has a site sketch been prepared by the field inspector with scale, north arrow,
, ,
location(s) of buildings, location(s) of regulated units, locations of monitoring'
wells, and a rough depiction of the site drainage pattern?
OWPE
A.24
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'1
I .
VIII. Conclusions
A. Is the facilitycurrently operating under the correct monitoring progaram
according to the statistical analyses performed by the current operator?
B. Does the ground-water monitoring system, as designed and operated, allow for
detection or assessment of any possible ground-water contamination caused by
the facility?
C. Does the sampling and analysis procedures permit the owner/operator to detect
and, where possible, assess the nature and extent of a release of hazardous
constituents to ground water from the monitored hazardous waste management
facility?
)
. 9950.2
Y!N
OWPE
A-25
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9950.2
. Figure 4.3
Relationship of Technical Inadequacies to
Ground-Water Performance Standards
Examples of Basic
Elements Required by
Performance Standards
Examples of Technical Inadequacies
. that may Constitute Violations
. Regulatory Citations
1. Uppermost Aquifer
must be correctly
identified.
2. Ground-water flow
directions and rates
must be properly
determined.
. failure to consider aquifers .
hydraulically interconnected to the
uppennpst aquifer.
. incprrect identification of certain
fonnations as confining layers or
. aquitards. .
.. failure to use test drilling and/or soil
borings to characterize subsurface
hydrogeology.
o failure to use piezometers or wells to
detennine ground-water flow rates and
directions (or failure to use a sufficient
number of them).
. failure to consider temporal variations
in water levels when establishing flow
directions (e.g., seasonal variations,
short-tenn fluctuations due to
. pumping).
. failure to assess significance of vertical
gradients when evaluating flow rates
and directions.
. failure to use standard/consistent
benchmarks when establishing water'
level elevations. .
. failure of the owner/operator (0/0) to.
consider the effect of local Withdrawal
wells on ground-water flow direction.
. failure of the % to obtain sufficient
water level measurements. .
~265.90(a)
~265.91(a)(1, 2)
~270.14( c )(2)
~265.90(a)
~265.91(a)(1, 2) .
~270.14(c)(2)
~265.90(a)
~265.91(a)(1,2)
~270.14(c)(2)
~265.90(a) .
. ~265.91(a)(1~ 2)
~270.14(c)(2)
~265.90(a)
~265.91(a)(1, 2)
~270.14(c)(2) .
~265.90(a)
~265.91(a)(1, 2)
~270.14(c)(2)
~265.90(a) .
~265.91(a)(1, 2)
~270.14(c)(2)
~265.90(a) .
~265.91(a)(1)
~265.90(a)
~265.91(a)(l)
OWPE
A-26
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9950.2
Examples of Basic
Elements Required by
Performance Standards
Examples of TechniCal Inadequacies
that may Constitute Violations
Regulatory Citations
3. Background wells
must be located
so as to yield
samples that are
not affected by
the facility.
. .
4. Background wells
must be
constructed so as
to yield samples
that are
representative of
in-situ ground-
water quality.
. failure of the % to consider the effect of
local withdrawal wells on ground-water
flow direction. .
. failure of the % to obtain sufficient
water level measurements.
. failure of the % to consider flow path of
dense immiscibles in establishing
up gradient well locations.
. failure of the % to consider seasonal
fluctuations in ground-water flow
direction.
. "failure to install wells hydraulically
upgradient, except in cases where
up gradient water quality is affected by
the facility (e.g., migration of dense
immiscibles in the up gradient direction,
mounding water beneath the facility)~
. failure of the % to adequately
characterize 'subsurface hydrogeology.
. wells intersect only ground water that
flows around facility.
. wells constructed of materials that may
release or absorb constituents of concern
. wells improperly sealed--contamination
of sample is a concern.
. nested or multiple screen wells are used
and it cannot be demonstrated that there
has been 00 movement of ground water
betWeen strata.
~265.90(a)
~265.91(a)(1)
~265.90(a)
~265.91(a)(1)
~265.90(a)
~265.91(a)(1)
~265.90(a)
~265.91(a)(1)
~~65.90(a)
'. ~265.91(a)(1)
~265.90(a)
~265.91(a)(1)
~265.90(a)
~265.91 (a)(1)
~265.90(a)
~265.91(a)
~265.90(a)
~265.91(a), (c)
~265.90(a)
~265.91(a)(1, 2)
OWP-E
A-27
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9950.2
. Examples of Basic
Elements Required by
Performance Standards
Examples of Technical Inadequacies
that may Constitute Violations
Regulatory Citations
4. . Background wells
must be .
constructed so a~
to yield samples
that are
representative of
in-situ ground-
water quaJity.
(<:ontinued)
5. Downgradient
monitoring wells
must be located so
a~ to ensure t:4e
immediate
detection of any
. contamination
migrating from the
facility.
. improper drilling methods were used,
possibly contaminating the formation.
. well intake packed with materials that
may contaminate sample.
. well screens used are of an
. inappropriate length.
. wells developed using water other than
formation water.
. improper well development yielding
samples with suspended sediments that
may bias chemical analysis.
. use of drilling muds or nonformation
water during well construction that can
bias results of samples collected from
wells.
. wells not placed immediately adjacent
to waste management area.
. failure. of % to con~ider potential
pathways for dense immiscibles.
. inadequate venical distribution of wells
in thick or heavily stratified aquifer.
. inadequate horizontal distribution of
wells in aquifers of varying hydraulic
conductivity. . .
. likely pathways of contamination (e.g.,
buried streams channels, fractures,
areas of high permeability) are not
intersected by wells.
. well network covers uppermost but not
interconnected aquifers.
~265.90(a)
~265.91(a)
~265.90(a)
~265:91(a), (c)
~265.90(a)
~265.91(a)(1, 2)
~265.90(a)
~265.91(a)
~265.90(a)
~265.91(a)
~265.90(a)
~265.91(a)
~265.90(a)
~265.91(a)(2)
~265.90(a)
~265.91(a)(2)
~265.90(a)
~265.91(a)(2)
~265.90(a)
~265.91(a)(2)
~265.90(a)
~265.91(a)(2)
~265.90(a)
~265.91(a)(2)
OWPE
A-28
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9950.2
Examples of Basic
Elements Required by
Performance Standards
Examples of Technical Inadequacies
that may Constitute Violations
Regulatory Citations
6. Downgradient
monitoring wells
must be
constructed so as
to yield samples
that are
representative of
in-situ ground-
water quality.
7. Samples from
background and
downgradient
wells must be
properly collected
and analyzed.
See No.4 above.
. failure to evacuate stagnant water from
. the well before sampling.
. failure to sample wells within a
reasonable amount of time after well
evacuation.
. improper decisions regarding filtering
or non-filtering of samples prior to
analysis (e.g., use of filtration on
samples to be analyzed for volatile
organics).
. use of an inappropriate sampling
device.
. use of improper sample preservation
techniques.
~265.90(a), ~265.92(a)
~265.93(d)(4)
~2705.14(c)(4) .
~265.90(a)
~265.92(a)
~265.93(d)(4)
~270.14(c)(4)
~265.90(a)
~265.92(a)
~265.93(d)(4)
~270.14(c)(4)
~265.90(a)
~265.92(a)
~265.93(d)(4)
~270.14(c)(4)
~265.90(a)
~265.92(a)
~265.93(d)(4)
~270.14(c)(4)
[ .
OWPE
A.29
-------
9950.2
Examples of Basic
Elements Required by
Performance Standards
Examples of Technical Inadequacies .
that may Constitute Violations
'. oJ;."
Regulatory Citations
7. Samples from
background and
down gradient
wells must be
properly collected
and analyzed.
(Continued)
. samples collected with a device that is
constructed of materials that interfere
with sample integrity.
. samples collected with a n~m-dedicated
sampling device that is not cleaned
. between sampling events.
. improper use of a sampling device such
that sample quality is affected (e.g.,
degassing of sample caused by agitation
. of bailer).
. improper handling of samples (e.g.,
failure to eliminate headspace from
containers of samples to be analyzed for
volatiles).
" failure of the sampling plan to establish
procedures for sampling immiscibles
(Le., "floaters" and "sinkers").
. failure to follow ~ppropriate QNQC
procedures.
. failure to ensure sample integrity through
the use of proper chain-of-custody
procedures. .
. failure to demonstrate suitability of
methods used for sample analysis (other
than those specified in SW-846). .
. failure to perform analysis in the field on
unstable parameters or constituents (e.g.,
pH, Eh, specific conductance, alkalinity,
dissolved oxygen).
~265.90(a) .' '. .
~265.92(a) ,':.:.. ",
~265.93(d)(4)
~270.14(c)(4)
~265.90(a)
~265.92(a)
~265.93(d)(4)
~270.14(c)(4)
~265.90(a)
~265.92(a)
~265.93(d)(4)
~270.14(c)(4)
~265.90(a)
~265.92(a)
~265.93(d)(4)
~'270.14(c)(4)
~265.90(a)
~265.92(a) .
. ~265.93(d)(4)
~270.14(c)(4)
~265.90(a)
~265.92(a)
. ~265.93(d)(4)
~270.14(c)(4)
~265.90(a)
~265.92(a)
~265.93(d)(4)
. ~270.14(c)(4)
~265.90(a)
~265.92(a)
~265.93(d)(4)
~270.14(c)(4)
~265.90(a)
~265.92(a)
~265.93(d)(4)
~270.14(c)(4)
OWPE
A-30
-------
9950.2
Examples~ : Jasic
Elements Re( Jired by
Performance Standards
Examples of Technical Inadequacies
that may Constitute Violations
Regulatory Citations
7. Samples from
background and
downgradient
wells must be
properly collected
and analyzed.
(Continued)
. use of sample containers that may
interfere with sample quality (e.g.,
synthetic containers used with volatile
samples). .
. failure to make proper use of sample
blanks.
~265.90(a)
~265.92(a)
~265.93(d)(4)
~270.14(c)(4)
~265.90(a)
~265.92(a)
~265.93(d)(4)
~270.14(c)(4)
OWPE
A-31
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