United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
&EPA
DIRECTIVE NUMBER: 9950.2
Final P.CPA Comprehensive Crcund-Water
Monitoring Evaluation (CNT) Guidance
Document
APPROVAL DATE:
EFFECTIVE DATE:
December 1986
December 1986
OWPE
ORIGINATING OFFICE:
Q FINAL
D DRAFT
LEVEL OF DRAFT
DA Signed by AA or DAA
D B Signed by Office Director
DC Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
'E DIRECTIVE DIRECTIVE Dl
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&EPA
United States Environm**'*' *Vf»«±j
OSWER Directive Initiation Reauest
1. Directive Number
9950.2
2. Originator Information
ame of Contact Person
(enneth V.B. Jennings
Mail Code
WH-527
°MiW OWPE
Telephone Number
475-9374
. Title
Final RCRA Comprehensive Ground-Water Monitoring Evaluation (CME)
Guidance Document
Summary of Directive (Include brialstatement otpurpose/ , . - , ,^, «..;.,,-/«,,a 1
The CME guidance document provides a framework for evaluating inspections/eval-
uations of groundwater monitoring systems under RCRA. The document contains text
and a detailed checklist and draws heavily from the RCRA Ground water Monitoring
Technical Enforcement Guidance Document (TEGD) and Compliance Order Guide
Keywords
CME, ground-water monitoring, TEGD, inspections, RCRA
a. Does this Directive Supersede Previous Directives)? QJ Yes [J No What directive (numttr. titlt)
Does It Supplement Previous Directives)?
Yes
No Whlt Directive (numtor. titlt)
Draft Level
D A Signed by AA/DAA
B Signed by Office Director
DC-
For Review & Comment
Din
Development
his Request Meets OSWER Directives System Format
Sigoature of Lead Office Directives Coordinator
Date
Name and Title of Approving Official
Date
OS WER OS WER OS WER
DIRECTIVE DIRECTIVE I
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FINAL RCRA COMPREHENSIVE
GROUND-WATER MONITORING EVALUATION
GUIDANCE DOCUMENT
December 1986
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9950.2
FINAL COMPREHENSIVE GROUND-WATER MONITORING EVALUATION
GUIDANCE DOCUMENT
Intrcx3uction
Several types of inspections and evaluations have been developed by the
United States Environmental Protection Agency to assist the Regions and States
in determining the degree of compliance with the Resource Conservation and
Recovery Act regulations of owners and operators of hazardous waste management
facilities. These inspections/evaluations cover all aspects of the RCRA require-
ments 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
ccmnunity 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 findings rather than the
methods. Clearly, the findings of inspections/evaluations are integrally
important to the enforcement process. The Compliance Monitoring and Enforcement
Log (CMEL) lists ten categories of evaluations: 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 three of them:
1. Compliance Evaluation Inspection (CEI) is an on-site evaluation of the
compliance of a facility with RCRA regulations and permits intended
to gather information necessary to support an enforcement action.
2. Case Development Inspection (GDI) is an intensive investigation intended
to gather sufficient informatiorTto support an enforcement action.
3. Comprehensive Ground-Water Monitoring Evaluation (CME) is a detailed
evaluation of the adequacy of the design and operation of ground-water
monitoring systems at RCRA facilities.
Guidance for conducting Sampling Inspections will be integrated with CEI,
GDI and CME guidance, and guidance for Follow-Up Evaluations 'will be part of
GDI 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/evaluations, 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 I. 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 and operated to detect releases or to define
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 CMS involves extensive 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 carponent 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 forty (40) man days.
A summary of the CME process follows:
Activity
Pre-CME Planning
CME office evaluation of
system design
CME field evaluation of
system operation/verification
of system design
CME report preparation
Review of CME report
Ftollow-up inspection
Persons involved
0 technical enforcement staff
0 professional experienced in
geology
0 field inspector
0 professional experienced in
hydrogeology
0 technical enforcement staff
0 professional experienced in
hydrogeology/engineering
c technical enforcement staff
0 field inspector
0 experienced hydrogeologist or
geotechnical. engineer, and
chemist (where necessary)
technical enforcement staff
experienced hydrogeologist or
geotechnical engineer, and
chemist (where necessary)
* field inspector
technical enforcement staff
* hydrogeologist
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CME's should focus on evaluating system design if system design is not
sufficiently known in order to assess its adequacy. Where design is of the
system is already well understood, the CME should evaluate system operation
and maintenance more thoroughly. The rationale for setting these priorities
is that until system design is adequately understood, little nay be gained
from a detailed scrutiny of system operation. Conversely, once an adequate
evaluation of system design has been completed, further examination of static,
site characteristics during subsequent CME's 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:
A. Office Evaluation
1. Technical evaluation of the site geological characterization inclu-
ding geomorphology and structural geology, stratigraphy, petrology,
geochemistry beneath the site and any solid waste management units
(SWMUs) close enough to be of concern.
2. Technical evaluation of the site ground-water hydrological charac-
terization, including identification and description of the uppermost
aquifer, potentiometric surface, vertical and horizontal gradients,
and hydraulic conductivity beneath the site and any SWMUs close
enough to be of concern.
3. Technical evaluation of the criteria for horizontal well placement
and screen lengths of detection monitoring wells, upgradient 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 moni-
toring well design and construction.
6. Technical evaluation of the assessment plan or outline.
7. Technical evaluation of the sampling and analysis plan.
To the extent possible, the enforcement official should use existing infor-
mation 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.
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2. Field verification of the number, locations and screen depths
of ground-water monitoring wells and piezometers, and water
levels (where deemed necessary).
3. Possible collection of samples for analysis by a contract laboratory
or EPA/State laboratory to assist in the verification of analytical
precision and methodology of facility procedures. Samples may
either be owner-operator splits if the Agency approves of the
sarpling procedure, or EPA-collected.
4. Possible implementation of confirmatory geophysical methods to
verify facility assessment of hydrogeology or contaminant distribu-
tion.
C. Information Sources
A CME permits the determination of the adequacy of ground-water monitoring
systems through a detailed technical appraisal of site hydrogeology, monitoring
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. EPA 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
8. Aerial photographs
Ttie 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 ty the facility.
c. A description of the processes used for treating, storing and
disposing of hazardous waste.
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.
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9950.2
2. Part B of the RCRA Permit 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 schedule.
e. A topographic nap (scale: 1" = 200').
f. Aerial photographs.
g. Geologic and hydrogeologic characterization information.
h. Description of the ground-water monitoring system.
i. Sampling and Analysis Plan.
j. Ground-Water Quality Assessment Plan CXitline.
k. Monitoring well construction details.
1. Information about nearby ground-water and surface water usage.
Parts A and B of the RCRA permit application should be available at sources.
3. Contractor geotechnical reports
a. Description of waste handling procedures.
b. Geologic and hydrogeologic data (site-specific arid regional).
c. Description of ground-water monitoring system.
d. Facility layout.
e. Msnitoring well construction details.
f. Results of geophysical tests.
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9950.2
g. Reconmendations 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 information.
b. Regional soil maps.
c. Regional hydrogeologic data.
d. Information on ground-water usage.
e. Geochemical data.
f. Climatic data, precipitation, evapo-transpiration.
Geologic reports should be available from source numbers 3 and 4.
5. Inspection reports or other records or correspondence related to the
facility's compliance status.
a. Records of past violations.
b. Copies of ccnplaints, administrative orders or case referral
packages.
c. HWDMS reports (compliance monitoring and enforcement log).
d. Correspondence.
Reports ray 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 contain-
ment, 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.
e. Field and laboratory quality assurance/quality control.
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9950.2
f. Evaluation of the quality of ground-water data, including reporting
of low and zero concentration values, significant digits, missing
data values, cutliners 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.
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 (i.e., test
borings, mathematical modeling).
f. Discussion of the number, location, and depth of monitoring wells
the owner/operator will install to define contaminant migration (in
order to define 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 available 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 charac-
terization 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,
geochenical composites).
c. Contractor geotechnical reports.
d. Results of geophysical tests.
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9950.2
e. Static water level data.
f . In situ permeability tests (horizontal)
g. In situ permeability tests (vertical)
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 veils theoretically adequate to iitmediately detect the
release of hazardous waste constituents from the regulated unit,
and hazard constituents from regulated units subject to 270.14
3. Are the horizontal placement and screen lengths of assessment
monitoring wells theoretically adequate to determine the rate
and extent of migration and chemical composition of any contaminant
plumes?
4. Can the detection monitoring system theoretically differentiate
nearby SWMU releases from regulated unit releases? *
5. Are the design and construction criteria for detection ground-water
monitoring wells sufficient to provide long-term, 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 from the regulated unit(s), and hazardous
constituents in the case of a regulated unit subject to 270.14
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 permits
an assessment of their significance?
9. Is the statistical method used consistent with the regulatory
requirement?
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 differ-
entiate that contamination from any originating from SWMJs?
Where it is not possible to differentiate i.e. , where SWMJs and regu-
lated 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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9950.2
Section II. Field Evaluation and Verification Preparation
Prior to performing the field evaluation ccnponent, it is necessary for
the evaluation team to complete a nuniber 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, decontam-
ination procedures, and other safety precautions necessary.
2. All evaluation team personnel should have credentials or ident-
ification that describe their federal or state agency affiliation.
3. The following equipment is recommended to conduct the field
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.
0 deionized water, hexane (or laboratory strength cleaner), and
sterile, disposalable paper towels or gauze for decontamination of
tape measure or probe.
0 sampling equipment, e.g., bailer (made of inert material), mono-
filament line, properly cleaned.
0 all appropriate forms, e.g., chain-of-custody
0 safety equipment
4. Determination 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.
Samples should be taken when contamination is observed or suspected.
The team should develop a project plan prior to entry and nay use
facility's sampling equipment if it 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 determinations. The samples
will be analyzed to assess the operation of the monitoring system
and analytical procedures utilized by the facility.
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9950.2
Section III. 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
sparing of monitoring wells or clusters
static water level measurements (where deemed necessary)
well elevations, physical condition, labeling (where deemed necessary)
The following elements of the ground-water monitoring system design and
operation should be verified and evaluated:
8 determination of the presence, where appropriate, of light and dense
phase immiscible layers (where deemed necessary)
0 sample collection, preservation, and handling procedures, implemen-
tation of the sampling and analysis plan
0 determination of total well depths
c surficial well construction
0 general site conditions
0 site sketch
The office evaluation component identifies deficiencies in the design of
ground-water monitoring systems, either detection or assessment. The field
evaluation and verification component of a CME serves a dual purpose. It first
identifies discrepencies between system design as presented and constructed.
Secondly, the field component of the CME is an evaluation of system operation
and an opportunity to collect data necessary to draw conclusions about the
adequacy of the ground-water monitoring program (detection or 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.
A. Number and Location of Monitoring Wells
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 eadh well should be field checked against those presented on site
maps in the owner/operator' s Part B permit 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 owner/operator's site map, if applicable, and
measure using an engineer's scale).
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9950.2
Facilities under detection nmitoring nust have a sufficient nunrber of
wells to identify the presence of a release of contaminants from the hazardous
waste management area. Dpgradient 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 can pose problems
in establishing the upgradient quality of ground-water. In those situations,
the emphasis of the field work should be determining 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 TEED for detail). Other wells located within the facility boundaries
should be identified on a facility map.
B. Assessment Monitoring
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 define the contaminant concentrations
and plume configuration. Each well cluster may have several wells, each screened
at various intervals to provide the vertical extent of migration.
The evaluation team should verify the locations and vertical sampling
intervals of assessment wells or clusters.
C. Static Water Level Elevation
The inspector should determine, for each well, the depth to standing water.
Measurements are taken from reference point on the 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-sccpe,
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 .01
foot at the measuring point recorded. The depth to water is obtained by subtrac-
ting the wetted length from the nearest foot reading at the measuring point.
Measurements are generally recorded in hundredths of feet. To convert
frcm inches to feet:
inches x 0.0833 = feet
Should the owner/operator's Sampling and Analysis Plan, waste analysis or historical
data indicate the presence 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 the location of an organic/
water interface.
NOTE: Engineering chain tapes are usually graduated to the nearest 0.01 foot
for the first foot only.
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9950.2
D. Sanple Collection
Sanple collection should be divided into three phases:
1. Sanpling of light/dense phase immiscibles (where necessary),
2. Well evacuation, and
3. Sanple withdrawal.
Depending on the waste characteristics, the owner/operator's Sanpling and
Analysis Plan may not have provisions for sampling of light/dense phase immis-
cibles. 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 specific screened intervals, and
to collect "sinkers" within dense phase sampling cups at the bottom of the
well.
8 Sampling of Light Phase Immiscibles (May not be applicable to the
facility)
Sanpling 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.
0 Sanpling of Dense Phase Immiscibles (May not be applicable to
the facility)
Collection of dense phase immiscibles should be done before well evacuation.
Either a clean positive gas displacement bladder pump or bottom filling fluoro-
carbon 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 notions
that agitate the standing water should be restricted. Pumping rates should be
kept to 100 ml/mLn or less to avoid turbulence.
e 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 or refractory materials (i.e., fluorocarbon resins or
stainless steel 316, 304 or 2205).
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9950.2
2. Note the type of purging equipment used. Peristaltic punps, gas-
lift pumps, centrifugal pumps and venturi pumps nay increase vola-
tilization 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 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:
ID (inches) Gallons Metric
0.5 0.01 37.8 ml
0.75 0.02 75.8 ml
1.00 0.04 15.5 cl
1.25 0.06 22.7 cl
1.50 0.09 34.09 cl
2.00 0.16 60.61 cl
3.00 0.37 1.40 liter
4 0.65 2.46 liter
6 1.47 5.56 liter
8 2.61 9.89 liter
10 4.08 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, sinply multiply
by the height (in feet) of the water column. It may be necessary to verify the
diameter of the well casing.
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9950.2
E. Sample Withdrawal
The inspector should look for any sanpling technique that nay result in
the procurement of a contaminated or otherwise altered sanple. 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, puip equipment and probes
mast 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:
0. IN HCL or HN03 rinse
Distilled or deionized water rinse
When Organic Constituents are Suspected:
Nonphosphate detergent wash
Tap water rinse
Distilled water rinse
Acetone rinse
Hexane rinse
Adequate drying time
3. Pumping rates should not exceed 100 ml/min when sampling for volatiles
and pH. Higher pumping rates are acceptable for other parameters.
4. Positive gas displacement bladder pumps should be operated in a
continuous manner so that they do not produce pulsating samples
that are aerated in the return tube or upon discharge.
5. Check valves should be designed and inspected to assure that fouling
problems do not reduce delivery capabilities or result in aeration
of the sample.
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 VQA containers from the bottom of the bailer causes less
turbulence than pouring its contents from the top. It is recommended,
therefore, to fill the containers from the bottom of the bailer whenever
possible.
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9950.2
8. Samples should not be conposited in one large container and
later transferred to others.
9. Clean sanpling equipment should not be placed directly on the
ground or other contaminated surfaces prior to insertion into wells.
10. Sanpling 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. In Situ or Field Analyses
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-Physical/Chemical Methods)
G. Sample Preservation and Handling
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 conpatible
parameters (e.g., dissolved metals). Samples should not be conposited
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 (VQA) vial should be poured so that it
overflows leaving no headspace or bubbles in the vial, its cap should
be lined with a fluorocarbon resin.
4. Sanples for metals analysis can be collected in polyethylene containers
with polypropylene caps, or in glass bottles with fluorocarbon resin
lined caps.
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5. Samples for organic analysis should be collected in glass bottles
with fluorocarbon resin.
H. Special Handling Considerations
0 Organics
1. Sanples must not be filtered.
2. Sanples must not be transferred from one container to another.
0 Metals
1 . Sanples collected for metals analysis should be split into
sanples. One portion filtered through a 0.45 u filter for dissolved
metals and the second portion renaining unf iltered for total metals
analysis. Samples should be filtered as soon as possible to minimize
the impacts of pH and Eh changes.
2. Both samples should be preserved with nitric acid to pH <2.
The reconmended procedures for sampling and preservation are presented in
Sable 1.
I. Quality Assurance/Quality Control
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 sanple collection and handling processes
have not affected the quality of the field sanples. Field verification of
quality control procedures will include:
1. The use of trip and equipment blanks.
- Trip blanks: Used to determine if contamination was introduced
from the sample containers through normal handling.
- Equipment blanks: Used to determine 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. Chain-of -Custody Procedures
Field verification of the owner/operator's chain-of -custody procedures
will contain the following elements:
1. Sample labels for proper identification.
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SAMPLING AND PRESERVATION PROCEDURES FOR DETECTION MONITORING3
Parameter
Recommended Maximum
Container*! Preservative Holding Time
Minimum Volume
Required for
Analysis
Indicators of Ground-Water Contamination0
pH
Specific conductance
TOC
TOX
T,P,G Field determined
T,P,G Field determined
G. teflon-lined Cool 4°C, HC1 to
cap pH <2
G. amber, Teflon- Cool 4°C, add 1 ml
lined cap of 1.1M sodium sulfite
None
None
28 days
7 days
25 ml
100 ml
4 x 15 ml
4 x 15 ml
Ground-Water Quality Characteristics
Chloride
Iron
Manganese
Sodium
Phenols
Sulfate
T,P,G 4°C
T, P Field Acidified
to pH <2 with HNO3
G 4°C/H2SO4 to pH <2
T,P,G Cool, 4°C
28 days
6 months
28 days
28 days
50 ml
200 ml
500 ml
50 ml
EPA Interim Drinking Water Characteristics
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Fluoride
Nitrate
T,P Total Metals
Field acidified to
pH <2 with HNO-.
J
Dissolved Metals
1. Field filtration
(0.45 micron)
Dark Bottle 2. Acidify to pH <2
with HNO3
T,P Field acidified to
pH <2 with HNO3
T,P,G 4°C/H2SO4 to pH <2
6 months
6 months
28 days
14 days
1,000 ml
1,000 ml
300 ml
1,000 ml
-------
SAMPLING AND PRESERVATION PttXEDURES FUR DETECTION MONITORING
Parameter
Endrin
Lindane
Methoxychlor
Toxaphene
2.4,D
2,4,5 TP Silvex
Radium
Gross Alpha
Gross Beta
Co li form bacteria
Recommended
Container*3
T,G
P,G
PP, G (sterilized)
Preservative
Cool, 4°C
Field acidified to
pH <2 with HNO3
Cool, 4°C
Maximum
Holding Time
7 days
6 months
6 hours
Minimum Volume
Required for
Analysis
2,000
1 gallon
200 ml
Other Ground-Water Characteristics of Interest
Cyanide
Oil and Grease
Semi volatile.
nonvolatile organics
Volatiles
P,G
G only
T,G
G,T-lined
Cool, 4°C, NaOH to
pH >12
Cool, 4°C H2SO4 to
pH <2
Cool, 4°C
Cool, 4°C
14 days
28 days
14 days
14 days
aReferences: Test Methods for Evaluating Solid Waste - Physical/Chemical Methods,
500 ml
100 ml
60 ml
60 ml
SW-846
(2nd edition, 1982) .
Methods
Standard
for Chemical Analysis
of Water and Wastes,
Methods for the Examination of Water and
EPA-600/4-79-020
Wastewater, 16th edition (1985).
^Container Types:
P = Plastic (polyethylene)
G = Glass
T = Teflon
PP = Polypropylene
CBased on the requirements for detection monitoring (§265.93), the owner/operator must collect
^Efficient volume of ground-water to allow for the analy^i of four separate replicates.
i
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9950.2
2. Sanple seals to ensure integrity of the collected samples until
they are reopened.
3. Field logbook to record ground-water monitoring program information.
4. Chain-of-custody record to track sample possession.
.K. Sanple Labels
Ideally, sample labels should contain the following information:
1. Sample identification number (mandatory ).
2. Name of collector.
3. Date and time of collection.
4. Monitoring well.
5. Parameter(s) requested.
L. Sample Seals
Seals may be important in the event that samples leave the owner/
operator's immediate control through shipnent to laboratory. Seals
thus provide assurance that samples have not been disturbed or tampered
with.
M. Field Logbook
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. Sanple withdrawal procedure/equipment
9. Date and tine of collection
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9950 ,,2
10. Well sanpling sequence
11. Types of sartple containers used and sanple identification
numbers
12. Preservative(s) used
13. Parameters requested for analysis
14. Field analysis data and method(s)
15. Sanple distribution and transporter
16. Field observations on sanpling event
17. Name of collector
N. Chain-of-Custody Record
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 sanple. The record should contain the following type
of information:
1. Sanple number
2. Signature of collector
3. Date and time of collection
4. Sanple 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
0. 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
accurate to +_ 0.01 foot.
P. Surficial Well Inspection
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:
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9950.2
1. Wells adequately maintained (not overgrown by vegetation or
inpaired 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
Q. Field Observations
While in the field it is important to record as many observations 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 affecting hydrogeology) -
Nearby industrial wells, drainage ditches, underground conduits
and drains, impoundments, also note area water supply sources.
R. Site Sketch
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
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9950.2
4. Drainage pattern and ground-water flow direction
5. Location of drains and seepage areas
6. North arrow and rough scale
Section IV. Sampling and Analysis
When the owner/operator's ground-water monitoring system design has
been determined to be satisfactory, subsequent CMEs focus 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)
sanple, collected and prepared using EPA-approved methods, to the enforce-
ment authority's laboratory for analysis.
Section V. Conclusions and Recommendations
Has the owner/operator adequately characterized site hydrogeology?
Is the detection monitoring system adequately designed and constructed
to intnediately detect any contaminant release from the regulated unit(s)
and differentiate where possible, such releases from nearby SWMJ releases?
Are the procedures used to make a first determination of contamination
adequate?
Is the operation of the ground-water monitoring system adequate to permit
immediate detection of a release of contaminants from hazardous waste
management areas?
Do the assessment monitoring-wells, given site hydrogeologic conditions,
define the extent and concentration of contamination in the horizontal
and vertical planes?
Are the assessment monitoring wells adequately designed and constructed?
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9950.2
Are the sampling and analysis procedures adequate to provide representative
sanples of ground-water in the uppermost aquifer?
Do the procedures used for evaluation of assessment monitoring data
result in determinations of the rate of migration, extent of migration,
and hazardous waste constituent composition of the contaminant plume?
Are the data collected at sufficient duration and frequency to adequately
determine the rate of migration?
Is the schedule of implementation adequate?
Is the owner/operator's assessment monitoring plan adequate?
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,
information 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 or minor areas of noncotpliance. Major deficiencies would involve short-
comings 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
define the recommendations. These recommendations will thus provide appropriate
guidance toward obtaining more information that may be required for administrative
or judicial action.
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9950.2
APPENDIX A
COMPREHENSIVE GROUND-WATER MONITORING EVALUATION WORKSHEET
The following worksheets have been designed to assist the enforcement
officer/technical reviewer in evaluating the ground-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.
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 permit application? (Y/N)
b. RCRA Part B permit application? (Y/N)
c. Correspondence between the owner/operator and
appropriate agencies or citizen's groups? (Y/N)
d. Previously conducted facility inspection reports? (Y/N)
e. Facility's contractor reports? (Y/N)
f. Regional hydrogeologic, geologic, or soil reports? (Y/N)
g. The facility's Sampling and Analysis Plan? (Y/N)
h. Ground-water Assessment Program Outline (or Plan,
if the facility is in assessment monitoring)? (Y/N)
i. Other (specify)
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 scientist, or
geoteohnical engineer)? (Y/N)
b. Materials tests (e.g., grain size analyses,
standard penetration tests, etc.)? (Y/N)
c. Piezometer installation for water level measure-
ments at different depths? (Y/N)
d. Slug tests? (Y/N)
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e. Punp tests? (Y/N)
f. Geochemical analyses of soil samples? (Y/N)
g. Other (specify) (e.g., hydrochemical diagrams
and wash analysis)
2. Did the owner/operator use the following indirect techniques
to supplement direct techniques data:
a. Geophysical well logs? (Y/N)
b. Tracer studies? (Y/N)
c. Resistivity and/or electromagnetic conductance? (Y/N)
d. Seismic Survey? (Y/N)
e. Hydraulic conductivity measurements of cores? (Y/N)
f. Aerial photography? (Y/N)
g. Ground penetrating radar? (Y/N)
h. Other (specify)
3. Did the owner/operator document and present the reiw data from
the site hydrogeologic assessment? (Y/N)
4. Did the owner/operator document methods (criteria)
used to correlate and analyze the information? (Y/N)
5. Did the owner/operator prepare the following:
a. Narrative description of geology? (Y/N)
b. Geologic cross sections? (Y/N)
c. Geologic and soil maps? (Y/N)
d. Boring/coring logs? (Y/N)
e. Structure contour naps of the differing water
bearing zones and confining layer? (Y/N)
f. Narrative description and calculation of ground-
water flows? (Y/N)
g. Water table/potentionetric nap? (Y/N)
h. Hydrologic cross sections? (Y/N)
6. Did the owner/operator obtain a regional nap of
the area and delineate the facility? (Y/N)
If yes, does this map illustrate:
a. Surficial geology features? (Y/N)
b. Streams, rivers, lakes, or wetlands near the
facility? (Y/N)
c. Discharging or recharging wells near the facility? (Y/N)
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9950.2
7. Did the owner/operator obtain a regional hydro-
geologic rap? (Y/N)
If yes, does this hydrogeologic nap indicate:
a. Major areas of recharge/discharge? (Y/N)
b. Regional ground-viater flow direction? (Y/N)
c. RDtentiometric contours which are consistent
with observed water level elevations? (Y/N)
8. Did the owner/operator prepare a facility site nap? (Y/N)
If yes, does the site nap show:
a. Regulated units of the facility (e.g., landfill
areas, impoundments)? (Y/N)
b. Any seeps, springs, streams, ponds, or wetlands? (Y/N)
c. Location of monitoring wells, soil borings, or
test pits? (Y/N)
d. How nany regulated units does the facility have?
If more than one regulated unit then,
o Does the waste management area enconpass all
regulated units? (Y/N)
Or
o Is a waste nanagenent area delineated for each
regulated unit? (Y/N)
C. Characterization of Subsurface Geology of Site
1. Soil boring/test pit program:
a. Were the soil borings/test pits performed under
the supervision of a qualified professional? (Y/N)
b. Did the owner/operator provide documentation
for selecting the spacing for borings? (Y/N)
c. Mere the borings drilled to the depth of the
first confining unit below the uppermost zone
of saturation or ten feet into bedrock? (Y/N)
d. Indicate the nethod(s) of drilling:
o Auger (hollow or solid stem)
o Mud rotary
o Reverse rotary
o Cable tool
o Jetting
o Other (specify)
e. Were continuous sample corings taken?(Y/N)
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9950.2
Hew were the samples obtained (checked method[s])
o Split spool
o Shelby tube, or similar
o Rock coring
o Ditch sampling
o Other (explain)
g. Mere the continuous sairple corings logged by a
qualified professional in geology? (Y/N)
h. Does the field boring log include the following
information:
o Hole name/number? (Y/N)
o Date started and finished? (Y/N)
o Driller's name? (Y/N)
o Hole location (i.e., map and elevation)? (Y/N)
o Drill rig type and bit/auger size? (Y/N)
o Gross petrography (e.g., rock type) of
each geologic unit? (Y/N)
o Gross mineralogy of each geologic unit? (Y/N)
o Gross structural interpretation of each
geologic unit and structural features
(e.g., fractures, gouge material, solution
channels, buried streams or valleys, identifi-
cation of depositional material)? (Y/N)
o Development of soil zones and vertical extent
and description of soil type? (Y/N)
o Depth of water bearing unit(s) and vertical
extent of each? (Y/N)
o Depth and reason for termination of borehole? (Y/N)
o Depth and location of any contaminant encountered
in borehole? (Y/N)
o Sample location/number? (Y/N)
o Percent sample recovery? (Y/N)
o Narrative descriptions of:
Geologic observations? (Y/N)
Drilling observations? (Y/N)
i. Were the following analytical tests performed
on the core samples:
o Mineralogy (e.g., microscopic tests and x-ray
diffraction)? (Y/N)
o Petrographic analysis:
- degree of crystallinity and cementation of
matrix? (Y/N)
- degree of sorting, size fraction (i.e.,
sieving), textural variations? (Y/N)
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9950.2
- rode type(s)? (Y/N)
- soil type? (Y/N)
- approximate bulk geochemistry? (Y/N)
- existence of nicrostructures that may effect
or indicate fluid flow? (Y/N)
o Falling head tests? (Y/N)
o Static head tests? (Y/N)
o Settling measurements? (Y/N)
o Centrifuge tests? (Y/N)
o Column drawings? (Y/N)
D. Verification of subsurface geological data
1. Has the owner/operator used indirect geophysical methods
to supplement geological conditions between borehole
locations? (Y/N)
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 lower water-bearing units? (Y/N)
3. Is the confining layer laterally continuous across
the entire site? (Y/N)
4. Did the owner/operator consider the chemical
compatibility of the site-specific waste types and
the geologic materials of the confining layer? (Y/N)
5. Did the geologic assessment address or provide
means for resolution of any information gaps of
geologic data? (Y/N)
6. Do the laboratory data corroborate the field
data for petrography? (Y/N)
7. Do the laboratory data corroborate the field
data for mineralogy and subsurface geochemistry? (Y/N)
E. Presentation of geologic data
1. Did the owner/operator present geologic cross
sections of the site? (Y/N)
2. Do cross sections:
a. identify the types and characteristics of
the geologic materials present? (Y/N)
b. define the contact zones between different
geologic materials?
c. note the zones of high permeability or
fracture? (Y/N)
d. give detailed borehole information including:
o location of borehole? (Y/N)
o depth of termination? (Y/N)
o location of screen (if applicable)? (Y/N)
o depth of zone(s) of saturation? (Y/N)
o backfill procedure?
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9950.2
3. Did the owner/operator provide a topographic nap
which was constructed by a licensed surveyor? (Y/N)
4. Does the topographic map provide:
a. contours at a maximum interval of two-feet? (Y/N)
b. locations and illustrations of nan-nade
features (e.g., parking lots, factory
buildings, drainage ditches, storm drains,
pipelines, etc.)? (Y/N)
c. descriptions of nearby water bodies? (Y/N)
d. descriptions of off-site wells? (Y/N)
e. site boundaries? (Y/N)
f. individual RCKA units? (Y/N)
g. delineation of the waste management area(s)? (Y/N)
h. well and boring locations? (Y/N)
5. Did the owner/operator provide an aerial photo-
graph depicting the site and adjacent off-site
features? (Y/N)
6. Does the photograph clearly show surface water
bodies, adjacent nunicipalities, and residences
and are these clearly labelled? (Y/N)
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? (Y/N)
b. Were the well water level measurements taken
within a 24 hour period? (Y/N)
c. Were the well water level measurements taken
to the nearest 0.01 feet? (Y/N)
d. Were the well water levels allowed to stabilize
after construction and development for a mininium
of 24 hours prior to measurements? (Y/N)
e. Was the water level information obtained from
(check appropriate one):
o nultiple piezometers placed in single borehole?
o vertically nested piezometers in closely spaced
separate boreholes?
o monitoring wells
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9950.2
f. Did the owner/cperator provide construction
details for the piezometers? (Y/N)
g. How were the static water levels measured
(check itethod(s).
o Electric water sounder
o Wetted tape
o Air line
o Other (e)qplain)
h. Was the well water level measured in wells with
equivalent screened intervals at an equivalent
depth below the saturated zone? (Y/N)
i. Has the owner/operator provided a site water table
(potentionBtric) contour nap? If yes,
o Do the potenticmetric contours appear logical
and accurate based on topography and presented
data? (Consult water level data) (Y/N)
o Are ground-water flow-lines indicated? (Y/N)
o Are static water levels shown? (Y/N)
o Can hydraulic gradients be estimated? (Y/N)
j. Did the owner/operator develop hydrologic
cross sections of the vertical flow component
across the site using measurements from all wells? (Y/N)
k. Do the owner/operator's flow nets include:
o piezometer locations? (Y/N)
o depth of screening? (Y/N)
o width of screening? (Y/N)
o measurements of water levels from all wells
and piezometers? (Y/N)
2. Seasonal and temporal fluctuations in ground-water level
a. Do fluctuations in static water levels occur? (Y/N)
o If yes, are the fluctuations caused by any of
the following:
Off-site well pumping (Y/N)
Tidal processes or other intermittent natural
variations (e.g., river stage, etc.) (Y/N)
On-site well pumping (Y/N)
Off-site, on-site construction or changing
land use patterns (Y/N)
Deep well injection (Y/N)
Seasonal variations (Y/N)
Other (specify)
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9950.2
b. Has the owner/operator documented sources and
patterns that contribute to or affect the ground-
water patterns below the waste management? (Y/N)
c. Do water level fluctuations alter the general
ground-water gradients and flow directions? (Y/N)
d. Based on water level data, do any head differ-
entials occur that nay indicate a vertical flow
corrponent in the saturated zone? (Y/N)
e. Did the owner/operator implement means for
gauging long term effects on water movement that
may result from on-site or off-site construction
or changes in land-use patterns? (Y/N)
3. Hydraulic conductivity
a. How were hydraulic conductivities of the subsurface
materials determined?
o Single-well tests (slug tests)? (Y/N)
o Multiple-well tests (pump tests) (Y/N)
o Other (specify)
b. If single-well tests were conducted, was it done
by:
o Adding or removing a known volume of water, (Y/N)
or
o Pressurizing well casing (Y/N)
c. If single well tests were conducted in a highly
permeable formation, were pressure transducers
and high-speed recording equipment used to record
the rapidly changing water levela? (Y/N)
d. Since single well tests only measure hydraulic
conductivity in a limited area, were enough tests
run to ensure a representative measure of conduc-
tivity in each hydrogeologic unit? (Y/N)
e. Is the owner/operator's slug test data (if
applicable) consistent with existing geologic
information (e.g., boring logs)? (Y/N)
f. Were other hydraulic conductivity properties
determined? (Y/N)
g. If yes, provide any of the following data, if
available!
o Transndssivity _______
o Storage coefficient
o Leakage
o Permeability _____
o Porosity
o Specific capacity
o Other (specify)
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9950.2
4. Identification of the uppermost aquifer
a. Has the extent of the uppermost saturated zone
(aquifer) in the facility area been defined? If yes, (Y/N)
o Are soil boring/test pit logs included? (Y/N)
o Are geologic cross-sections included? (Y/N)
b. Is there evidence of confining (conpetent,
unfractured, continuous, and low permeability)
layers beneath the site? (Y/N)
o If yes, how was continuity demonstrated?
What is hydraulic conductivity of the confining unit
(if present)? CM/Sec
How was it determined?
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? (Y/N)
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 Methods
a. What drilling method was used for the well?
o Hollow-stem auger
o Solid-stem auger
o Mud rotary
o Air rotary
o Reverse rotary
o Cable tool
o Jetting
o Air drill with casing hammer
o Other (specify)
b. Were any cutting fluids (including water) or additives used
during drilling? (Y/N)
If yes, specify
Type of drilling fluid
Source of water used
Foam
Polymers
Other
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9950.2
c. Was the cutting fluid, or additive, identified? (Y/N)
d. Was the drilling equipment steam-cleaned prior to
drilling the well? (Y/N)
Other methods
Vfes compressed air used during drilling? (Y/N)
o If yes, was the air filtered to remove oil? (Y/N)
Did the owner/operator document procedure for
establishing the potentiometric surface? (Y/N)
o If yes, how was the location established?
Formation samples
o Were formation samples collected initially during
drilling? (Y/N)
o Were any cores taken continuous? (Y/N)
If not, at what interval were samples taken?
o How were the samples obtained?
- Split spoon
- Shelby tube
- Core drill
- Other (specify)
o Identify if any physical and/or chemical tests were
performed on the formation samples (specify)
2. Monitoring Well Construction Materials
a. Identify construction materials (by number) and diameters
(ID/OD)
Diameter
Material (ID/OD)
o Primary Casing
o Secondary or outside casing
(double construction)
o Screen
b. How are the sections of casing and screen connected?
o Pipe sections threaded
o Couplings (friction) with adhesive or solvent
o Couplings (friction) with retainer screws
o Other (specify)
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9950.2
Were the naterials steam-cleaned prior to (Y/N)
installation?
If no, how were the materials cleaned?
3. Well Intake Design and Well Development
a. Was a well intake screen installed? (Y/N)
o What is the length of the screen for the well?
o Is the screen manufactured? (Y/N)
b. Was a filter pack installed? (Y/N)
o What kind of filter pack was enployed?
o Is the filter pack compatible with formation
materials? (Y/N)
o How was the filter pack installed?
o What are the dimensions of the filter pack?
o Has a turbidity measurement of the well water ever
been made? (Y/N)
o Have the filter pack and screen been designed for
the in situ naterials? (Y/N)
Well development
Was the well developed? (Y/N)
o 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)
o 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)
b. Was a different seal used in the unsaturated zone? (Y/N)
If yes,
o Was this seal made with?
- Sodium bentonite (specify type and grit)
- Cement (specify neat or concrete)
- Other (specify)
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9950.2
o Was this seal installed by?
- Dropping iraterial down the hole and tamping
- Dropping material down the inside of hollow
stan auger
- Other (specify)
c. Is the upper portion of the borehole sealed with a
concrete cap to prevent infiltration from the surface? (Y/N)
d. Is the well fitted with an above-ground protective
device and bunper guards? (Y/N)
e. Has the protective cover been installed with locks to
prevent tanpering (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? (Y/N)
b. Hew far apart are the detection monitoring wells?
c. Does the owner/operator provide a rationale for the
location of each monitoring well or cluster? (Y/N)
d. Has the owner/operator identified the well screen
lengths of each monitoring well or clusters? (Y/N)
e. Does the owner/operator provide an explanation for
the vgell screen lengths of each monitoring well or
cluster? (Y/N)
f. Do the actual locations of monitoring wells or
clusters correspond to those identified by the
owner/operator? (Y/N)
2. Placement of Upgradient Monitoring Wells
a. Has the ovmer/operator documented the location of
each upgradient monitoring well or cluster? (Y/N)
b. Does the owner/operator provide an explanation for
the location(s) of the upgradient monitoring wells? (Y/N)
c. What length screen has the owner/operator employed in
the background monitoring well(s)?
Does the owner/operator provide an explanation for
the screen length(s) chosen? (Y/N)
Does the actual location of each background monitoring
well or cluster correspond to that identified by the
owner/operator? (Y/N)
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9950.2
I. Office Evaluation of the Facility's Assessment Monitoring Program
1. Does the assessment plan specify:
a. The number, location, and depth of wells? (Y/N)
b. The rationale for their placement and identify the
basis that will be used to select subsequent sampling
locations and depths in later assessment phases? (Y/N)
2. Does the list of monitoring parameters include all
hazardous waste constituents from the facility? (Y/N)
a. Does the water quality parameter list include other
important indicators not classified as hazardous
waste constituents? (Y/N)
b. Does the owner/operator provide documentation for
the listed wastes which are not included? (Y/N)
3. Does the owner/operator's assessment plan specify the
procedures to be used to determine the rate of con-
stituent migration in the ground-water? (Y/N)
4. Has the owner/operator specified a schedule of imple-
mentation in the assessment plan? (Y/N)
5. Have the assessment monitoring objectives been clearly
defined in the assessment plan? (Y/N)
a. Does the plan include analysis and/or re-evaluation
to determine if significant contamination has occurred
in any of the detection monitoring wells? (Y/N)
b. Does the plan provide for a comprehensive program of
investigation to fully characterize the rate and
extent of contaminant migration from the facility? (Y/N)
c. Does the plan call for determining the concentrations
of hazardous wastes and hazardous waste constituents
in the ground water? (Y/N)
d. Does the plan employ a quarterly monitoring program? (Y/N)
6. Does the assessment plan identify the investigatory
methods that will be used in the assessment phase? (Y/N)
a. Is the role of each method in the evaluation fully
described? ' (Y/N)
b. Does the plan provide sufficient descriptions of the
direct methods to be used? (Y/N)
c. Does the plan provide sufficient descriptions of the
indirect methods to be used? (Y/N)
d. Will the method contribute to the further characteri-
zation of the contaminant movement? (Y/N)
7. Are the investigatory techniques utilized in the assess-
ment program based on direct methods? (Y/N)
a. Does the assessment approach incorporate indirect
methods to further support direct methods? (Y/N)
b. Will the planned methods called for in the assessment
approach ultimately meet performance standards for
assessment monitoring? (Y/N)
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9950.2
c. Are the procedures well defined? (Y/N)
d. Does the approach provide for nonitoring wells
similar in design and construction as the detection
monitoring wells? (Y/N)
e. Does the approach employ taking samples during drill-
ing or collecting core sanples for further analysis? (Y/N)
8. Are the indirect methods to be used based on reliable
and accepted geophysical techniques? (Y/N)
a. Are they capable of detecting subsurface changes
resulting fran contaminant migration at the site? (Y/N)
b. Is the measurement at an appropriate level of
sensitivity to detect ground-water quality changes
at the site? (Y/N)
d. Is the method appropriate considering the nature
of the subsurface materials? (Y/N)
e. Does the approach consider the limitations of
these methods? (Y/N)
f. Will the extent of contamination and constituent
concentration be based on direct methods and sound
engineering judgment? (Using indirect methods to
further substantiate the findings) (Y/N)
9. Does the assessment approach incorporate any mathe-
matical modeling to predict contaminant movement? (Y/N)
a. Will site specific measurements be utilized to
accurately portray the subsurface? (Y/N)
b. Will the derived data be reliable? (Y/N)
c. Have the assumptions been identified? (Y/N)
d. Have the physical and chemical properties of the
site-specific wastes and hazardous waste constituents
been identified? (Y/N)
J. Conclusions
1. Subsurface geology
a. Has sufficient data been collected to adequately
define petrography and petrographic variation? (Y/N)
b. Has the subsurface geochemistry been adequately
defined? (Y/N)
c. Was the boring/coring program adequate to define
subsurface geologic variation? (Y/N)
d. Was the owner/operator's narrative description
complete and accurate in its interpretation
of the data? (Y/N)
e. Does the geologic assessment address or provide
means to resolve any information gaps? (Y/N)
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9950.2
2. Ground-water flowpaths
a. Did the owner/operator adequately establish the hori-
zontal and vertical cottponents of ground-water flow? (Y/N)
b. Were appropriate methods used to establish ground-
vater flowpaths? (Y/N)
c. Did the owner/operator provide accurate dccumenta-
tion? (Y/N)
d. Are the potentiate trie surface measurements valid? (Y/N)
e. Did the cwner/operator adequately consider the
seasonal and temporal effects on the ground-water? (Y/N)
f. Were sufficient hydraulic conductivity tests
performed to document lateral and vertical variation
in hydraulic conductivity in the entire hydrogeologic
subsurface below the site? (Y/N)
3. Uppermost aquifer
a. Did the owner/operator adequately define the upper- (Y/N)
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? (Y/N)
b. Are the samples representative of ground-water
quality? (Y/N)
c. Are the ground-water monitoring wells structurally
stable? (Y/N)
d. Does the ground-water monitoring well's design and
construction permit an accurate assessment of aquifer
characteristics? (Y/N)
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? (Y/N)
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 repre-
sentative of upgradient (background) ground-water
quality including any ambient heterogenous chemical
characteristics? (Y/N)
-38-
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9950.2
6. Assessment Monitoring
a. Has the owner/operator adequately characterized site
hydrogeology to determine contaminant migration? (Y/N)
b. Is the detection monitoring system adequately designed
and constructed to immediately detect any contaminant
release? (Y/N)
c. Are the procedures used to make a first determination
of contamination adequate? (Y/N)
d. Is the assessment plan adequate to detect, charac-
terize, and track contaminant migration? (Y/N)
e. Will the assessment monitoring veils, given site
hydrogeologic conditions, define the extent and
concentration of contamination in the horizontal and
vertical planes? (Y/N)
f. Are the assessment monitoring wells adequately
designed and constructed? (Y/N)
g. Are the sampling and analysis procedures adequate
to provide true measures of contamination? (Y/N)
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? (Y/N)
i. Are the data collected at sufficient frequency and
duration to adequately determine the rate of
migration? (Y/N)
j. Is the schedule of implementation adequate? (Y/N)
k. Is the owner/operator's assessment monitoring plan
adequate? (Y/N)
o If the owner/operator had to implement his
assessment monitoring plan, was it implemented
satisfactorily? (Y/N)
II. Field Evaluation
A. Ground-water monitoring system:
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 ) (Y/N)
B. Monitoring well construction:
1. Identify construction material
Material Diameter
a. Primary Casing
b. Secondary or
outside casing
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9950.2
2. Is the upper portion of the borehole sealed with iron-
Crete to prevent infiltration from the surface? (Y/N)
3. Is the well fitted with an above-ground protective
device? (Y/N)
4. Is the protective cover fitted with locks to
prevent tampering? (Y/N)
If a facility utilizes more than a single well design,
answer the above questions for each well design.
III. 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? (Y/N)
2. Are measurements taken to the 0.01 feet? (Y/N)
3. Vhat device is used?
4. Is there a reference point established by a licensed
surveyor? (Y/N)
5. Is the measuring equipment properly cleaned between
well locations to prevent cross contamination? (Y/N)
B. Detection of immiscible layers:
1. Are procedures used which will detect light phase
immiscible layers? (Y/N)
2. Are procedures used which will detect heavy phase
immiscible layers? (Y/N)
C. Sampling of immiscible layers:
1. Are the immiscible layers sampled separately prior to
well evacuation? (Y/N)
2. Do the procedures used minimize mixing with water
soluble phases? (Y/N)
D. Well evacuation:
1. Are low yielding wells evacuated to dryness? (Y/N)
2. Are high yielding wells evacuated so that at
least three casing volumes are removed? (Y/N)
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9950.2
3. What device is used to evacuate the wells?
4. If any problems are encountered (e.g., equipment
malfunction) are they noted in a field logbook? (Y/N)
E. Sample withdrawal:
1. For lew yielding wells, are sanples for volatiles, pH,
and oxidation/reduction potential drawn first after
the well recovers? (Y/N)
2. Are sanples withdrawn with either flurocarbon/resins or
stainless steel (316, 304 or 2205) sampling devices? (Y/N)
3. Are sampling devices either bottom valve bailers
or positive gas displacement bladder pumps? (Y/N)
4. If bailers are used, is fluorocarbon/resin coated wire,
single strand stainless steel wire, or monofilament used
to raise and lower the bailer? (Y/N)
5. If bladder pumps are used, are they operated in a
continuous manner to prevent aeration of the sample? (Y/N)
6. If bailers are used, are they lowered slowly to
prevent degassing of the water? (Y/N)
7. If bailers are used, are the contents transferred
to the sample container in a way that minimizes
agitation and aeration? (Y/N)
8. Is care taken to avoid placing clean sampling equip-
ment on the ground or other contaminated surfaces prior
to insertion into the well? (Y/N)
9. If dedicated sampling equipment is not used, is equip-
ment disassembled and thoroughly cleaned between
sanples? (Y/N)
10. If sanples are for inorganic analysis, does the clean-
ing procedure include the following sequential steps:
a. Dilute acid rinse (HNO3 or HC1)? (Y/N)
11. If samples are for organic analysis, does the cleaning
procedure include the following sequential steps:
a. Nonphosphate detergent wash? (Y/N)
b. Tap water rinse? (Y/N)
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9950.2
c. Distilled/deionized water rinse? (Y/N)
d. Acetone rinse? (Y/N)
e. Pesticide-grade hexane rinse? (Y/N)
12. Is sampling equipment thoroughly dry before use? (Y/N)
13. Are equipment blanks taken to ensure that sample
cross-contamination has not occurred? (Y/N)
14. If volatile sanples are taken with a positive gas
displacement bladder putp, are pumping rates below
100 ml/min? (Y/N)
F. In-situ or field analyses:
1. Are the following labile (chemically unstable) para-
meters determined in the field:
a. pH? (Y/N)
b. Temperature? (Y/N)
c. Specific conductivity? (Y/N)
d. Redox potential? (Y/N)
e. Chlorine? (Y/N)
f. Dissolved oxygen? (Y/N)
g. Turbidity? (Y/N)
h. Other (specify)
2. For in-situ determinations, are they made after well
evacuation and sample removal? (Y/N)
3. If sample is withdrawn from the well, is parameter
measured from a split portion? (Y/N)
4. Is monitoring equipment calibrated according to
manufacturers' specifications and consistent with
SW-046? (Y/N)
5. Is the date, procedure, and maintenance for equipment
calibration documented in the field logbook? (Y/N)
IV. Review of Sample Preservation and Handling Procedures
A. Sample containers:
1. Are sanples transferred from the sampling device
directly to their conpatible containers? (Y/N)
2. Are sample containers for metals (inorganics) analyses
polyethylene with polypropylene caps? (Y/N)
3. Are sample containers for organics analysis glass
bottles with fluorocarbonresin-lined caps? (Y/N)
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9950.2
4. If glass bottles are used for metals samples are
the caps fluorocarbonresin-lined? (Y/N)
5. Are the sample containers for metal analyses cleaned
using these sequential steps?
a. Nonphosphate detergent wash? (Y/N)
b. 1:1 nitric acid rinse? (Y/N)
c. Tap water rinse? (Y/N)
d. 1:1 hydrochloric acid rinse? (Y/N)
e. Tap water rinse? (Y/N)
f. Distilled/deionized water rinse? (Y/N)
6. Are the sample containers for organic analyses cleaned
using these sequential steps?
a. Nonphosphate detergent/hot water wash? (Y/N)
b. Tap water rinse? (Y/N)
c. Distilled/deionized water rinse? (Y/N)
d. Acetone rinse? (Y/N)
e. Pesticide-grade hexane rinse? (Y/N)
7. Are trip blanks used for each sample container type
to \«rify cleanliness? (Y/N)
B. Sample preservation procedures:
1. Are samples for the following analyses cooled to 4*C:
a. TOC? (Y/N)
b. TCK? (Y/N)
c. Chloride? (Y/N)
d. Phenols? (Y/N)
e. Sulfate? (Y/N)
f. Nitrate? (Y/N)
g. Coliform bacteria? (Y/N)
h. Cyanide? (Y/N)
i. Oil and grease? (Y/N)
j. Hazardous constituents (§261, Appendix VIII)? (Y/N)
2. Are samples for the following analyses field acidified to
pH <2 with HNO3:
a. Iron? (Y/N)
b. Manganese? (Y/N)
c. Sodium? (Y/N)
d. Total metals? (Y/N)
e. Dissolved metals? (Y/N)
f. Fluoride? (Y/N)
g. Endrin? (Y/N)
h. Lindane? (Y/N)
i. Msthoxychlor? (Y/N)
j. Toxaphene? (Y/N)
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k. 2,4, D? (Y/N)
1. 2,4,5, TP Silvex? (Y/N)
m. Radium? (Y/N)
n. Gross alpha? (Y/N)
o. Gross beta? (Y/N)
3. Are samples for the following analyses field acidified
to pH <2 with H2S04: (Y/N)
a. Phenols? (Y/N)
b. Oil and grease? (Y/N)
4. Is the sanple for TOC analyses field acidified to
pH <2 with HC1? (Y/N)
5. Is the sanple for TCK analysis preserved with
1 ml of 1.1 M sodium sulfite? (Y/N)
6. Is the sanple for cyanide analysis preserved with
NaOH to pH >12? (Y/N)
C. Special handling considerations:
1. Are organic sattples handled without filtering? (Y/N)
2. Are sanples for volatile organics transferred to
the appropriate vials to eliminate headspace over
the sanple? " (Y/N)
3. Are sanples for metal analysis split into two
portions? (Y/N)
4. Is the sanple for dissolved metals filtered
through a 0.45 micron filter? (Y/N)
5. Is the second portion not filtered and analyzed
for total metals? (Y/N)
6. Is one equipment blank prepared each day of
ground-vater sampling? . (Y/N)
V. Review of Chain-of-Custody Prodecures
A. Sanple labels
1. Are sanple labels used? (Y/N)
2. Do they provide the following infornation:
a. Sanple identification number? (Y/N)
b. Name of collector? (Y/N)
c. Date and tiro of collection? (Y/N)
d. Place of collection? (Y/N)
e. Parameter(s) requested and preservatives used? (Y/N)
-------
9950.2
3. Do they remain legible even if wet? (Y/N)
B. Sanple seals:
1. Are sanple seals placed on those containers to
ensure the samples are not altered? (Y/N)
C. Field logbook:
1. Is a field logbook maintained? (Y/N)
2. Does it document the following:
a. Purpose of sampling (e.g., detection or
assessment) ? (Y/N)
b. Location of well(s)? (Y/N)
c. Total depth of each well? (Y/N)
d. Static water level depth and measurement
technique? (Y/N)
e. Presence of immiscible layers and
detection method? (Y/N)
f. Collection method for iirmscible layers
and sample identification numbers? (Y/N)
g. Well evacuation procedures? (Y/N)
h. Sanple withdrawal procedure? (Y/N)
i. Date and time of collection? (Y/N)
j. Well sampling sequence? (Y/N)
k. Types of satple containers and sample
identification number(s)? (Y/N)
1. Preservative(s) used? (Y/N)
m. Parameters requested? (Y/N)
n. Field analysis data and method(s)? (Y/N)
o. Sample distribution and transporter? (Y/N)
p. Field observations? (Y/N)
o Unusual well recharge rates? (Y/N)
o Equipment malfunctions)? (Y/N)
o Possible sample contamination? (Y/N)
o Sampling rate? (Y/N)
D. Chain-of-custody record:
1. Is a chain-of-custody record included with
each sample? (Y/N)
2. Does it document the following:
a. Sample number? (Y/N)
b. Signature of collector? (Y/N)
c. Date and tiro of collection? (Y/N)
d. Sanple type? (Y/N)
e. Station location? (Y/N)
f. Number of containers? (Y/N)
g. Parameters requested? (Y/N)
h. Signatures of persons involved in the (Y/N)
chain-of-possession? (Y/N)
i. Inclusive dates of possession? (Y/N)
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9950.2
E. Sample analysis request sheet:
1. Does a sanple analysis request sheet acccrpany
each sarple? (Y/N)
2. Does the request sheet document the following:
a. Name of person receiving the sanple? (Y/N)
b. Date of sample receipt? (Y/N)
c. Laboratory sample number (if different than
field number)? (Y/N)
d. Analyses to be performed? (Y/N)
VI. Review of Quality Assurance/Quality Cbntrol
A. Is the validity and reliability of the laboratory
and field generated data ensured by a QA/QC program? (Y/N)
B. Does the QA/QC program include:
1. Documentation of any deviations from approved
procedures? (Y/N)
2. Documentation of analytical results for:
a. Blanks? (Y/N)
b. Standards? (Y/N)
c. Duplicates? (Y/N)
d. Spiked samples? (Y/N)
e. Detectable limits for each parameter
being analyzed? (Y/N)
C. Are approved statistical methods used? (Y/N)
D. _Are QC samples used to correct data? (Y/N)
E. Are all data critically examined to ensure it
has been properly calculated and reported? (Y/N)
VII. Surficial Well Inspection and Field Observation
A. Are the wells adequately maintained? (Y/N)
B. Are the monitoring wells protected and secure? (Y/N)
C. Do the veils have surveyed casing elevations? (Y/N)
D. Are the ground-water samples turbid? (Y/N)
E. Have all physical characteristics of the site been noted
in the inspector's field notes (i.e., surface waters,
topography, surface features)? (Y/N)
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9950.2
F. Has a site sketch been prepared by the field inspector
with a scale, north arrow, location(s) of buildings,
lccation(s) of regulated units, location of monitoring
wells, and a rough depiction of the site drainage pattern? (Y/N)
VIII. Conclusions
A. Is the facility currently operating under the correct
monitoring program according to the statistical analyses
performed by the current operator? (Y/N)
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? (Y/N)
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? (Y/N)
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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
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
uppermost aquifer
incorrect identification of certain
formations as confining layers or
aquitards
failure to use test drilling and/or
soil borings to characterize sub-
surface hydrogeology
failure to use piezometers or wells
to determine ground-water flow
rates and directions (or failure to
use a sufficient number of them)
failure to consider temporal varia-
tions in water levels when
establishing flow directions (e.g.,
seasonal variations, short-term
fluctuations due to pumping)
failure to assess significance of
vertical gradients whan evaluating
flow rates and directions.
failure to use standard/consistent
benchmarks when establishing
water level elevations
failure of the O/O to consider the
effect of local withdrawal wells on
ground-water flow direction
failure of the 0/0 to obtain suffi-
cient water level measurements
Regulatory
Citations
§265.90(a)
§265.91(3X1)
§270.14
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FIGURE 4.3 (continued)
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
failure of the O/O to consider the §265.90
-------
FIGURE 4.3 (continued)
9950.2
Examples of Basic
Elements Required
by Performance
Standards
Examples of Technical
Inadequacies that may
Constitute Violations
Regulatory
Citations
Background wells must be
constructed so as to yield
samples that are represen-
tative of in-situ ground-water
quality, (continued)
well screens used are of an inap- §265.90(a)
propriate length §265.9l(a)(l)
§265.91 (aX2)
wells developed using water other §265.90(a)
than formation water §265.91 (a)
improper well development §265.90(a)
yielding samples with suspended §265.91 (a)
sediments that may bias chemical
analysis
use of drilling muds or nonforma- §265.90(a)
tion water during well construction §265.91 (a)
that can bias results of samplea
collected from wells
5. Downgradient monitoring
wells must be located so as
to ensure the immediate
detection of any contamina-
tion migrating from the
facility
6. Oowngradient monitoring
wells must be constructed
so as to yield samples thai
are representative of in-situ
ground-water quality
wells not placed immediately adja-
cent to wast* management area
failure of O/O to consider poten-
tial pathways for dense
immiscibles
inadequate vertical distribution of
wells in thick or heavily stratified
aquifer
inadequate horizontal distribution
of wells in aquifers of van/ing
hydraulic conductivity
likety pathways of contamination
(e.g., buried stream channels.
fractures, areas of high
permeability) are not intersected
by wetls
wed network coven uppermost:
but not interconnected aquifers
See #4
§265.90(a)
§265.91 (aX2)
§265.9
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9950.2
Examplta of Basic
Elements Required
by Performance
Standards
Examples of Technical
inadequacies that may
Constitute Violations
Regulatory
Citations
7. Samples from
background and down-
gradient wells must be
properly collected and
analyzed
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 Ultra*
tion on samples to be analyzed
for volatile organic*)
use of an inappropriate sampling
device
use of improper sample preserva-
tion techniques
samples collected with a device
that is constructed of materials
that interfere with sample integrity
samples collected with a non-
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 sam-
ple caused by agitation of bailer)
§265.90(a)
§265.92(4)
§265.93
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FIGURE 4.3 (continued)
9950.2
Examples of Basic
Elements Required
by Performance
Standards
Examples of Technical
Inadequacies that may
Constitute Violations
Regulatory
Citations
Samples from background
and downgradient wells
must be properly collected
and analyzed (continued)
improper handling of samples
(e.g., failure to eliminate
headspace from containers of
samples to be analyzed for
volatile*)
failure of the sampling plan to
establish procedures for sampling
immiscible* (i.e., "floaters" and
"sinkers")
failure to follow appropriate
QA/QC 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-646)
failure to perform analysis in the
. field on unstable parameters or
constituents (e.g., pH, Eh, specific
conductance, alkalinity, dissolved
oxygen)
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(1)
§265.93(4X4)
§270.14(c)(4)
§265.90(a)
§265.92(8)
§26S.93(dX4)
§270.14
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9950.2
Examples of Basic
Elements Required
by Performance
Standards
Examples of Technical
Inadequacies that may
Constitute Violations
8. In Part 265 assessment
monitoring the O/O must
sample for the correct
substances
9. In defining the Appendix
VIII makeup of a plume the
0/0 must sample for the
correct substances
10. in Part 265 assessment
monitoring and in defining
the Appendix VIII makeup of
a plume the O/O must use
appropriate sampling
methodologies
11. Part 6 applicants who
have either detected con-
tamination or failed to imple-
ment an adequate part 265
GWM program must deter*
mine with confidence
whether a plume exists and
must characterize any
plume
Regulatory
Citations
failure of the 0/O's list of sam- §265.93(dX*)
pling parameters to include cer-
tain wastes that are listed in
§261.24 or §261.33. unless ade-
quate justification is provided
failure of the 0/O's list of sam- §265.93(dX4)
pling parameters to include
Appendix VII constituents of all
wastes listed under §§261.31 and
261.32. unless adequate justifica-
tion is provided
failure of the 0/O's list of sam- §270.l4(cX4)
pling parameters to include all
Appendix VIII constituents, unless
adequate justification is provided
failure of sampling effort to idewv §265.93(dX4)
tify areas outside the plume §270.i4(cX4)
* ; ,
number of wells was insufficient §265.93(dX4)
to determine vertical and horizon- §270.14
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