PROCEEDINGS OF A WORKSHOP ON
MONITORING CONSIDERATIONS IN THE SITING AND
OPERATION OF HAZARDOUS WASTE DISPOSAL FACILITIES
IN TEMPERATE ZONE WET ENVIRONMENTS
Prepared for:
3ohn D. Koutsandreas
Water and Waste Management Monitoring Research Division
Office of Monitoring Systems and Quality Assurance
Office of Research and Development
U.S. Environmental Protection Agency
Washington, D.C. 20460
Prepared by:
The Hazardous Waste Management Program
Institute of Science and Public Affairs
Florida State University
Tallahassee, Florida 32306
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
..„,, rt „ RESEARCH AND DEVELOPMENT
MAY 2 4 1984
Mr. Jack L. Wttherow
Environmental Engineer - Wastewater Management Branch
Robert S. Kerr Environmental Research Lab.
U.S. Environmental Protection Agency
P.O. Box 1198
Ada, Oklahoma ,74820
Dear Mr. Wither ow:
I am pleased to send you a copy of the "Proceedings of the Workshop
On Monitoring Considerations in the Siting and Operation of Hazardous
Waste Disposal Facilities in Temperate Zone Wet Environments" which was
co-sponsored by the U.S. Environmental Protection Agency (EPA) and the
Hazardous Waste Management Program of Florida State University (FSU).
Your participation was most valuable in helping the Office of Research
and Development understand the monitoring considerations in listing and
operating hazardous waste disposal facilities in temperate zone wet
environments. The cross section of participants included State, Regional,
industry, university and Federal Agency personnel. Through such meetings
and the exchange of valuable information, EPA's research planning and
products will be most responsive to the nation's needs for monitoring of
hazardous waste sites.
Due to the great success and your response to this workshop, plans
are being made to hold a similar type of workshop at the Florida State
University in the fall of 1984 dealing with RCRA, Subtitle D facilities.
Attendance will be by invitation. Details on this workshop are being
developed by Mr. John D. Koutsandreas, of my staff, and Dr. Roy C. Herndon
of FSU. For additional information, please contact Mr. Koutsandreas on
202-382-5791.
Your efforts and interest in environmental protection are appreciated.
Sincerely,
v
J&&
William J<
Director
Water and Waste Management
Monitoring Research Division
-------
PROCEEDINGS OF A WORKSHOP ON
MONITORING CONSIDERATIONS IN THE SITING AND
OPERATION OF HAZARDOUS WASTE DISPOSAL FACILITIES
IN TEMPERATE ZONE WET ENVIRONMENTS
Prepared for:
John D. Koutsandreas
Water and Waste Management Monitoring Research Division
Office of Monitoring Systems and Quality Assurance
Office of Research and Development
U.S. Environmental Protection Agency
Washington, D.C. 20460
Prepared by:
The Hazardous Waste Management Program
Institute of Science and Public Affairs
Florida State University
Tallahassee, Florida 32306
-------
NOTICE
This research planning document has not been peer and administratively
reviewed within EPA and is for internal agency use and distribution only.
11
-------
FOREWORD
Research and Development plays an important role in finding solutions to
environmental problems. The Office of Research and Development, U.S.
Environmental Protection Agency, has as one of its goals the identification of
improved technology and systems for the detection and prevention of
environmental problems through appropriate monitoring techniques. This
publication is one of the products of that research: a vital communications link
between the researcher and the user community.
On October 4-5, 1983, a workshop was held to discuss monitoring
considerations in the siting and operation of hazardous waste disposal facilities in
temperate zone wet environments. The workshop was cooperatively sponsored by
the U.S. Environmental Protection Agency and the Florida State University. The
objective of the workshop was to determine what monitoring and surveillance needs
exist and what research and development should be undertaken to support these
needs.
The workshop provided a forum for an exchange of information among
scientific experts on the monitoring and surveillance needs of hazardous waste
disposal facilities in wet environments. The discussion and presentations will assist
the Office of Research and Development in determining needed research programs,
identifying state-of-the-art research for evaluating the suitability of wet
environments for hazardous waste disposal facilities, and in determining special
monitoring considerations for facilities in wet environments. This report contains
the proceedings of the workshop and the position papers presented by invited
speakers.
in
-------
CONTENTS
Page
FOREWORD iii
I. INTRODUCTION 1
II. CONCLUSIONS AND RECOMMENDATIONS 2
III. WORKSHOP OVERVIEW 6
IV. EVALUATION TECHNIQUES FOR NEW SITES
IN WET ENVIRONMENTS (SESSION I) 16
V. SITE SELECTION/DENIAL CRITERIA FOR
SATURATED SOILS (SESSION II) 19
VI. SPECIAL WET ENVIRONMENT CONSIDERATIONS (SESSION III) 22
VII. MONITORING TECHNIQUES FOR OPERATING SITES (SESSION IV) 24
VIII. CONTAMINANT MIGRATION/PLUME TRACKING
MONITORING (SESSION V) 27
IX. QUALITY ASSURANCE CONSIDERATIONS (SESSION VI) 29
X. RESEARCH NEEDS TO IMPROVE SITE EVALUATION TECHNIQUES,
MONITORING TECHNIQUES, AND QUALITY ASSURANCE
(SESSION VII) 32
XI. CONCLUSION AND POLICY RECOMMENDATIONS (SESSION VIII) 34
APPENDIX A: DISCUSSION PAPERS A-l
APPENDIX B: WORKSHOP AGENDA B-l
APPENDIX C: WORKSHOP PARTICIPANTS C-l
-------
I. INTRODUCTION
Workshop Proceedings
These workshop proceedings are primarily a reflection of the responses from
the invited speakers and workshop participants concerning four specific issues
pertaining to hazardous waste landfill sites located in or near wetlands or in
saturated soils (hereafter referred to as wet environments). These issues are:
• What are the monitoring and surveillance needs?
• What research and development should be undertaken to support these
needs?
• What available monitoring and surveillance methods can be
recommended for use?
• What are the quality assurance requirements for ongoing monitoring and
surveillance programs?
Section I is a brief introduction that provides an overview of the paper
format. Section II lists the workshop conclusions and recommendations. Section III
presents comments concerning the overall objectives of the workshop and
summaries of federal laws and regulations as they relate to the issue of monitoring
hazardous waste disposal facilities in wet environments. The welcoming address by
Representative Don Fuqua, Chairman of the Science and Technology Committee,
and opening comments by Kenneth A. Shuster, Chief of the Land Disposal Branch,
Office of Solid Waste, U.S. Environmental Protection Agency (EPA), and John D.
Koutsandreas, with the U.S. EPA's Office of Research and Development, are also
included. Mr. Shuster and Mr. Koutsandreas presented the objectives and goals of
the workshop and outlined the program format. Sections IV through XI summarize
the individual workshop sessions. The appendices include the position papers by the
invited speakers, the workshop agenda, and a list of workshop participants.
-------
II. CONCLUSIONS AND RECOMMENDATIONS
This workshop has been summarized as a series of conclusions followed by
recommendations. As a result of the nature of the topics discussed, there was
considerable overlap among the workshop sessions. Much of the discussion included
comments on issues other than the four specific issues listed in the introduction of
these proceedings. Current monitoring and surveillance needs, as well as research
necessary to solve ongoing monitoring and hazardous waste management problems,
were discussed at length. The subject of available monitoring methods which could
be recommended for use was not covered in detail, except in terms of quality
assurance problems.
Conclusions and Recommendations
1. A standardized multidisciplinary approach to monitoring is needed to ensure
that the quality of monitoring data collected under varying conditions is
consistent.
Recommendation;
Develop and disseminate standard methodologies for groundwater moni-
toring and data collection.
Recommendation;
Develop quality assurance methods for both on-site installation of monitor-
ing systems and for laboratories which test under RCRA program require-
ments.
2. Location strategies concerning the siting of hazardous waste disposal facilities
should include those hydrogeological factors that are appropriate in order to
provide adequate environmental protection.
Recommendation;
Develop location strategies based upon monitoring data which take into
account all the parameters of a site. Location strategies should be flexible
enough not to rule out a site based solely on one parameter, such as depth to
the water table, if other parameters satisfactorily limit the rate and amount
of contaminant migration. On the other hand, these location standards must
be stringent enough to provide maximum protection to productive and
ecologically vital wet environments.
-------
Recommendation;
An important component in the siting of hazardous waste disposal facilities
involves the use of a technical advisory committee to review and develop
permitting requirements on a site-by-site basis. The composition of this
technical advisory committee should at least consist of environmental
chemists, hydrogeologists, biologists and soil scientists.
3. Proper hydrogeologic training and knowledge of field monitoring techniques is
required in order to adequately design and operate monitoring networks at
disposal sites in wet environments.
Recommendation:
Develop and provide additional training courses on the hydrogeologic aspects
of monitoring networks in wet environments. Incorporate in these training
courses state-of-the-art methodologies, technologies, and research findings.
Recommendation;
Implement a computerized groundwater monitoring data management
system that can be used to analyze monitoring data from proposed or
existing hazardous disposal sites. Designate EPA as the lead agency for
compilation and analysis of data.
4. As a result of the complexity, variability and dynamic nature of wet environ-
ments, monitoring procedures and requirements should be formulated so that
monitoring system plans can be developed to properly include all media through
which pollutants can influence the condition of the wet environment and its
ability to store wastes.
Recommendation;
Design multimedia systems that can be used for monitoring in most wet
environments. These systems including remote sensing, in situ sensing,
surface and ground water sampling, and biological monitoring.
5. Quick-look screening methods could help in determining whether in-depth
monitoring and analysis are necessary for a disposal site in a wet environment.
Data gathered from these methods could be used in developing location
standards for landfills in wet environments.
Recommendation;
Develop screening methods that can be used inexpensively to help evaluate
hazardous waste disposal sites located in wet environments.
6. Monitoring requirements should be developed for hazardous waste disposal sites
that may reside in the various types of wet environments. In addition,
monitoring requirements should be developed for existing hazardous waste
disposal sites as well as for facilities proposed to be sited proximate to wet
environments.
-------
Recommendation;
Develop monitoring requirements for existing and proposed hazardous waste
disposal sites in wet environments.
Recommendation;
Classify and prioritize wet environments based upon monitoring data. These
classifications and priorities should relate to the environmental and health
risks posed by each site.
7. The states and regions need technical guidance in order to properly review
permit applications and in order to properly advise new permit applicants
regarding the appropriate monitoring requirements for hazardous waste disposal
sites in or near wet environments.
Recommendation:
Develop a compendium of standard monitoring methods which can be
employed for site evaluation during the permitting process.
8. Workshop participants identified several areas in which research would benefit
their programs directly. These areas include the development of statistical
methqds for monitoring data analysis, detection methods for contaminant
movement in karst terrains, specialized instrumentation for monitoring wells,
and the design of monitoring networks at sites with groundwater gradient
reversals.
Recommendation;
Evaluate research potential for those areas identified by workshop partic-
ipants for future research by the U.S. EPA. Identify on-going and completed
research projects in these fields and provide this information to the states
and regions on a continuing basis.
9. More research is needed concerning the fate of contaminants in all natural
systems including wet environments.
Recommendation;
Initiate and/or continue research efforts in environmental chemistry of
hazardous waste mixtures, assimilative capacities of natural sites and
adequacy of current landfill design for long-term isolation of wastes.
10. A major need for evaluating the environmental impact of hazardous waste
facilities is the development of environmental and human health maximum
contaminant levels. Without these levels, monitoring data are difficult to
interpret and use in identifying dangers to human health or the environment.
-------
Recommendation;
Accelerate development of health and environmental standards for contam-
inants. It may be necessary to develop two maximum contaminant levels--
one level applicable to the environment to be used for cleanup purposes and
another level for human health concerns.
-------
III. WORKSHOP OVERVIEW
General Comments
The wet environments discussed in the workshop included saturated soils and
wetlands. The workshop provided a technology exchange among scientific experts
on the monitoring of hazardous waste disposal sites in wet environments. The
workshop was designed to assist EPA's Office of Research and Development and
Office of Solid Waste in determining needed research programs, in identifying
state-of-the-art research for evaluating a wet environment's suitability for hazard-
ous waste disposal facilities, and in determining special monitoring considerations
for those facilities in various wet environments. The existing regulations governing
the location of hazardous waste disposal sites may not be adequate for facilities
that are proposed to be located in wet environments.
Laws and Regulations Pertaining to Hazardous Waste Disposal in Wet Environments
The Resource Conservation and Recovery Act of 1976 (RCRA) and its
amendments require the U.S. Environmental Protection Agency (EPA) to regulate
hazardous waste activities. Under Subtitle C of RCRA, U.S. EPA has promulgated
regulations which provide (a) criteria to determine which wastes are hazardous; (b)
a system to track wastes from point of generation to point of disposal; and (c)
standards for the design and operation of disposal facilities. These regulations
identify a large number of individual wastes and process waste streams as
hazardous and also specify four characteristics--ignitibility, corrosivity, reactiv-
ity, and toxicity--for identifying other wastes as hazardous. The RCRA
regulations include floodplain and seismic location standards, but they do not
include hydrogeologic location standards.
The EPA has been directed to identify and clean up uncontrolled and
abandoned hazardous waste disposal sites. This effort includes the investigation
and monitoring of several thousand uncontrolled hazardous waste sites throughout
-------
the nation. Legislation entitled the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), commonly referred to as
"Superfund" legislation, has emphasized the need for expanded monitoring
activities.
Other Laws and Regulations
Section 404 of the Clean Water Act deals with wetlands acquisition and
dredge-and-fill activities in wetlands. Section 404(b)(l) of this Act promulgated by
the U.S. EPA defines "wetlands" as those areas that are inundated or saturated by
surface or ground water at a frequency and duration sufficient to support, and that
under normal circumstances do support, a prevalence of vegetation typically
adapted for life in saturated soil conditions. The Army Corps of Engineers and the
Environmental Protection Agency regulations dealing with dredge-and-fill
activities in wetlands impose three basic requirements: the proposed activity must
be water dependent; no feasible alternative sites must exist; and there must be no
unacceptable adverse impacts on the aquatic ecosystem. Both the Corps and the
EPA regulations are sufficiently flexible to allow alteration or destruction of
wetlands where the public interest compels it.
Executive Order 11990 (Protection of Wetlands) mandates that each agency
take action to minimize wetland destruction, degradation, or loss. Executive Order
11988 (Floodplain Management) pertains to federal activities and programs, includ-
ing water and related land resource planning, in floodplains. All federal actions,
including regulating and licensing activities, come within the purview of these
Orders. Department of Energy regulations under E. O. 11990 and E. O. 11988
provide for an environmental review of impacts on floodplains and wetlands in an
attempt to minimize wetland damage and loss; however, if no practicable alterna-
tive to locating an activity in these areas is found, then attempts to minimize
adverse effects from the activity are to be undertaken. Finally, the National
-------
Environmental Policy Act (NEPA) requires an Environmental Impact Statement
(EIS) for significant federal activities that may adversely affect the environment
including wet environments.
Permitting requirements for hazardous waste land disposal facilities were
issued in July, 1982 by the U.S. EPA. For floodplains, EPA concluded that
hazardous waste land disposal units preferably should not be located in 100-year
floodplains. However, if some are so located, they must either be designed to
prevent washout of hazardous waste by a 100-year flood or the hazardous waste
must be removed before flooding. An exemption from this requirement is possible
if the owner or operator can demonstrate that a washout would cause no adverse
effects on human health or the environment.
Wet Environments
The wet environments addressed in the workshop are of two types. The first
is the wetland, where the water table is at or above the land surface for extended
periods, creating certain natural landforms such as swamps, marshes, and bogs.
These, and other areas where soil is saturated by heavy rainfall and snowmelt, are
widespread in the United States. In addition to the vast expanses of wetlands that
exist in Louisiana and Alaska, many other states have extensive wetlands that
constitute valuable, sometimes unique, habitats for plants and animals and
frequently are associated with important human uses such as municipal water
supplies and sport and commericial fisheries.
The second type of wet environment under discussion in this workshop is that
of saturated soils. In many parts of the country, particularly the humid southeast,
the water table is at or near the land surface. In operating a hazardous waste
landfill, it may not be possible to maintain an unsaturated zone between the waste
and the water table and in this case the waste could possibly be found within the
saturated zone. In the event that a waste site was located in the saturated zone,
-------
extremely low soil permeability and groundwater flow rate would be desirable
characterisitics for the site.
Both types of wet environments require special monitoring and protection.
Wetlands are among the most productive of the major ecosystem types. Saturated
soils may be sources of recharge for groundwater aquifers used for water supply.
Many avenues of potential contamination exist in a wetland including surface water
flow thereby potentially affecting a large number of living organisms. This may
require biological as well as ground and surface water monitoring. In a saturated
soil environment with low permeability it may be difficult to obtain samples that
conform to standard protocols. By virtue of conditions that are peculiar to wet
environments, the usual monitoring approaches and techniques may have to be
expanded to include methods that will ensure that these areas are adequately
protected.
Monitoring Considerations
Implementation and enforcement of the RCRA and CERCLA regulations
require reliable monitoring tools. Of special concern are the requirements for
identification and delineation of waste sites, characterization of the composition
of wastes and waste sites, and detection of environmental contamination resulting
from hazardous waste operations. These areas present a range of problems that
are not easily addressed with current technology. For example, the waste may
include complex mixtures of hazardous substances ranging from concentrated
materials to dilute solutions. The waste may occur as a solid, semi-solid, or liquid
material, and it may be stored in containers, tanks, or basins, or placed in landfills,
surface impoundments (pits, ponds, or lagoons), or land treatment units.
-------
Monitoring often involves several approaches. Historical data, such as
archived photography and company records, can be used to help identify the
contents of an existing or abandoned facility, the boundaries of the site, and the
parties affected by the site. Physical data, including, for example, the location,
local meteorology, geology, and hydrology, can be used to identify immediate and
potential hazards to the surrounding environment. Chemical data are usually
required to identify wastes at the site and monitor the migration of toxic
substances away from the site. Biological monitoring methods can provide data to
help identify chemical hazards not readily detected from physical or chemical data
and these biological data can assist in the development of risk assessments.
Finally, epidemiological and medical data may help to identify the health effects
from a specific site and also to assist in the development of risk assessments.
An essential element in producing sound monitoring data is a good quality
assurance program. Methods used in well construction, sample collection and
preparation, and sample analysis must be standardized to enable comparison among
data collected at different facilities or at the same facility during multiple time
periods.
Comments by Don Fuqua, U.S. House of Representatives and Chairman of the
Science and Technology Committee (taped)
This important meeting is being held to discuss monitoring concerns with
regard to the siting and operation of hazardous waste disposal facilities in wet
environments. As you know, on May 19 and 26, 1983, and June 2, 1983, the Science
and Technology Subcommittee on Natural Resources, Agricultural Research, and
the Environment held hearings entitled "National Environmental Monitoring" on the
need to improve environmental monitoring. The purpose of the hearings was to
10
-------
review monitoring efforts concerning air, surface water, and groundwater
pollution, to identify problems, and to make recommendations leading to improved
environmental monitoring. The focus was not only on federal programs, but on
monitoring efforts nationwide. We received testimony from U.S. EPA, U.S.
Geological Survey (USGS), the Council on Environmental Quality as well as from
individuals representing the private sector. The problems concerning monitoring
identified during the hearings centered around the following areas: fragmentation,
quality assurance, lack of data, lack of continuity, and lack of policy direction and
goals.
Your meeting will focus on monitoring in relation to the siting and operation
of hazardous waste disposal facilities in wet environments. Many of the issues
discussed during the hearings will probably be discussed today along with many
more technical considerations. Certainly an area that deserves further discussion
is the need for additional research to provide guidance in the area of monitoring.
Perhaps one of the most important considerations is how to assure adequate quality
control of the monitoring data being collected. Some states such as Florida
contain many wetland areas. It is important for us to identify the strategies that
will effectively protect those resources. We must have an effective monitoring
system so that reliable data can be collected to help us make proper management
decisions especially as they relate to wet environments.
Comments by Kenneth A. Shuster, Office of Solid Waste, Land Disposal Branch,
U.S. EPA
I am the Chief of the Land Disposal Branch in the Office of Solid Waste and
am responsible for writing regulations for hazardous waste disposal facilities.
Current hazardous waste regulations although they do not specifically address
hydrogeologic settings do address, in terms of location, seismic areas and flood-
11
-------
plains. We know that lack of hydrogeologic criteria is one area of deficiency in the
regulations. For long-term protection, you need to address location, and then you
need to look at the design that is appropriate for that location and the types of
wastes to be disposed. That is, location, design and waste types must be considered
together. So, in a sense, our regulations are missing an important first step. We
believe that the current regulations, however, are protective in the sense that they
include a stringent liner requirement and stringent groundwater protection and
corrective action standards. These standards were developed with the
consideration that we did not have location standards, and further that we could
not develop the location standards within the time-frame specified in the court
order to develop the regulations.
We are now developing location standards and this process has three phases:
1. Identification of high risk sites. Sites that are categorized as high risk
include areas of high uncertainty such as karst terrain or fractured
bedrock (with insufficient overburden) where it is impossible to predict
groundwater flow. Sites are also categorized as high risk according to
aquifer characteristics and sensitivity, for example, recharge zones of
sole source aquifers. Under current regulations, we have the authority
to prohibit the development of facilities in locations of high risk due to
uncertainty since adequate monitoring systems cannot be developed,
but we do not have the authority to deny a site that is in a recharge
zone of a major aquifer.
2. Study of saturated soil settings. Preferred locations for waste facilities
typically have low permeability soils, and in areas of high precipitation
these are usually saturated soils. The problem here is to distinguish
between "good" and "bad" saturated soils in so far as waste facilities
are concerned.
12
-------
3. Study of preferred hydrogeologic settings (beyond those already ad-
dressed in phase 2).
It will take two or three years to develop location standards for a number of
reasons. The Administrative Procedures Act requires us to propose these
standards, to receive comments, and then to publish the standards in final form.
The physical characteristics of a site are also extremely important. For example,
the presence of a fractured bedrock does not necessarily mean the location is bad
because of uncertainty. You also have to consider the type and thickness of
overburden. The question also arises concerning which aquifers should receive
stringent protection such as locations bans and which aquifers should be protected
by technology and waste controls. How do you define the recharge zones of those
aquifers to be protected? If it is an extensive aquifer, perhaps certain portions of
the recharge zone are important and others, toward the discharge area, are less
important. Another area of controversy is the possible designation of sinks, that is,
aquifers that are already so contaminated or have a yield low enough that they are
impractical for use and therefore can be set aside for disposal. Since it will take
us so long to resolve these major policy issues and to finish the final regulations,
we plan to develop a guidance document for agency personnel to use to review
hazardous waste facility permit applications.
One area I have not yet mentioned is wetlands. We have traditionally
believed that wetlands are best regulated under Sections 402 and 404 of the Clean
Water Act. Because of a legal consideration called double jeopardy, we do not
specifically exclude the use of wetlands in our hazardous waste regulations.
Instead, we look to the Clean Water Act for such controls since it has sufficient
powers to exclude the use of major important wetlands. The question then, under
the Clean Water Act, is which wetlands should be protected from alteration.
13
-------
The focus of this workshop is monitoring. Monitoring includes site evaluation
for site selection and site evaluation for performance during and after operation.
But there are policy issues that have to be resolved before monitoring priorities
can be set, such as site selection criteria and protection standards. We need to
look at these policy and monitoring issues at the same time.
Comments by John D. Koutsandreas, Office of Research and Development, Water
and Waste Management Monitoring Research Division, U.S. EPA
The purpose of this workshop is to assist the Office of Research and
Development in planning needed monitoring research of hazardous waste sites in
saturated soils or wet environments. The goal of the workshop is to determine
what monitoring and surveillance needs exist, and what research and development
should be undertaken to support these needs. We hope to identify monitoring and
surveillance methods that are presently available and that can be recommended for
use. An important issue concerns identifying the quality assurance requirements
for on-going monitoring and surveillance programs.
There are a number of specific issues that need to be addressed during this
meeting. For example, it is important to determine how to best utilize information
gathered from the monitoring of existing hazardous waste disposal areas that are
located in or near wet environments. These data can assist the Office of Research
and Development in formulating monitoring requirements that are appropriate for
hazardous waste sites. In addition, it is important to identify those data
management systems that are needed to effectively utilize monitoring data on
state and regional levels. Finally, it will be important to take advantage of the
expertise of those individuals here today in order to assist the agency in
formulating regulations and standards concerning the monitoring of hazardous
waste facilities in or near wet environments. Other important issues may be
-------
introduced during the meeting, and I encourage everyone to actively participate in
these discussions.
-------
IV. EVALUATION TECHNIQUES FOR
NEW SITES IN WET ENVIRONMENTS (SESSION I)
Moderator; Mr. 3ack L. Witherow, Environmental Engineer, U.S. EPA,
Robert S. Kerr Environmental Research Lab, Ada, Oklahoma
Panel Members; Dr. G. Ronnie Best, Associate Director, Center for Wetlands,
University of Florida, Gainesville, Florida
Dr. Keros Cartwright, Head, Hydrology and Geophysics Section,
Illinois State Geological Survey, Champaign, Illinois
Dr. Rodney S. DeHan, Administrator, Groundwater Section,
Florida Department of Environmental Regulation, Tallahassee,
Florida
Mr. Witherow opened the session with a brief summary of some of the current
research projects at the U.S. EPA laboratory in Ada, Oklahoma. The Kerr
Environmental Research Lab is involved with groundwater protection research,
hazardous waste land treatment, wastewater land treatment, and wastewater
treatment in wetlands. The lab has completed a manual on groundwater
measurement techniques and has compiled information on site selection for
hazardous waste land treatment systems. Current research includes development
of bioassay techniques for hazardous wastes.
Four major issues were discussed during the first session:
The first issue concerned the question of why wet environments are even
being considered as disposal sites. As explained by EPA officials, RCRA
regulations, as written, do not necessarily prohibit siting of hazardous waste
facilities in wet environments. If an application for a facility includes proper
design criteria and flood protection, it cannot be denied because the site is located
in a wet environment. In practice, however, it is unlikely that hazardous waste
disposal facilities will be proposed in wet environments. From the experience of
the EPA Region IV RCRA Program, only four or five applications for new
hazardous waste facilities have been submitted for the entire southeast. In most
16
-------
cases, although the sites were well acceptable from a technical viewpoint, local
opposition, even in rural areas, caused termination of the projects even before the
permitting process was completed. None of these facilities was proposed for
location in an environmentally sensitive area such as a wetland.
The point was raised that the RCRA facility permitting process involves the
wasteful expenditure of money if applications for hazardous waste sites in
environmentally sensitive areas are inevitably turned down. The RCRA regula-
tions could be amended, for example, to eliminate wetlands from consideration
altogether. This gap may be partially filled by regulations currently being
considered that would allow regional EPA offices more authority to deny permits
based on site considerations and by state criteria, which may be more stringent
than the federal requirements.
The second issue discussed was that of cost effective monitoring. A major
point of contention was the role which economics should play in monitoring. The
example was given of a facility where proposed monitoring costs exceeded those
for operation and maintainence. It was agreed that there have been cases where
standards have been lowered to reduce monitoring costs thereby making facility
operation cost effective. Three major viewpoints concerning the second issue
emerged:
• There are areas where monitoring costs can be reduced. However,
some minimal amount of data is necessary to properly monitor each
site. It is important to know how the data will be used and what
resources are available to process the data prior to its collection in
order to make sure the data will be effectively utilized.
• It is possible for monitoring costs to exceed the costs of facility
operation and maintenance. The cost of monitoring should be consid-
ered as a part of the total cost of facility operation and not as a
17
-------
separate operation that can be eliminated or reduced if costs become
too high.
• A monitoring system should be evaluated solely on the quality of its
design and its utility. The decrease in monitoring to reduce overall
facility operation costs will in turn decrease the information collected
regarding ground and surface water quality at or near a site.
The third issue involves a concept from a paper presented by Kenneth J.
Quinn at the Sixth Annual Madison Conference of Applied Research and Practice
on Municipal and Industrial Waste, September 14 and 15, 1983. Quinn employed a
numerical model to evaluate the groundwater flow systems surrounding landfills
located within a saturated clay soil environment in order to define parameters that
would induce groundwater inflow to the landfill and limit or eliminate the potential
for leachate migration away from the facility. Quinn found that in his model
leachate outflow rates from a properly designed and sited facility in a saturated,
low permeability soil are substantially less than those possible from a clay-lined
site above the water table.
The fourth issue, which was raised, but not discussed in detail, was whether
wet environments have any special characteristics that make them attractive for
hazardous waste disposal. If there are properties of wet environments that can be
used to increase the amount of treatment or to hold contaminants more securely,
then the use of wet environments for hazardous waste disposal may be an
alternative management method. If, however, such areas could be irreparably
harmed by this use, then perhaps a different environment should be considered.
18
-------
V. SITE SELECTION/DENIAL
CRITERIA FOR SATURATED SOILS (SESSION II)
Moderator; Mr Ron Lee, Water Resources Assessment Team Leader, U.S.
EPA, Region X, Seattle, Washington
Panel Members; Dr. Robert P. Gambrell, Associate Professor, Center for Wetland
Resources, Louisiana State University, Baton Rouge, Louisiana
Mr. James 3. Geraghty, President, Geraghty and Miller, Inc.,
Tampa, Florida
Dr. Forest O. Mixon, Vice President, Research Triangle Institute,
Research Triangle Park, North Carolina
Session II began with a discussion of conflicting responsibilities for wetland
protection under RCRA and various provisions of the Clean Water Act. Much of
the discussion was not directly related to the session topic. The consensus was that
the issues raised concerning this responsibility have yet to be resolved and were
outside the scope of the meeting. The following conclusions were reached:
• "Hazardous waste" as used during this workshop means hazardous waste
as defined by RCRA with all of the exclusions contained within that
definition (e.g. radiological waste).
• "Waste disposal facilities" are not limited to landfills but also include
surface impoundments, land treatment facilities, and waste piles. Some
of these can be considered as short-term facilities. An example is a
surface impoundment which may be used for storage for a finite period
of time, after which the waste is removed and the site closed. Others,
such as landfills, involve the permanent placement of hazardous materi-
als and will require long-term maintenance and monitoring. It would be
expected that different types of facilities would have different selec-
tion and monitoring criteria and requirements.
19
-------
Four major points were developed:
1. Many hazardous waste sites are located in wet environments or
adjacent to them. It was suggested that existing facilities in wet
environments be studied concerning monitoring needs. Information on
existing sites could be used to identify potential problems in areas with
similar characteristics. Further, this information could be useful in
evaluating permit applications for new facilities in or near wet environ-
ments.
2. Hydrogeological evaluation of the site, including baseline monitoring of
ambient conditions, is limited by the lack of testing involving the actual
discharge of waste to the system. Injectivity testing required by the
state of Florida for permitted deep injection wells was given as an
example. There may be a need for a research effort to determine
whether evaluation requirements should include limited discharge of
waste into the site environment to test attenuation properties of the
system before the facility is permitted.
3. Hazardous wastes are composed of a multitude of chemical compounds.
The environmental chemistry of one compound under a given set of
conditions may be very different from the behavior of another
compound. For example, some chemical compounds may be effectively
contained by a clay layer while others may permeate it. In addition,
waste interactions can be very complex and lead to the formation of
additional hazardous products.
4. In some states such as Texas, large areas of saturated clay soil exist
that are characterized by extremely low groundwater flow rates and
low permeability. Such deposits, although saturated, do not yield
sufficient quantities of ground water to be considered as aquifers. If
20
-------
these deposits are homogeneous, laterally continuous, and sufficiently
thick, they may be suitable as disposal sites for hazardous waste. In
other states, such as Florida, soils are more permeable and groundwater
flow rates more rapid. The question was raised whether attenuation
properties of the saturated soils surrounding the waste materials in
either situation could be considered as a part of the treatment system.
21
-------
VI. SPECIAL WET ENVIRONMENT CONSIDERATIONS (SESSION III)
Moderator: Mr. William Mason, Aquatic Ecologist, U.S. Environmental
Protection Agency, Washington, D.C.
Panel Members; Mr. Irwin H. Kantrowitz, District Chief, U.S. Geological Survey,
Tallahassee, Florida
Dr. C.R. Lee, Chief, Environmental Mobility and Regulation
Criteria Group, Waterways Experiment Station, Vicksburg,
Mississippi
Dr. Robert 3. Livingston, Professor, Department of Biological
Sciences, Florida State University, Tallahassee, Florida
Session III focused on the special monitoring requirements for facilities
located in wet environments. There was agreement among many of the partici-
pants that wet environments typically should not be used for the disposal of
hazardous waste. Two points were raised regarding existing hazardous waste
disposal sites in wet environments:
1. A wetland that is a groundwater discharge point is not a suitable place
to dispose of hazardous waste. Often, the predominant flow of water
from the site is surface water which requires periodic monitoring.
Contamination of surface water would have a significant potential for
adversely affecting human health as well as fisheries and other
resources.
2. Wetlands are typically complex and extremely dynamic hydrogeologic
and ecological systems. The physical structure of wetlands are
susceptible to change if perturbed by natural phenomena. For example,
a flood may significantly change, or even relocate, a wetland system.
Even without major perturbations, wetland systems naturally change
their physical structures over time, or they may be altered due to
dredging and development activities.
22
-------
The following points were also raised in the discussion:
1. There are many types of wet environments, each with its own ability to
assimilate pollutants. Wetlands should be defined and categorized
based upon various criteria and in terms of proposed uses. The Army
Corps of Engineers, the Fish and Wildlife Service, and the Soil
Conservation Service are currently working together to document,
catalog, and assign values to wetlands according to a number of
criteria.
2. An important monitoring problem concerns the lack of standard proce-
dures and techniques. Data collected by different agencies at the same
site may not be comparable due to the use of different methods.
3. It was noted that facilities may be sited in wetlands and used for
disposal purposes because of private financial considerations, and these
financial considerations may be viewed by the facility owner as being
more important than environmental concerns. It was stated that it is
prudent to consider more than the private costs (e.g. the cost of the
land, the cost of the disposal facility and cost of transportation, etc)
when evaluating the overall benefits and costs of facility operations.
Other external costs, including the potential for site remediation,
should also be considered.
4. Research needs include investigations of existing hazardous waste sites
in wet environments to determine the effects of waste constituents on
these areas.
23
-------
VII. MONITORING TECHNIQUES FOR OPERATING SITES (SESSION IV)
Moderator; Mr. John Koutsandreas, Water and Waste Management Monitoring
Research Division, Office of Research and Development, U.S.
EPA, Washington, D. C.
Panel Members; Dr. Wayne A. Pettyjohn, Professor, Department of Geology,
Okalahoma State University, Stillwater, Oklahoma
Dr. Forest O. Mixon, Vice-President, Research Triangle Institute,
Research Triangle Park, North Carolina
Dr. G. Ronnie Best, Associate Director, Center for Wetlands,
Gainesville, Florida
Mr. Koutsandreas opened the session with a brief summary of the types of
research concerning groundwater monitoring presently being conducted by the
Office of Research and Development. Current projects include work in the
following areas:
1. Well construction methods, including investigation of casing materials,
well flushing techniques, sample preparation, and sample analysis
quality assurance;
2. Well location and the design of monitoring well networks;
3. Indicator parameters;
4. Geophysical monitoring methods, including down looking radar, seismic
methods and electromagnetic conductivity;
5. Application of fiber optics to groundwater monitoring;
6. Groundwater tracers;
7. Use of remote sensing for monitoring; and
8. Statistical methods for use in data interpretation.
Mr. Koutsandreas requested that workshop participants limit the discussion in
this session to existing sites and that they examine the monitoring necessary to
collect data for closure and clean up. He reminded the audience that the
-------
discussion would include not only wetlands but also disposal sites in other types of
wet environments. During this session, the following issues were discussed:
1. The costs of a monitoring system are primarily attributable to the long-
term cost of sample analysis and not to the costs of well construction.
At some facilities it may be necessary to conduct monitoring programs
for many decades. In order to limit the number of wells to be sampled
over the long-term, it may be prudent to initiate a comprehensive well
placement program from which to select the best wells for long-term
monitoring
2. There are inherent problems in using the four RCRA indicator
parameters (pH, specific conductance, Total Organic Carbon (TOC), and
TOX) because of natural variability of these parameters within the
hydrologic system. Rapid localized changes in shallow groundwater
quality due to natural phenomena such as rainfall or seasonal changes
are common. Research is showing that pH at the same site can vary
significantly, while specific conductance and TOC can vary to a lesser
degree. These four RCRA indicator parameters may indicate contami-
nation where none exists and conversely may fail to identify contami-
nated sites.
3. Biological analysis, not presently required by RCRA, may be a valuable
monitoring tool. Biota can concentrate contaminants in sufficient
quantities to indicate that a release into the environment is taking
place before it can be detected by other monitoring methods. Micro-
biological methods can be especially economical relative to more
conventional techniques. A sample could be taken when a well is first
installed and analyzed for types and numbers of microbes. Any
subsequent analysis that detects a change in the microbial population
25
-------
relative either to the initial sample or the microbial populations of
background well samples may indicate contamination.
4. The first task in properly developing a monitoring system is to establish
its specific purpose. This will vary from site to site and may also vary
through time at the same site.
5. Monitoring systems must be site specific to adequately reflect both the
stressed and unstressed hydrologic system.
6. Monitoring systems must be operated in such a way as to allow the
collection of data which can be used to fulfill monitoring requirements.
Ideally, the data collected could also be used for other purposes, such as
regional studies or the development of case histories.
7- Without a clear understanding of the hydrogeologic system, it is not
possible to design and operate a monitoring system effectively. A
major problem in this area is the lack of general hydrogeologic
knowledge.
8. Computer models have been developed to simulate hydrologic systems.
The complexity of these real systems may not be adequately repre-
sented in these models. Improved modeling is needed to better
represent the actual hydrologic system.
26
-------
VIII. CONTAMINANT MIGRATION/PLUME
TRACKING MONITORING (SESSION V)
Moderator: Dr. Walter Grube, Soil Scientist, Solid and Hazardous Waste
Research Division, U.S. EPA, Cincinnati, Ohio
Panel Members; Dr. Rodney DeHan, Administrator, Groundwater Section, Florida
Department of Environmental Regulation, Tallahassee, Florida
Dr. Keros Cartwright, Head, Hydrology and Geophysics Section,
Illinois State Geological Survey, Champaign, Illinois
Dr. Robert P. Gambrell, Associate Professor, Center for Wetland
Resources, Louisiana State University, Baton Rouge, Louisiana
Dr. Grube opened the session by describing some of the RCRA and CERCLA
related research presently underway at the U.S. EPA Cincinnati laboratory.
Current projects include investigation of facility design practices and site regula-
tions, and compilation of technical handbooks on the applicability and effectiveness
of available engineering technology to hazardous waste site remedial action.
In this session the following discussion took place:
1. For many contaminants, there are no standards, either promulgated by
states or by EPA. When a facility owner is requested to clean up a site,
there may be no established levels against which the site leachate
concentrations can be evaluated. The regulator may be left to make a
decision based on a meager data base. The resolution of differences
between a state regulatory agency and a facility owner faced with
cleanup costs may require data showing direct effects of contaminants
on human health and these toxicological linkages have yet to be
determined for many contaminants. For some compounds, taste and
odor threshholds may be of assistance in setting standards. Although
the water may be potable, its taste, odor or appearance may render it
unpalatable. In such cases the taste or odor threshhold could be used in
conjunction with other parameters.
27
-------
2. A better understanding of the chemistry of waste mixtures in wet
environments is needed in order to determine the fate of these
contaminants.
3. Biological monitoring could serve as an effective backup system to the
primary monitoring system. Groundwater monitoring should not be the
only detection system.
4. Research needs in the area of contaminant migration include:
a. More research in the detection of contaminant movement in karst
terrains.
b. More work on the development of specialized instrumentation for
wells, such as electronic contamination sensors which can be left
in the well or organic vapor sensitive devices which could be
installed in the well and removed periodically for laboratory
analysis.
c. Design of monitor well networks in sites with groundwater
gradient reversals. This would include river floodplains, where
shallow groundwater flow direction could change with the stage of
the river, coastal areas influenced by tidal changes and special
situations such as occur in the Biscayne Aquifer of South Florida
where groundwater flow directions may fluctuate with rainfall.
Since RCRA specifies the construction of upgradient and down-
gradient wells, some guidance is needed for sites which have
changing flow directions. One suggestion was that downgradient
be defined as the area needing the most protection.
The consensus of the workshop participants in this session was that the most
important factor in tracking of contaminants is a clear and thorough understanding
of the hydrogeologic system.
28
-------
IX. QUALITY ASSURANCE CONSIDERATIONS (SESSION VI)
Moderator; Mr. Douglas McCurry, Chief, Waste Engineering Section, U.S.
EPA, Region IV
Panel Members; Mr. James 3. Geraghty, President, Geraghty and Miller, Inc.,
Tampa, Florida
Dr. C.R. Lee, Chief, Contaminant Mobility and Regulation
Criteria Group, Waterways Experiment Station, Vicksburg,
Mississippi
Mr. Irvin H. Kantrowitz, District Chief, U.S. Geological Survey,
Tallahassee, Florida
Mr. McCurry provided some background information on the RCRA permitting
program in Region IV with special emphasis on the groundwater well monitoring
component of the program. The concern of the agency centers around the
placement of the upgradient and downgradient wells. An important issue concern-
ing well placement involves delineation of the aquifer flow pattern. In addition,
the quality of well construction may affect the accuracy of groundwater
monitoring data.
A RCRA treatment/storage/disposal facility permit is typically issued for an
existing facility in two parts: for Part A (interim) and Part B (permanent). If
contamination is detected prior to the Part B phase of the application process, then
applicants are required to complete a thorough groundwater study to determine the
exact nature and extent of the contamination. This requires the applicant to
gather data on the geology, topography, hydrology, and also to test for the
presence of contaminants listed in RCRA rules and regulations. Upon issuance of
the (Part B) permit, applicants embark upon either a corrective action program or
a compliance monitoring program. A program of corrective action requires the
applicant to reduce contaminant levels below groundwater standards. Once
groundwater standards are met, the applicant must implement a compliance
29
-------
monitoring program. The issue of assuring the quality of data necessary to
properly regulate the activities of applicants for RCRA permits is of critical
concern for the overall permitting program.
The decision to require applicants to implement these various programs is
based on the data gathered by the applicant. The quality or reliability of the data,
from the perspective of the permitting agency, depends upon how the applicant
both collects the data and reports the results. Reporting of monitoring data is an
area of concern because the programs require "self-monitoring." The objectivity of
the monitoring methods used by applicants or consultants hired by the applicant is
also of concern to the agency. Currently, there is no quality assurance program
applied to labs conducting groundwater analysis under RCRA regulations.
A number of issues dealing with quality assurance of monitoring data were
discussed after Mr. McCurry's comments. Four areas of concern were identified:
1. Consultants and testing laboratories vary considerably in terms of
expertise, sampling and analysis techniques, and consistency. These
variations present major obstacles to the assurance of quality
monitoring data and results.
2. There may be a need for the agency to certify laboratories that monitor
wells and test samples under RCRA program requirements. A program
similar to that used to certify laboratories under the Water Supply
Program might be appropriate. It may be necessary for the agency to
develop long-term contracts with selected laboratories, both publicly
and privately owned, to provide greater consistency in monitoring and
data analysis.
30
-------
3.Further guidance is needed concerning standardized monitoring and
analysis methods. Guidelines already exist in various agency manuals,
both from the Office of Solid Waste and the Office of Research and
Development, but these guidelines may not always be consistent.
Quality assurance requirements need to be implemented for site
monitoring.
31
-------
X. RESEARCH NEEDS TO IMPROVE
SITE EVALUATION TECHNIQUES, MONITORING
TECHNIQUES, AND QUALITY ASSURANCE (SESSION VII)
Moderator; Mr. Victor Lambou, Aquatic Biologist, Environmental Monitoring
Systems Laboratory, U.S. EPA, Las Vegas, Nevada
Panel Members; Dr. C.R. Lee, Chief, Contaminant Mobility and Regulation
Criteria Group, Ecosystems Research and Simulation Division,
Waterways Experiment Situation, Vicksburg, Mississippi
Dr. Robert J. Livingston, Professor, Department of Biological
Sciences, Florida State University, Tallahassee, Florida
Dr. P.O. Mixon, Vice President, Research Triangle Institute,
Research Triangle Park, North Carolina
Mr. Lambou began the session by asking a number of questions concerning
monitoring research needs. He asked whether there exists sufficient knowledge
concerning the basic design of monitoring systems and the subsequent use of the
data generated by these systems. It was suggested that additional research is
needed to improve the design of monitoring systems. A second question involved
the classification of wet environments. Mr Lambou asked whether further research
is necessary in order to better classify them. A third question asked by Mr.
Lambou concerned the need for a list of monitoring research priorities.
During this session, the following discussion took place:
1. There should be a lead agency to evaluate all of the monitoring data
being generated by various sources. It was suggested that EPA should
be that lead agency. Data from federal sources, state and local
entities, environmental impact statements, and existing data bases such
as STORET and WATSTOR could be combined into a central system,
evaluated, and then used to generate models for the prediction of
contaminant migration in various environments. The evaluation could
include compilation of a directory of information of all groundwater
monitoring efforts.
32
-------
2. As a result of the need to protect human health and the environment,
data analysis should provide information on how human health is
adversely affected by hazardous waste mismanagement. There are two
aspects related to the protection of human health. One is the degree or
level of exposure, which is relatively easy to monitor, model, and
analyze. The other is the effect of that exposure, which is more
difficult to assess.
3. Research programs on human health effects are long, expensive, and
difficult to design. The necessary funding should be appropriated to
conduct research to provide technical data to decision makers for the
evaluation of health related issues.
4. Sample collection and data analysis should be standardized. For
example, a problem with using existing data is that different methods
were used for their collection and, thus, comparison among data is
difficult.
5. More data are needed on wet environments in order to better classify
them in terms of their suitability for hazardous waste disposal. The
factors that control movement of contaminants in a wet environment
should be evaluated.
6. Research on the fate of contaminants in all types of environments is
needed.
7. Additional research is needed concerning the development of new
techniques to monitor hazardous waste landfills.
33
-------
XI. CONCLUSIONS AND POLICY RECOMMENDATIONS (SESSION VIII)
Moderator; Mr. Kenneth A. Shuster, Chief, Land Disposal Branch, Office of
Solid Waste, U.S. EPA, Washington, D.C.
Panel Members; Dr. G. Ronnie Best, Associate Director, Center for Wetlands,
University of Florida, Gainesville, Florida
Dr. Wayne A. Pettyjohn, Professor, Department of Geology,
Oklahoma State University, Stillwater, Oklahoma
Dr. Keros Cartwright, Head, Hydrogeology and Geophysics
Section, Illinois State Geological Survey, Champaign, Illinois
Session VIII focused on conclusions and policy recommendations. Several
important issues from previous sessions were raised during this session. The
conclusions and recommendations from this session were combined with those of
other sessions to produce the following Section XI, which provides a summary of
the workshop discussions.
Mr. Shuster began Session VIII by discussing the issues concerning the
development of hazardous waste disposal sites in saturated zones. By way of
example, he discussed the issue concerning a minimum distance between the base
of the landfill and the water table. Typically, the distance recommended is 20 or
30 feet of unsaturated soil. It was noted that this condition alone does not ensure
protection of ground water. For example, in humid areas there may be 30 feet of
unsaturated soil between a potential landfill base and the water table but these
soils are typically unsaturated because of their porosity or permeability (i.e. they
often are sandy soils or gravel). These highly permeable soils allow rapid
percolation of water from the surface to the water table and are often important
aquifer recharge zones. This rapid flow of leachate would allow for little
attenuation of wastes. Thus the effectiveness of a 30 foot buffer between the base
of the landfill and the water table is dependent upon soil type and characteristics.
-------
Better hydrogeologic settings for disposal sites are generally found in areas
with soils of low permeability, but in humid areas these low permeability soils tend
to be saturated. Low permeability soils tend to be clays and the rate of flow
through them can be extremely low. The slow movement of leachate through these
soils allows for a greater degree of waste attenuation and degradation. In addition,
these clays in humid areas do not yield appreciable quantities of water, which
precludes their use as a water supply source.
This discussion illustrates that depth to the water table is not the only
consideration in the siting of hazardous waste facilities, and may even result in a
selection of a worse site. Other factors such as the porosity and permeability of
the soils, the transmissivity of the aquifers, the groundwater flow gradient, and the
groundwater flow pattern both at the site and on a regional level are important.
The level of the potentiometric surface the presence or absence of a confining bed
or a highly permeable lens, the location of the closest usable ground water, and the
location of recharge and discharge zones also should be considered.
There are four general siting conditions that a hazardous waste facility must
meet. First, the site location should minimize uncertainty and risk. Second, the
facility design and location must generally provide for containment and isolation of
waste and leachate. Facility design criteria for containment (i.e., liners and
leachate collection and removal systems) have already been developed. The
selection of a site should maximize isolation of the waste from the environment.
Third, site selection criteria should help to minimize long-term environmental
impacts. Fourth, the ability to correct failures must be considered.
The first step in implementing a location standard involves the identification
of those hydrogeologic settings that pose a high risk. For example, high risk sites
include recharge zones for major aquifers, those hydrogeologic settings which
provide for high operational risk due to certain karst terrains and fractured
35
-------
bedrock, etc. Such sensitive hydrogeologic settings would not meet the location
standard and, therefore, would be prohibited for use for disposal. The second step
would involve an evaluation of the sites not eliminated in step one. This evaluation
would examine each site hydrogeologically in terms of its ability to contain and
isolate the wastes. Different criteria would be used to evaluate sites located in
saturated soils and in unsaturated soils.
There are several different ways in which a location standard could be
applied. One way would be to compile a national map, generally showing areas
with "good" locations and areas with "bad" locations. This approach is useful as a
general screening approach but obviously impractical as a regulatory tool.
Location decisions must be based on a number of very site-specific factors. There
are three other approaches that can be used. The first would be to describe
hydrogeologic environments that are acceptable in terms of permeability, porosity,
soil type, etc. The second approach would be to identify areas or sites based on
flow rates. A facility would be required to demonstrate that during a certain time
period (e.g. 500 years), there would not be a flow of water from the facility to a
point of concern, such as a water supply well, spring, or surface water body. The
third approach would be to develop a rating system whereby the best combination
of all site related factors could be selected and judged as being acceptable or
unacceptable.
There are a few points that should be considered in the use of any of these
approaches. First, it is generally easier to consider the flow of water rather than
the flow of contaminants. It is difficult to predict the flow of chemicals due to
attenuation factors. Generally, the flow of water is faster than the flow of
contaminants and so use of the flow of water would yield more conservative site
evaluations. A second problem area involves the evaluation of hydrogeologic
systems. Many hydrogeologic systems are complex, with heterogeneous soil
36
-------
profiles and complex flow lines that are difficult to define. The selection process
should generally encourage the selection of areas that are already contaminated,
are isolated, and/or are so low in yield as to be impractical for use. A third point
concerns design standards. Current facility design standards have been developed
under the assumption that location criteria would not be used and as a result sites
could possibly be located in very poor hydrogeological settings. More stringent
location standards may allow some design standards, such as the requirement for
synthetic liners in tight clay soils, to be less stringent or unnecessary.
After Mr. Shuster's opening remarks, the following discussion took place:
1. In order to properly develop monitoring systems, it is necessary to first
conduct basic research to provide information concerning the properties
of soils and subsurface materials typically found in wet environments.
For example, the attenuation properties, as well as subsequent degra-
>--
dation and dispersion effects of soils and other subsurface materials,
are not fully understood.
2. Monitoring must be based on a sound, fundamental understanding of the
hydrogeology that exists at the site. Studies of a site's hydrogeology
should include an examination of the physical characteristics of the
subsurface materials, the hydraulics of the flow system, the composi-
tion and volume of waste, and the physical, chemical and biological
controls that influence waste migration and degradation. It is evident,
therefore, that the design of monitoring systems should reflect site-
specific conditions.
3. In order to design and maintain monitoring systems, investigators should
have a fundamental understanding of the entire hydrogeologic system.
There are too few individuals who are properly trained to deal with the
37
-------
present hydrogeologic problems. There is a need for increased training
and education in this area by means of short courses, workshops,
manuals, specific university programs, etc.
4. One of the problems that must be examined is whether a site should be
chosen for its suitability or whether engineering modifications should be
mandated that would make any site suitable for the placement of a
hazardous waste facility. A disposal facility should be sited in a
location that would provide natural advantages and minimize long-term
maintenance. As a result of the uncertainty of the long-term integrity
of current engineered features of disposal facilities, the hydrogeologic
setting is of primary importance in assuring long-term protection. A
short-term storage site could be placed in less than optimum
environmental conditions and could rely upon engineering modifications
for the containment of the hazardous materials.
5. Site location standards should not only be based upon geology but also
upon climate of the area. Regions where the rate of evapotranspiration
is greater than the rate of precipitation have less potential for leachate
development and migration.
6. Regulations and guidance concerning hydrogeologic evaluation and site
selection are necessary to provide for the protection of human health
and the environment at waste disposal facilities.
7- One approach for evaluating a permit application for a hazardous waste
disposal facility would be the use of a technical advisory committee for
site planning. The lead permitting agency could invite other agencies
to review permit applications in order to achieve a consensus about the
suitability of the proposed site and the facility design.
38
-------
8. Research needs were also discussed. There are three areas where
information is urgently needed.
a. The development of health and environmental standards for
contaminants is the highest priority need. It may be necessary to
develop two levels or standards for each contaminant — one level
applicable to the environment and another level for human health.
b.More information on the assimilative capabilities of natural
sites is needed, not only for wet environments, but for all
environments that may be used for hazardous waste disposal.
c. The amount of groundwater data generated is growing rapidly and
therefore data management systems should be developed which
can effectively manage these data on a regional or aquifer level.
39
-------
APPENDIX A: DISCUSSION PAPERS
-------
A. Comments by Mr. James 3. Geraghty, President
Geraghty and Miller, Inc.
The design of a system for monitoring ground water at any waste-disposal
facility should be based on (1) the nature of the waste, (2) the factors governing
leachate production, (3) the permeabilities of earth materials underlying the
facility, (4) the depth to the saturated zone, (5) groundwater transmissivities and
hydraulic gradients, (6) attenuation characteristics of the leachate and the earth
materials, and (7) locations of nearby points of ground-water discharge. In essence,
the interrelationships of these factors determine what chemical constituents, in
what concentrations, move where and at what speed toward places where they
could pose a risk to health and/or the environment.
The amount and chemical composition of generated leachate are functions of
the wastes themselves and of the infiltration of precipitation, surface runoff, and
ground water into and through the waste mass. For the most part, this generation
process is common to the production of leachate at all waste facilities, regardless
of whether the environment is wet or dry. The principal distinctions in the
wetland/saturated soil case are that (1) more natural water may be available than
in dry areas, and (2) the avenues for transporting leachate into the hydrologic
system may be more direct.
Wetlands;
The term "wetland" is generally taken to mean an area of some appreciable
size where a body of shallow standing water is present perennially or for
substantial periods of time throughout a year. Swamps and marshes are the two
clearest examples of wetlands; other open surface-water bodies like puddles, ponds,
lakes, streams, tidal bodies, or springs are not normally described as wetlands.
Natural quality of water in wetlands may range from brackish to fresh.
A-l
-------
Wetlands can be classified according to their sizes and the magnitudes of
inflows and outflows of water. Water may enter a wetland through direct
precipitation, inflows of surface water (sometimes from man-made drainage
systems), outward seepage of shallow ground water, or discharges from springs or
abandoned flowing wells. The size of the wetland obviously is controlled by
climatological factors, the topographic configuration, the amount of incoming
water, and the mechanisms that carry the water away.
In some instances, most of the water in a wetland escapes through streams.
In other instances, it may largely be evaporated or consumed by vegetation, or may
move into the underlying groundwater system. Combinations of all three avenues
of discharge are the rule, the only major distinction being what proportion of the
water is removed via each avenue.
The permeability of the soil material underlying the wetland is a major
controlling factor, and many wetlands exist simply because the water cannot drain
downward rapidly enough. However, even where the soil materials are highly
permeable, a wetland may be present because the water table is close to or at land
surface and is contributing water into the wetland area.
Monitoring Concepts
Most waste constituents (an important exception being volatile organics) do
not result in emissions into the air, so that the principal monitoring effort can be
devoted to transport in surface water and/or in ground water. If the wetland is
underlain by permeable earth materials and is in direct hydraulic contact with the
shallow water-table aquifer, there is no unsaturated zone to be monitored between
the land surface and the water table. If the wetland is "perched" on top of a
geologic layer of low permeability, an unsaturated zone is commonly present below
the wetland.
A-2
-------
Where the groundwater flow pattern is radially inward to the wetland (the
most comon condition in areas of high soil permeability), monitor wells landward of
a waste facility in the wetland are unlikely to detect releases of leachate, unless
the wells are installed direclty at the edge of the waste mass. In this setting, the
leachate plume will extend along the direction of the radial groundwater flow, that
is, more or less toward the center of the wetland, from which it will move upward
to enter the open standing water. From there, the contaminated water either will
be evaporated (leaving the solids behind) or will discharge into the brooks or
streams that drain the wetland. Potential monitoring points are the shallow
geologic units downgradient of the waste facility and the natural surface-water
drainage system.
Where the wetland is on top of a layer of low permeability, the natural
discharge of water (other than through evapotranspiration) will be via a surface-
water route and/or slow downward seepage to the underlying water table.
Contaminants entering the water-table aquifer will move according to prevailing
groundwater gradients. Potential monitoring points are the unsaturated zone
beneath the landfill, shallow water-table units downgradient of the waste facility,
and the natural surface-water drainage system.
Saturated Soils:
For the purpose of this analysis, the term "saturated soils" is restricted to
dry-land areas where the water table is at or very close to the land surface. In
many instances, however, recharge causes such a shallow water table to rise to or
above the land surface, creating a wetland, so that the distinction may be blurry.
Saturated soil conditions are most common in low-lying regions adjacent to
wetlands, rivers, lakes, and tidal bodies of water. The permeabilities of the soils
may be anywhere from extremely low to extremely high.
A-3
-------
By definition, no unsaturated zone is present above the water table in a
saturated soil area. Also by definition, there is no upward discharge of water into
surface water bodies, although there commonly is some evaporation to the
atmosphere. Thus, all water flow is lateral or downward in the groundwater
system, the lateral flow terminating in nearby open surface water bodies, wetlands,
springs, or wells, and the downward flow moving into deeper aquifers to follow
regional groundwater patterns.
Monitoring Concepts
In the saturated-soil case, the shallow ground water generally moves toward
the nearest point of discharge, which is precisely what happens in any other
groundwater system. Thus, the conventional procedures for groundwater monitor-
ing are equally applicable to saturated soils, except that unsaturated-zone monitor-
ing is not possible.
Most rules for conventional groundwater monitoring of a waste facility do not
properly allow for differences in rates of groundwater movement. Many soils are
saturated simply because they have a very low permeability and do not drain
rapidly, and under those circumstances, contaminated fluids entering the soils also
cannot move rapidly. In many instances, literally years might elapse before the
contaminants could move even a few yards. To provide early detection, monitor
wells in such cases would have to be extremely close to a waste source.
-------
B. Comments by Dr. Keros Cartwright, Head
Hydrogeology and Geophysics Section
Illinois State Geological Survey
It has now been approximately two decades since Dr. George M. Hughes, then
at the Illinois Geological Survey, made the statement that the water table was
inconsequential to the disposal of waste. Much more is known now about waste
leaching and contaminant transport, yet his statement remains generally valid for
the region which he was speaking about. That is, the flat to gently rolling
glaciated north-central region of the country where precipitation exceeds eva-
potransportation. This is also the region my remarks will be directed toward
although they probably have much wider application.
In this region, the water table generally is slightly subdued, but coincident to
the topography. The high moisture content of the clay-rich soils holds the water
table very high for most of the year. Many thousands of miles of drainage canals,
master drains, and field tiles have been installed to suppress the water table. Vast
areas of Illinois were intermittant wet lands before drainage for agriculture. Low
water tables were associated with shallow highly permeable soils which are major
recharge areas and/or shallow aquifers. Directing waste disposal to such areas is
counterproductive.
There is a considerable body of data suggesting that most waste disposal sites
in humid climates become anaerobic fairly rapidly even if they are above the water
table. The decay and decomposition consumes oxygen much faster than air can
permeate the slowly permeable material in which the waste has been placed.
Although some contaminants in the leachates may be less mobile in the oxygenated
state, this may not be practical in real world terms. I might also point out, some
contaminants are less mobile in a reduced state and may be almost immobile in an
aqueous solution.
A-5
-------
Much still needs to be learned about unsaturated groundwater flow and
contaminant transport in wet, clay-rich, unsaturated soils. For instance, there are
conflicting data concerning possible increased attentuation of contaminants in a
vadose zone; there appears to be increased attentuation of some contaminants and
not for others. Those contaminants which show some increased attenuation in the
vadose zone generally are those with fairly high attenuation in the saturated zone.
The more mobile contaminants appear to move easily in both the vadose zone and
saturated soils.
Second, we know little of the contaminant transport characteristics of the
unsaturated, fine-grained, clay-rich soils. However, I have seen evidence of very
rapid chemical transport despite the fact that the hydraulic conductivity of
unsaturated soils is significantly less than when it is saturated. Unsaturation does
not appear to offer a significant advantage.
The most significant aspect of site design is the water balance. The common
"bath tub effect" is a result of water imbalance. While many factors contribute to
the imbalance, the main root of the problem is the difficulty of constructing a
landfill cover that will limit infiltration to the volume which can drain from the
waste. This is a key area for future improvement in landfill construction
techniques. The "bath tub effect" will occur in both saturated and unsaturated
soils.
The key to good landfill site design and monitoring is an excellent description
of the site geology and groundwater movement. The less complex the site, the
easier it is to design the operations and monitoring. Monitoring is done primarily in
the saturated zone, although unsaturated monitoring is possible and has been
undertaken at a few sites. There are insufficient, well-trained people presently in
the field designing monitoring systems. To add unsaturated zone monitoring
reduces this limited pool of qualified people even further.
A-6
-------
The performance of a disposal site should be judged on the basis of the
discharge of contaminants to the environment. This discharge takes place through
saturated soils to either the surface or on an aquifer. We also have the ability to
alter the saturated groundwater flow to perform remedial actions or control the
flow path of the contaminants.
A-7
-------
C. Comments by Dr. Wayne A. Pettyjohn
Department of Geology
Oklahoma State University
Before anyone can monitor waste disposal in a wetland, a fundamental
question must first be answered. That is, what is a wetland? The more
commonplace definitions are related to the type of vegetation present, the
abundance or number of animal or plant species present, the depth of the water (if
any), the amount of time each year that the area is wet, or perhaps the depth to
the water table. These definitions beg the question. Wetlands are caused by a high
water table, but the hydrogeologic situation is likely to be far more complex than
readily meets the eye.
Prior to monitoring system design, the groundwater flow system must be
determined and understood. It is the framework upon which the system must be
based. Of what value, for example, are monitoring wells that are all upgradient,
other than to evaluate ambient conditions? Although not well studied, wetlands
can represent from a hydrogeologic point of view, a zone or zones of groundwater
discharge, groundwater recharge, both recharge and discharge depending on the
season, or it might represent an area of through flow. In other words, wetland flow
patterns are similar to those adjacent to lakes. In fact is not a wetland nothing
more than a very shallow lake? It is the flow pattern that controls both the
vertical and horizontal head distribution, direction of flow, and the chemical
quality of water that is present under natural conditions.
A relatively new and fruitful area of research lies in the development of
knowledge and a data base that describes the effects of the geologic medium on
waste compounds and vice versa. We know that soil organic matter plays a major
role on the attenuation of many organic compounds, but how much is significant,
what is the effect of its distribution, both vertically and horizontally, and what
control is exerted by hydroxides, clays, or microorganisms?
A-8
-------
In the past three or four years many investigators have begun to look at
monitoring well design and installation as well as sample collection. Although
some exciting developments have occurred, an examination of permit applications
and published information rather clearly indicates that primitive systems are still
being used. This is likely a function of ignorance and cost. The need lies in the
development of techniques that are relatively simple to construct and install, can
be readily obtained at a moderate cost, and perhpas most importantly, a good,
rapid, and inexpensive means of technology transfer. The most sophisticated
system is of limited value if no one knows about it.
Another area of research that needs to be developed to a greater extent deals
with ambient groundwater quality conditions. Some investigators have shown
rather clearly that shallow or surficial aquifers can undergo rather rapid changes in
quality, which is brought about by rechanrge. What is the background concentra-
tion of nitrate, for example, that in any particular area may range from less than 1
to more than 100 mg/1 throughout the year and the changes are natural? How does
a regulatory agency establish an upper limit?
A considerable variety of computer models have been developed and some of
them are very good. They can be particularity useful for the development of a
monitoring system design and this perhaps is their strongest point. On the other
hand, most require data that simply are not available and may not be available for
several years. Furthermore, many individuals appear to believe that only a few
people are sufficiently versatile with computers to use them, while others suggest
that programs should be written in such a manner that most regulatory personnel
can use them. Then, of course, there is always the old dead horse to beat that
there isn't enough data to make a prediction. There is always enough data to make
a prediction despite the fact that many parameters must be assumed, but one must
A-9
-------
clearly recognize the limitations of their data, their program, and their own
expertise.
It has only been in the past 10 years or so that regulatory agencies have
finally realized there is such a thing as ground water. It is no wonder that we
suffer from a great of ignorance because we simply have not had sufficient time to
even recongize all of the problems, much less solve them. Although a good deal of
research remains to be carried out, it would appear that in any monitoring scheme
a fundamental understand of the hydrogeologic system is primary.
A-10
-------
D. Comments by Dr. F. O. Mixon, Manager
Hazardous Materials Research Office
Research Triangle Institute
Conventional wisdom has it that the best environment for siting of land
disposal facilities possesses a deep water table, low permeability soils, a high
adsorptive capacity of soils, and remote locations from wells, lakes and surface
streams. In a practical sense, however, the conditions of a deep water table and
low permeability are frequently self-exclusive in that areas of low permeability in
humid climates rarely have deep water tables. Thus the examination of the
feasibility of siting hazardous waste disposal facilities in wetlands is eminently
timely.
Leakage or leachate from such facilities will follow the groundwater flow,
experiencing both axial and lateral dispersion in its transit. The groundwater flow
field is perhaps the dominant factor in plume transport and should be carefully
characterized during the siting decision. Thereafter several issues are of concern.
Representative Sample Acquisition
Necessity for Concentration Measurements
For a facility in unsaturated soils, the occurrence of leachate can be
detected by the presence of water. In a saturated environment, however, the
sensing of the leachate must be through concentration measurements.
Consequently, the acquisition of a representative sample is highly important.
Heisenburg Principle
The Heisenburg principle operates in that the act of observation perturbs the
observed phenomenon. Sample analysis has been reported to depend on well design,
placement, and sampling protocol. This phenomenon is likely to be of strong
consideration in low permeability soils because of poor rates of drainage into the
well and the tight zone of response to the well environment. Specifically, if one
follows the usual procedure of pumping several well volumes prior to sampling,
A-ll
-------
then one generates a transient adsorption-desorption phenomenon in the adjacent
soil that can create nonrepresentative samples. The resolution depends upon the
development of a better understanding of the response dynamics of the neighbor-
hood of the well.
Plume Surfacing
Of particulate importance in saturated low permeability environments is a
shunting of contaminants to the nearby surface in the form of surface moisture or
leachate springs. Such seepage can occur periodically with a transient ebb and
flow in the water table. Acquiring a representative sample of such widely spread
surface water at the seepage plume requires careful thought of what one is trying
to measure. For example, photooxidation can modify chemical species, composi-
tions, and toxicities. What is a meaningful analysis of environmental insult in such
circumstances?
Monitoring Trigger Levels
An ultimate concern is the impact upon human health of drinking water
contamination. A monitoring program should then be targeted toward detecting
levels at the monitoring point that might result in levels detrimental to human
health at the consumption point. Given the current status of risk assessment
technology this is a tall order, but there exist compilations of concentration levels
thought to be threshold values for human exposure to air, as well as water.
Illustrative of one such data base is the attached graphical representation in which
estimated permissible concentrations of various chemical species in drinking water
are displayed for various chemical categories. Each solid bar on the logarithmic
representation shows the range of values for health effects for compounds in that
particular category and the indicators and the numbers on each solid line refer to
individual compounds. The recommendation is to think through carefully the
utilization of some similar set of values in establishing monitoring triggering
A-12
-------
levels, e.g., concentration levels observed in samples that trigger further action.
The further action could be more detailed characterization of the sample or
remedial response.
Regulatory Philosophy
Soil Attenuation Mechanisms
What is important is not so much the transit time of a pollutant from a
landfill to a drinking water supply but the concentration of the pollutant at its time
of entry into the drinking water supply. Over the long run, all landfills will leak,
and the resulting materials will be redispersed into the environment. What matters
is that the characteristic time for detoxification whether by adsorption, dilution,
or degradation be of a shorter order than the transit time from the landfill to the
drinking water supply. Little attention appears to have been given to these
attenuation mechanisms. A data base is needed with monitoring requirements
emphasized for high toxicity materials whose half lives exceed their transit times.
Risk Management
Ultimately, regulatory decisions should have a sound basis in risk manage-
ment. Monitoring requirements should be set to produce information leading to
risk assessment with subsequent remedial activity satisfying some reasonable cost
benefit balance. An overall risk management structure tailored specifically for
land disposal would be of immense value in setting perspectives, priorities,
monitoring requirements, and remedial action thresholds.
A-13
-------
MEG't Category
1. ALIPHATIC HYDROCARBONS
A. Alkanes and Cyclic Alkanes
B. Alkencs. Cyclic Alkenes, Dienes
C. Alkynes
2. ALKYl HAIIDES
A. Saturated
B. Unsaturated
3. ETHERS
A. Noncyclic Aliphatic or Aromatic
B. Cyclic
4. HAtOCENATEO ETHERS; EPOXIDES
A. Monohalngnnated; Epoxidcs
B. Dihnlogcnated, Polyhalognnaled
o.oi
o.i
SUMMARY OF WATER EPC VALUES
EPC VALUES, ,,B"
too
Dinettes vmut tot srtcirit jimsunci MSIO on HEMIH tirtcrs
noiCArfs »«iui ro« sMcinc sunsmcr usio o» rcoiocioi imtis.
moicius »»iui 1*^(0 on c*Rcnnr,r»ic POTrmut.
01 muis Bisto ox HUI in irricrs
«»»r.r ex T«IUIS iisro on icoiocicut rrncts
-------
E. Comments by Mr. Irwin H. Kantrowitz
District Chief, USGS
Florida District Office
Monitoring requirements for disposal sites in wetlands will depend on the
nature of the wetland. Significant ground-water contamination is possible from
leachate generated from upland wetland sites. Ground water from these sites will
move in the prevailing ground-water flow direction which may carry it thousands of
feet or even miles laterally away from the site and hundreds of feet below the
water table. Obviously, extensive ground-water monitoring may be required at
such sites with only secondary concern given to surface-water monitoring (unless
there is a surface-water outlet from the wetland). Leachate generated at lowland
wetland sites, on the other hand, will generally move only short distances
underground before emerging in a surface-water body. Surface-water monitoring
may be the principle requirement at such sites with little or no regard given to
ground-water monitoring. An understanding of the hydrologic setting of a wetland
site is therefore the first requirement in designing a monitoring program.
Wetlands are often of special environmental concern because of the unique
fauna and flora they support. Most definitions of "wetland" include a reference to
the biologic environment and yet it is water that "wets the land" and supports the
unique biology. The chemical quality of water under and adjacent to wetland
waste-disposal sites will affect the viability of the wetland biologic community and
is an obvious concern. Therefore, ground- and/or surface-water quality monitoring
will be included in all monitoring schemes. Less obvious, is the quantitative effect
of a disposal site on the environment and in turn the effect that changes in the
hydrologic regimen may have on the wetland biologic community. For example,
changes in the length of time that wetlands are inundated and alternately dried
may adversely affect bird nesting, seed germination, tree distribution, etc. These
A-15
-------
changes in hydrologic regimen are related to changes in the position of the water
table.
There may be short term lowering of the water table at and adjacent to
disposal sites if excavation is a part of the design scheme. Longer term changes
will occur if the permeability of the material used to fill the excavation is
different than the adjacent undisturbed material. If the fill is more permeable, the
water table will be lowered, and if it is less permeable, the water table will be
raised, these water-table changes will occur both in and adjacent to the disturbed
site. The changes will occur both in and adjacent to the disturbed site. The
amount and areal extent of the change in the water table will depend on the size of
the site and the permeability contrast; it is conceivable that these changes could
be environmentally significant. Engineering solutions to leachate generation or
migration may also affect the water table. For example, perimeter ditches
(inevitably excavated below the water table in wetland environments) will lower
the water table in and adjacent to the site; impermeable liners (required on the
sides as well as the bottom of wetland site) will raise the water table upgradient
from the site and lower it downgradient.
Sites at which waste materials are disposed of above ground (rather than in
excavations) may also affect the hydrologic regimen of a wetland. The direction
and magnitude of hydrologic changes depend on the manner in which the problems
of controlling surface runoff, infiltration, and leachate generation and migration
are addressed.
Wetland communities are often in a delicate state of balance so that small
disturbances of hydrology (and quality of water) may have an appreciable impact.
The impact is likely to multiply because of the interrelationship of adjacent
communities; first the community adjacent to a site is affected, which, in turn
affects the hydrology and ecology of more distant areas.
A-16
-------
Monitoring of the hydrologic environment at potential waste-disposal sites
should begin with an understanding of the relationship between hydrology and
biology in the area of concern. Possible hydrologic effects of the disposal site can
be estimated, possibly by use of numerical models, and in turn the biologic effects
can be estimated. If judged to be potentially significant, alternate or mitigating
design features can be evaluated.
To conclude and summarize, monitoring requirements of wetland sites are not
all that different from those at other hydrologic environments except that: (1) in
some cases surface-water monitoring rather than ground-water monitoring may be
of prime importance, and (2) monitoring for subtle changes in the hydrologic
regimen may be required in ecologically sensitive areas.
A-17
-------
F. Comments by Dr. Robert 3. Livingston
Department of Biological Sciences
Florida State University
1. One of the initial questions at the outset involves the spatial and
temporal dimensions of the toxic waste problem. To include this question in the
original design of the monitoring scheme devised to answer the question is circular
and therefore a preliminary survey is necessary to define the boundaries of the
problem. In other words, it is impossible, both philosophically and scientifically, to
set up or initiate a monitoring program without a preliminary survey. Our research
group has done a great deal of work on this phase of monitoring. What is an
"adequate" sample? Quantification of results? Etc.
2. It is necessary to define the specific physical, chemical and biological
parameters within established levels of background variability (temporal, spatial)
of the study area. How much data are enough to answer the specific research
questions? What kind of data are necessary? What are the quality assurance steps
necessary to insure that the data are valid, relevant to the research question, and
adequate to define the scope and extent of the toxic waste impact? Once again,
we have done considerable work on the various forms (physical, chemical, biologi-
cal) of data that are necessary to answer such questions. In each case, the answers
are largely relative depending on the questions. And the research questions, from
the outset, should be based on preliminary analyses.
3. What is the relevance of the monitoring effort and how can the program
be designed for maximal efficiency of effort within the boundaries of the quality
assurance demands? This is an extremely difficult series of questions to answer. A
subsidiary (related) set of questions would be how to relate monitoring data to
cheaper methods of evaluation (i.e., bioassay or experimental approaches) and how
can such data be extrapolated to a variety of study sites in different environments
and under differing levels of stress due to varying forms of toxic wastes. My
A-18
-------
research group is currently examining the so-called "validation" or "verification"
question in a series of aquatic habitats from freshwater to coastal and marine
systems. These questions can only be answered after steps 1 and 2 (above) have
been addressed. Long-term, multidisciplinary data in a variety of aqutic habitats
are needed if these questions are to be correctly formulated and finally answered.
k. Can monitoring, in itself, be used to define the scope and effects of
toxic waste effects? This question is related to the specific needs of compliance
monitoring (NPDES permits under FWPCA, ocean pumping permits under MPRSA,
preparation of Federal Environmental Impact Statements, toxic waste levels
related to evaluations of toxic waste levels input into "natural" systems or TSCA
regulations, etc.). How can the various forms of analysis (physical, chemical,
biological) be integrated in an appropriate fashion to answer specific questions
regarding the different needs of the agency in their broad program of compliance
monitoring. Such questions need to be based on solid scientific inquiry but must
also be asked within the context of agency needs. Are there effective and
efficient methods available to answer the various families of questions so that a
research effort can be tailored to agency (regulatory) needs?
A-19
-------
G. Comments by Dr. Rodney S. DeHan
Administrator, Groundwater Section
Florida Department of Environmental Regulation
My concerns are outlined below:
1. Dynamics of interaction of ground water underlying the wetland with
the surface water overlaying the wetland. These dynamics could be
largely site specific. The need for a clear understanding of such
interaction is obvious since the protection of the ground water is of
great concern.
2. Qualitative and quantitative data on the assimilative capabilities of the
wetlands for various pollutants; organics, inorganics and microbiological
agents.
3. The leachability rates of the various chemicals through the organic
muck bottoms of the wetlands.
4. Data on methylation of heavy metals in the leachate.
5. Data on the uptake of organic and inorganic chemicals by the wetland
vegetation.
6. Data on the bioaccumulation and biomagnification of chemicals in
various animal populations of the wetlands (fish, mammals, birds,
insects, reptiles, etc. . . . ).
7. Data on the t. anslocation of pollutants taken up by plants through
consumption of such plants and incorporation into the food chain.
8. The economic and environmental impacts of transporting and disposing
of contaminated dredge material and harvested wetland vegetation.
9. Data on the synergistic and antagonistic potential of the interaction of
various chemicals with each other and the wetland's organic bottom
constituents.
There is a great gap in the literature concerning the above issues. Dr.
Odom's (University of Florida) research on the potential for using cypress domes
for disposal of domestic treated sewage left many questions unanswered.
A-20
-------
H. Comments by Dr. Robert P. Gambrell
Associate Professor, Marine Sciences
Laboratory for Wetlands, Soils and Sediment
Center for Wetland Resources
Louisiana State University
I have given some thought to the topics I feel should be included and these
are presented briefly below.
Much of the information available on the environmental chemistry of toxic
metals and synthetic organics has been done with aerobic soils. In this Laboratory,
we have demonstrated that the environmental chemistry of metals and synthetic
organics is very different in anaerobic (flooded or wetland soils) compared to
typical aerobic upland soils. For trace and toxic metals, this includes speciation,
mobility, and biological availability. For synthetic organics and petroleum
hydrocarbons, this includes degradation rates and adsorption to soil solid phases.
From my perspective, more information is needed to identify the differences
in behavior of toxic materials under upland and wetland conditions. Specifically,
different factors, processes, and interactions between processes are involved in
regulating the mobility and fate of toxic materials in saturated soils and wetlands
compared to uplands. for example, the oxidation-reduction status of a soil
material, which is greatly influenced by water saturation, affects several soil
properties. These include pH, redox potential, microbial populations and activities,
and a number of microbially mediated processes which either directly or indirectly
affect the environmental chemistry of hazardous materials in soil.
When we understand the fate and transport of hazardous materials in
saturated soils and wetlands, one important aspect of monitoring would be to keep
track of those soil properties associated with various oxidation-reduction condi-
tions to see if interactions between the soil and waste may occur that will result in
some unexpected transformations or transport of toxic materials.
A-21
-------
Because of the closer proximity of water, a primary transport medium, to
waste materials disposed of in wetlands or areas with saturated soil materials near
the surface, it would seem more intensive monitoring of the shallow groundwater
would be required than for a well designed upland waste disposal facility to insure
unacceptable contamination is not occurring.
Also, saturated soils associated with wetlands are often less stable than
upland soils. For example, clay liners often used for upland waste facilities may be
more subject to cracking, or other deformation, under wetland conditions such that
the structural integrity of a designed containment facility would have to be
monitored more closely than a comparable structure on upland soils.
A-22
-------
I. Comments by Dr. G. Ronnie Best
Wetlands Ecologist and Associate Director
Center for Wetlands
University of Florida
First, let us address the function of wetlands relevant to the hydrologic
cycle. Wetlands function to store water during normal high-water or flood events.
These waters are then gradually released to downstream or belowground systems.
At normal-to-high-water periods, groundwater systems can actively recharge wet-
lands. However, during normal-to-low water periods the reverse is generally true
though subsurface discharge through wetlands is generally mediated by organic or
clay zones. Therein lies one concern regarding solid waste disposal in or near
wetlands. Will there by any effect, such as alteration of wetland hydroperiod, of
solid waste disposal sites near wetlands on groundwater recharge of wetlands? If
so, will hydroperiod alteration be within the functional tolerance limit of the
wetland ecosystem?
What about water quality entering or leaving wetlands that are influenced by
solid waste disposal? Most of us are cognizant of the important role wetlands play
in water quality enhancement, especially removal of nutrients from non-point
source runoff or even municipal wastewater. Recent and current research also
indicate that wetlands may function as repositories for municipal or some
industrial wastewaters containing selected heavy metals. What about the fate of
organic compounds in wetlands? Is there a chance for accumulation of some waste
products up the food chain? Some of Center for Wetlands' recent research on
selected heavy metals in wetlands indicate that heavy metals discharged into
organic rich, moderate-to-low-pH wetlands form insoluble precipitates that
accumulate in the sediments. Is this a long-term storage for the metals? What is
the fate of other waste products in wetlands? Will they occur in insoluble or
soluble forms; available or unavailable forms?
A-23
-------
What are the major forcing functions that drive (maintain) wetlands? We
have already briefly discussed one primary forcing function--hydroperiod--and
have raised questions concerning how solid waste disposal sites may affect wetland
hydroperiod (we must recognize that "hydroperiod" integrates three basic hydro-
logic parameters: flood frequency, flood duration, and flood intensity. What are
some other major forcing functions that maintain wetlands? Generally, water
levels fluctuate in most wetlands on at least a 1 to 2-year basis. In many wetlands
the soils go from completely saturated to completely unsaturated, resulting in
periods of aerobic and anaerobic conditions. How will annual fluctuation between
aerobic and anaerobic soil conditions affect availability rates of waste products
discharged into wetlands? What about the longer term major drought cycles (and
concomitant longer aerobic periods) that typify most wetlands?
Another major forcing function maintaining wetlands is fire, especially for
wetlands in the Southeast. The importance of fires in maintaining wetlands is not
well understood since only a limited number of studies have been done on fire
frequency in wetlands. However, data to date on historical fires, burn layers in
peat, and wetland recovery mechanisms following fires indicate fires are important
maintenance mechanisms in wetlands. Will wildfires in wetlands pose a threat to
solid waste disposal sites in or near wetlands? Or, will it be necessary to control
wetland fires to minimize risk to waste disposal sites? What about waste products
in wetlands; how will fire affect their solubility, availability, etc.?
Finally, let us talk about wildlife in wetlands. Many plants and animals in
wetlands have adapted to the normal seasonal and even long-term wet-and-dry
periodicity that typifies wetlands--at least within some functional range for the
specific wetland community. Alteration in the environment, such as changing
hydroperiod, increasing nutrients, or potentially toxic substances (especially if in
an available form) and affecting fire frequency could cause a shift in flora and
-------
faunal composition of the wetlands. Minor shifts may be acceptable. But, how
much of a shift in community structure and function can the wetland system
tolerate? Also, if waste products accumulate in wetlands, will there be potential
for food chain accumulation?
The list of questions could go on. But, since I do not really have an
understanding of how solid waste (hazardous waste) disposal sites are designed or
how they function especially within the context of disposal in or near wetlands, it
is really difficult to speculate on their affect on wetlands. In summary, the major
areas of wetland functions that must be monitored with respect to solid waste
disposal sites in or near wetlands are as follows: 1) affect on hydroperiod; 2)
influence on water quality; 3) affect on fire frequency and concomitant affect of
fires on waste produce release and availability; 4) potential for bioaccumulation in
food chain and subsequent affect on wildlife; and 5) alteration of the wetland
ecosystem beyond its functional tolerance limits.
A-25
-------
J. Comments by Dr. C.R. Lee
Contaminant Mobility and Regulation Criteria Group
Waterways Experiment Station
U.S. Army Corps of Engineers
This paper will address the question of what types of monitoring, environ-
mental constraints, and management should be considered during the implementa-
tion of a fill of solid or hazardous waste onto a saturated soil. It should be pointed
out that this report reflects basic technical ideas of myself and in no way
represents nor should be construed to represent the position of the U.S. Army
Corps of Engineers, Waterways Experiment Station, or the Department of the
Army. The questions and considerations to be addressed are in relation to my
technical understanding of the geochemistry of natural and pertubated systems in
relation to saturated flooded soils.
Solid and/or hazardous waste disposal in a wetland or flooded soil scenario
creates an interesting and somewhat difficult condition regarding application of
standard upland landfill practices and concerns. The geochemistry of flooded soils
is vastly different from those of an upland environment. The mere presence of
water creates an oxygen deficient system in regard to well-aerated and drained
pores of an upland soil. This initial oxygen deficiency or separation from the
atmospheric environment is further exacerbated by the presence of readily
decomposable organic matter (OM) common to wetland swamp and marsh areas.
The OM creates an oxygen demand through the decomposition by microbes, both
aerobic facultative, and strict anaerobes such that the demand for oxygen is much
greater than the supply. Then, anaerobic or anoxic conditions prevail in the soil
and soil pores and possibly the overlying water.
These anoxic conditions cause the release of some metals (iron and
manganese); some nutrients (ammonia and orthophosphate); and some complexing
OM. These complexing agents are poorly decomposed organic materials due to
A-26
-------
slower decomposition process in flooded soils and complexing inorganic materials,
such as hydrogen sulfide which has an extremely high affinity for complexing and
stabilizing heavy metals. The wetland soil environment is also a unique ecological
niche supporting flora and fauna obviously not found in an upland environment and
having a direct relationship to the nearby aquatic flora and fauna. It is well known
that the associated aquatic system depends heavily on the flux of organic detritus
and soluble nutrient material from productive swamp and marsh areas. The
marine, estuarine, and freshwater fishery are directly related to the productivity
of these areas. It is also well known that marshes and wetlands, from a
macrophyte standpoint, are on an acres basis some of the most highly productive
areas in the world. This high level and intense productivity is direclty coupled to
the geochemical considerations in a wetland soil that could either enhance release
of contaminants, retard release of contaminants, or due to the anoxic decomposi-
tion processes, convert what could be inert organic molecules into highly toxic
degradation products. Many of these inorganic pathways are well known; however,
most of the organic pathways are not well known. Other concerns that enter
directly into consideration of a saturated soil or wetland area for solid or
hazardous waste disposal is the effects of these areas' groundwater hydrography.
Many of these areas of groundwater recharge could, in some cases, also be areas of
upwelling. This factor plays a very important role in consideration of wetland
sites. Furthermore, a wetland site could be chosen for fill with waste material
high in metals. Such metals would be stabilized and detoxified as very poorly to
insoluble sulfide complexes. This would hold true as long as the materials remained
in an anoxic and saturated state. However, if the filling was such that the material
became drained and perched in an upland position, oxidation of the metallic
sulfides could result in acidic conditions and a worst case scenario for release of
metals. In light of potential long-term land use practices, the area could be
A-27
-------
drained, filled, or diked and allowed to dry and become well oxidized. This
condition would result in a drastic change in the geochemistry of the soil and marsh
soil environment (reversion to an upland soil condition) with a potential massive
release of metals. The metal sulfides would be oxidized with time to the sulfate
form with the potential of developing very acidic soil conditions. The acid
conditions would only increase metal release and biological availability. Organic
matter and the metal-organic decomposition products would be rapidly completed
under oxic conditions, with potential release and enhanced metals release. On the
other hand, some organic contaminants would be more completely and rapidly
decomposed under oxidizing soil decomposition conditions.
Question 1; What types of monitoring should be performed during the implementa-
tion of a large-scale filling program?
1. A complete reconnaissance of the distribution of natural soil
components in the marsh sediments must be conducted, along with a
complete knowledge of the groundwater hydrography and whether these
areas are one of groundwater recharge or upwell.
a. Spatial geochemical conditions must be evaluated and determined
through the vertical/horizontal profiles of the marsh and any
adjoining creek bottoms and banks.
b. Sediment cores must be deep enough to indicate not only the
desired filling depth, but the conditions of the underlying soils in
relation permeabiltiy and stability.
2. A solid waste/hazardous waste containment facility could be
constructed within a wetland's environs considering that total contain-
ment must be ensured. This is extremely important to relation to the
A-28
-------
intense productivity and the relationship of this marsh and swamp
productivity to the ecology of the adjoining aquatic areas. With the
possible exception of selected inorganic nutrients and micronutrient
metals, retention of all contaminants in the site should be mandated.
a. Monitoring wells should be distributed within and outside the
containment facility to document groundwater hydrology and
potential for contaminant movement out of the site. Tidal
influence on groundwater movement should also be identified
(such as changes in groundwater salinity or conductivity, in
relation to tidal cycles).
b. Contaminant distribution should be quantified in the material
proposed for disposal and distribution quantified after disposal to
identify potential problems areas.
c. Holding or retention efficiency in the containment facility must
be carefully determined.
d. The extent of the subsoil or clay pan, if it exists, or lower strata
distribution must be accurately mapped and its permeability or
lack of permeability determined. It would be very important to
know any fractures or sand lenses in the underlying soil structures
that might contribute to leaking of a containment facility.
e. The dikes comprising the containment should be designed to
restrict lateral movement of contaminants from the soil surface
to the underlying containment structure.
f. Adequate soil material should be located to seal the containment
facility after disposal to prevent upward movement of
contaminants and maintain anoxic conditions in the disposed
material.
A-29
-------
3. Additional Questions
a. Rate controlling mechanisms and factors controlling the move-
ment of contaminants. The anoxic geochemistry (inorganic and
organic) of the soil/sediment system and the high organic loading
(marsh detritus and any other sources, man-made or natural)
dominate those rate controlling mechanisms and mobility factors
responsible for the apparent "stable" system. Any major shift
from flooded anoxic state to a nonflooded (upland) oxic conditions
represents the most serious condition for metals release, bioaccu-
mulation, and toxicity potential. The pH shift from near neutral
(as it normally exists in flooded soils) to acidic will have a
profound effect on metals with the release and bioaccumulation
potential orders of magnitude greater than that originally present.
The marsh should be maintained in as natural a state as possible
because it, in itself, drives the geochemistry of this flooded
system and supplies enough organic material year-round to keep
the sediments anoxic through the import of detrital organic
matter and these various cycles.
b. Models. At best, only a qualitative conceptual model may be
developed to predict direction of expected changes due to this
type of disposal activity in a wetland. A quantitative estimate of
magnitude is not possible to model to any great degree of
accuracy. Some specific compartments may be physically or
analytically modeled to leaching, bioassay tests, bioaccumulation
tests, etc., for estimates of magnitude of short-term events.
c. Short-term effects. These should include storm events, prolonged
droughts, dredging industrial outfalls, new filling, new manage-
A-30
-------
ment techniques, or any other event that may shift the existing or
predicted geochemical balance.
A-31
-------
APPENDIX B: WORKSHOP AGENDA
-------
WORKSHOP ON MONITORING CONSIDERATIONS
IN THE SITING AND OPERATION OF HAZARDOUS
WASTE DISPOSAL FACILITIES IN TEMPERATE ZONE WET ENVIRONMENTS
OCTOBER t-5, 1983
TALLAHASSEE, FLORIDA
Florida State Conference Center West Pensacola and Copeland
AGENDA
Tuesday Morning, October 4
8:30 REGISTRATION AND CONTINENTAL BREAKFAST
Florida State Conference Center
West Pensacola and Copeland
9:00 INTRODUCTION AND ANNOUNCEMENTS
Workshop Coordinator: Roy C. Herndon, Florida State University
WELCOME
Congressman Don Fuqua: Chair man, Committee on Science
and Technology, U.S. House of
Representatives
9:15 WORKSHOP OVERVIEW
o Wet Environments
o Office of Solid Waste Regulatory Program Needs
o Objectives and Goals of the Workshop
o Program Format
Kenneth A. Shuster: Office of Solid Waste, Land Disposal Branch,
U.S. EPA
John D. Koutsandreas: Office of Research and Development, Water
and Waste Management Monitoring Research Division, U.S. EPA
9:30 INVITED COMMENTS
10:30 BREAK
B-l
-------
10:45 Session I - Evaluation Techniques for New Sites in Wet Environments:
Hydrogeologic Setting, Water Flow, and Other Factors to Consider;
Techniques to Measure
Moderator: Mr. 3ack L. Witherow
Panel: Dr. G. Ronnie Best; Dr. Keros Cartwright;
Dr. Rodney S. DeHan
11:30 SESSION n - Site Selection/Denial Criteria for Saturated Soils: Factors
to Consider; Decision Criteria
Moderator: Mr. Ron Lee
Panel: Dr. Robert P. Gambrell; Mr. 3ames 3. Geraghty;
Dr. P.O. Mixon
12:15 BUFFET LUNCHEON
Florida State Conference Center
West Pensacola and Copeland
Tuesday Afternoon, October £
1:30 Session ni - Special Wet Environment Considerations: Types; Site
Hydrologic Evaluation; Flora and Fauna Life Support Systems
Evaluation; Decision Criteria
Moderator: Mr. William Mason
Panel: Mr. Irwin H. Kantrowitz; Dr. C.R. Lee;
Dr. Robert 3. Livingston
2:15 SESSION IV - Monitoring Techniques for Operating Sites: Need for
Monitoring; Designing and Operating Monitoring System
Moderator: Mr. John Koutsandreas
Panel: Dr. P.O. Mixon; Dr. Wayne A. Pettyjohn;
Dr. G. Ronnie Best
3:00 BREAK
B-2
-------
3:15 SESSION V - Contaminant Migration/Plume Tracking Monitoring
Moderator: Dr. Walter Grube
Panel: Dr. Keros Cartwright; Dr. Rodney S. DeHan;
Dr. Robert P. Gambrell
4:00 SESSION VI - Quality Assurance Considerations for: Site Evaluation
Techniques and Monitoring Techniques
Moderator: Mr. Douglas McCurry
Panel: Mr. James 3. Geraghty; Dr. C.R. Lee;
Mr. Irwin H. Kantrowitz
5:00 ADJOURN
Social/Hospitality Hour
Tuesday Evening, October ^
6:00 DINNER MEETING
The Florida State Conference Center
Speaker: Dr. Robert J. Livingston, Florida State University
Wednesday Morning, October 5
8:30 REGISTRATION AND CONTINENTAL BREAKFAST
Florida State Conference Center
West Pensacola and Copeland
9:00 SESSION VII - Research Needs to Improve Site Evaluation Techniques,
Monitoring Technqiues, and Quality Assurance
Moderator: Mr. Victor Lambou
Panel: Dr. C.R. Lee; Dr. Robert J. Livingston;
Dr. F.O. Mixon
10:15 BREAK
B-3
-------
10:30 Session VIII - Conclusions and Policy Recommendations Concerning the
Modification of Current Regulations Dealing with the Monitoring
Aspects of Hazardous Waste Landfills In or Near Wet Environments
Moderator: Mr. Kenneth A. Shuster
Panel: Dr. Wayne A. Pettyjohn; Dr. G. Ronnie Best;
Dr. Keros Cartwright
11:30 WORKSHOP SUMMARY AND CRITIQUE
12:00 WORKSHOP ADJOURNMENT
1:30 AFTERNOON SESSION: INDIVIDUAL DISCUSSION (Optional)
-------
APPENDIX C: WORKSHOP PARTICIPANTS
-------
LIST OF PARTICIPANTS
Monitoring Workshop
October 4-5, 1983
Tallahassee, Florida
Dr. Martin 3. Allen
Physical Scientist
U.S. Environmental Protection Agency/Region VI
1201 Elm Street
Dallas, Texas 75270
767-8941
Mr. David Beno
Environmental Protection Specialist
Dredge and Fill Section/Mail Stop: 5WQD-11
U.S. Environmental Protection Agency/Region V
230 S. Dearborn
Chicago, Illinois 60604
(312) 353-2000
Dr. G. Ronnie Best (Invited speaker)
Associate Director
Center for Wetlands
Phelps Laboratory
University of Florida
Gainesville, Florida 3261 1
(904) 392-2424
Mr. Charles Biedermann
Environmental Specialist
Solid and Hazardous Waste Section
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, Florida 3230 1
(904) 488-0300
Mr. Kenneth Bradley
Environmental Scientist
Environmental Services Division/6-ES-SH
U.S. Environmental Protection Agency/Region VI
1201 Elm Street
Dallas, Texas 75270
(214) 767-9770
Mr. James Butch
Biologist
Wetlands Review Section
U.S. Environmental Protection Agency/Region III
6th and Walnut Streets (Curtis Building)
Philadelphia, Pennsylvania 19106
(215) 597-3429
C-l
-------
Dr. Keros Cartwright (Invited speaker)
Head, Hydrogeology and Geophysics Section
Illinois State Geological Survey
615 E. Peabody Drive
Champaign, Illinois 61820
(217) 344-1481
(217)333-5113
Ms. Linda Clemens
Hydrologist
U.S. Environmental Protection Agency/Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
881-3866
Mr. Will Clements
Biologist
Department of Biological Sciences
136 Conradi Building
Florida State University
Tallahassee, Florida 32306
(904) 644-1466
Mr. William Davis
Aquatic Biologist
8523 Durham Court
Springfield, Virginia 22151
(202) 382-5087
Dr. Rodney S. DeHan (Invited speaker)
Administrator, Groundwater Section
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, Florida 32301
(904) 488-3601
Dr. Norman Francinques
Surpervisory Environmental Engineer
U.S. Army Corps of Engineers
Attn: WES-EE-S
P.O. Box 63 1/ Water ways Experiment Station
Vicksburg, Mississippi 39180
(601) 634-3703
Dr. Robert P. Gambrell (Invited speaker)
Associate Professor, Marine Sciences
Laboratory for Wetlands, Soils and Sediment
Center for Wetland Resources
Baton Rouge, Louisiana 70803
(504) 388-8810
C-2
-------
Mr. James 3. Geraghty, President (Invited speaker)
Geraghty and Miller, Inc.
Carrollwood Village, Executive Center
13902 North Dale Mabry Highway
Tampa, Florida 33688
(813)961-1921
Dr. James Greene
Subcommittee on Natural Resources,
Agriculture Research <5c Environment
U.S. House of Representatives
Room 388, House Annex II
Washington, D.C. 20515
(202) 226-6990
Mr. John E. Griffin
Engineer
Solid and Hazardous Waste Section
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, Florida 32301
488-0300
Dr. Walter Grube
Soil Scientist
Solid & Hazardous Waste Research Division
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
(513) 684-7871
Dr. Roy C. Herndon
Director of Research
Institute of Science and Public Affairs
361 Bellamy Building
Florida State University
Tallahassee, Florida 32306
(904) 644-2007
Mr. Joseph Hudek
Marine Ecologist
Marine Wetlands Protection Agency/Region II
26 Region Plaza - Room 837
New York, New York 10278
(212) 264-5170
Mr. Samuel Johnston
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, Florida 32301
(904) 488-3601
C-3
-------
Mr. Irwin H. Kantrowitz (Invited speaker)
District Chief, USGS
227 N. Bronough Street, Suite 3015
Tallahassee, Florida 32301
(90*) 681-7631
Mr. Jack S. Kendall
Environmental Engineer
S.C. Department of Health and Environmental Control
2600 Bull Street
Columbia, South Carolina 29201
(803)758-5681
Dr. Donald 3. Klemm
Research Aquatic Biologist
Environmental Aquatic Research Lab
U.S. EPA
26 West St. Ciair
Cincinnati, Ohio 45268
(513)684-8601
Mr. George S. Kopp
Staff Director, Subcommittee on Natural
Resources, Agriculture Research and Environment
U.S. House of Representatives
Room 388, House Annex II
Washington, D.C. 20515
(202) 226-6980
Mr. John D. Koutsandreas
Hazardous Waste Monitoring
Office of Research and Development (RD-680)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
(202)382-5791
Dr. William L. Kruczynski
Office of Ecological Review
U.S. Environmental Protection Agency/Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404)881-7901
Mr. J. Michael Kuperberg
Research Associate
Department of Biological Sciences
136 Conradi Building
Florida State University
Tallahassee, Florida 32306
(904) 644-1466
C-4
-------
Mr. Victor Lambou
Aquatic Biologist
Environmental Monitoring Systems Laboratory
U.S. Environmental Protection Agency
P.O. Box 15027
Las Vegas, Nevada 89114
(702) 798-2259
Dr. Edward LaRoe
Chief of Division of Biological Services
Department of Biological Services
Fish & Wildlife Service
Department of Interior
Washington, D.C. 20240
(202)653-8723
Dr. C.R. Lee, Chief (Invited speaker)
Contaminant Mobility and Regulation Criteria Group
Ecosystems Research and Simulation Division
P.O. Box 631/Waterways Experiment Station
Vicksburg, Mississippi 39180
(601) 636-3111
Mr. Ron Lee
Water Resources Assessment Team Leader
Environmental Evaluation Branch/Mail Stop 423
U.S. Environmental Protection Agency/Region X
1200 6th Avenue/Mail Stop: 423
Seattle, Washington 98101
(206) 442-1442
Mr. Clyde R. Livingston
Geologist
Ground Water Protection Division
South Carolina Department of Environmental Control
2600 Bull St.
Columbia, South Carolina 29201
(803) 758-5213
Dr. Robert J. Livingston (Invited speaker)
Department of Biological Sciences
136 Conradi Building
Florida State University
Tallahassee, Florida 32306
(904) 644-1466
Mr. William Mason
Equatic Ecologist
U.S. Environmental Protection Agency
401 M Street, S.W., RD682
Washington, D.C. 20460
(202) 382-5980
C-5
-------
Mr. Douglas McCurry
Chief, Waste Engineering Section
U.S. Environmental Protection Agency/Region IV
345 Courtland St. N.E.
Atlanta, Georgia 30365
881-4727
Dr. Harold K. McGinnis
Carlton Building
Room 301
Governor's Building
Tallahassee, Florida 32301
(904) 488-4512
Dr. P.O. Mixon, Manager
Hazardous Materials Research Office
Research Triangle Institute
P.O. Box 12194
Research Triangle Park
North Carolina 27709
(919) 541-5917
Mr. John Moerlins
Research Associate
Institute of Sciences and Public Affairs
361 Bellamy Building
Florida State University
Tallahassee, Florida 32306
(904) 644-2007
Mr. Greg Peck
Environmental Scientist
Criteria and Standards Division
Section 404 Program
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
(202 755-0100
Dr. Wayne A. Pettyjohn (Invited speaker)
Department of Geology
Oklahoma State University
Stillwater, Oklahoma 74078
(405) 624-6358
Dr. Elizabeth Purdum
Research Associate
Institute of Science & Public Affairs
361 Bellamy Building
Florida State University
Tallahassee, Florida 32306
(904) 644-2007
C-6
-------
Mr. John Reese
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, Florida 32301
(90*) 488-0300
Mr. Lawrence Schmidt
Acting Director
Office of Science & Research
Planning Group (CN 402)
New Jersey Department of Environmental
Protection
Trenton, New Jersey 08625
(609) 984-2662
Dr. Walter Schmidt
Administrator, Geologic Investigative Section
Florida Geological Survey
903 W. Tennessee St.
Tallahassee, Florida 32304
(904)488-9380
Dr. Donald Schultz
Environmental Contaminant Specialist
Habitat Resources
U.S. Fish and Wildlife Services
75 Spring Street, S.W.
Atlanta, Georgia 30303
(404)221-6343
Mr. Kenneth A. Shuster
Chief, Land Disposal Branch
Office of Solid Waste (WH-565E)
Land Disposal Division
U.S. Environmental Protection Agency
401 M Street S.W.
Washington, D.C 20460
(202) 382-3345
Mr. Alex P. Sokolik
Legislative Analyst
Committee on Natural Resources
Florida House of Representative
214 House Office Building
Tallahassee, Florida 32301
(904)488-1564
Mr. Douglas Thompson
Wetlands Coordinator
Water Quality Branch
U.S. Environmental Protection Agency/Region I
Room 2203, John F. Kennedy Building
Boston, Massachusetts 02203
(617) 223-5470
C-7
-------
Mr. Greg Tipple
Geologist, Disposal Facilities Unit
Texas Department of Water Resources
P.O. Box 13987
Capitol Station
Austin, Texas 78711
(512) 475-2041
Dr. Gerald Walsh
Section Leader - Aquatic Toxicology Group
Environmental Research Laboratory
U.S. Environmental Protection Agency
Sabine Island
Gulf Breeze, Florida 32561
(904)932-5311
Mr. Jack L. Witherow
Environmental Engineer - Wastewater Management Branch
Robert S. Kerr Environmental Research Lab
U.S. Environmental Protection Agency
P.O. Box 1198
Ada, Oklahoma 74820
(405) 332-8800
Mr. Glen Yager
U.S. Environmental Protection Agency/Region VII
324 E. llth Street
Kansas City, Missouri 64106
(813) 374-5593
C-8
------- |