oEPA
               United States
               Environmental Protection
               Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER: 9523.05(84)

TITLE; Ground-Water Monitoring Requirements at a Site
    Overlying by Two Aquifers
                APPROVAL DATE. 9-6-84

                EFFECTIVE DATE: 9-6'8A

                ORIGINATING OFFICE: office of solid waste

                E FINAL
                  *            ^           ^
                D DRAFT

                 STATUS:
               A- Pending OMB approval
               B- Pending AA-OSWER approval
               C- For review &/or comment
            [ ]  D- In development or circulating

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PART 270  SUBPART B - PERMIT APPLICATION
                                                DOC:  9523.05(84)
Key Words:

Regulations:

Subject:


Addressee:

Originator:


Source Doc:

Date:

Summary:
Acquifer, Enforcement

40 CFR 270.14(c), 264.222, 265.91(a)

Ground-Water Monitoring Requirements at a Site Overlying by Two
Aquifers

James Reidy, Chief, RCRA Permits Section, Region II

Rich Steimle, HQ Permit Assistance Team
(Steam Team Comments Re: Phillips EGG)

#9523.05(84)

9-6-84
     According to §270.14(c), the permit applicant must characterize the upper-
most aquifer, describe any existing contamination, and provide all information-
necessary to establish an appropriate ground-water monitoring program in the
permit.  If there are two aquifers, a shallow upper till aquifer which transmits
ground water only 2-3 months per year and is dry the remaining months, and a
deeper bedrock aquifer which is recharged by the upper aquifer at the Downgra-
dient Point of Compliance (POC), both aquifers should be monitored.  When the
upper aquifer dries out, monitoring should continue in the lower aquifer.  A
condensed sampling program should be used in the upper aquifer and less frequent
sampling in the lower aquifer.  The applicant's alternative to such a comprehen-
sive monitoring program is a double liner system as provided in §264.222.

     If the applicant is in violation of §265.91(a), the Region can use a com-
pliance order under RCRA §3008.  If the applicant is also in violation of
§270.14(c), the Region should issue a Notice of Deficiency and Warning Letter
to enforce a time schedule for each phase of the investigation.

    .The Steam Team does not recommend issuing short-term permits when the
applicant fails to provide sufficient information to meet the Part B require-
ments.

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                                                                 9523.05 (84)
                                    SEP   6 1984
MEMORANDUM
Subject:  Steam Team Comments re: Phillips E.C.G.

From:     Rich Steimle
          HQ Permit Assistance Team

To:       Jares Reidy, Chief
        .  RCRA Pernits Section, Reg. II

                   *
Background - Phillips, E.C.G. Inc. has applied for a RCRA permit
to continue operating two impoundments at Seneca Falls, N.Y.
One impoundment accepts industrial wastewaters and the other
accepts dewatered wastewater treatment sludge.  Both wastes are
hazardous because of EP Toxicity for lead.

     The site is underlain by two aquifers:  a shallow internit-
tend aquifer in glacial till and a deeper aquifer found in shale
bedrock.  Separation is by 40' to 80' of bedrock.  The shallow
aquifer only transmits water during the wet spring season;
during the remaining period of the year monitoring wells are dry.
This aquifer also recharges the deeper bedrock aquifer, through an
area which is highly fractured.  This recharge zone is at the
downgradient Point of Compliance (POC).

     The applicant has attempted to define the qualitative and
quantitative nature of the local groundwater;  however, the
mixing of aquifers at the POC has caused confusion over which
aquifers to monitor and when.

Issue - Region II specifically asked:

          1.) How much groundwater monitoring data is necessary
              for permitting?
                    •*•
          2.) What options are'available for accelerating the
              gathering of new ground water monitoring data?

          3.) Can & short term permit be issued with a ground
              water monitoring compliance schedule?

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 Discussion - Grcundwater monitoring  data  requirements  for  RCRA permit
 applicants are outlined in  §270.l4(c).  In essence,  the permit
 applicant nust characterize the  uppermost aquifer, describe  any
 existing coritanination, and provide  a,ll information  necessary to
 establish an appropriate groundwater monitoring program in the
 permit.

     The applicant  in  this  case  has  not adequately defined
 th»  nature of the uppermost aquifer  or proposed an appropriate
 i^roundwater nonitoring system.   The  applicant's consultant has
 suggested that the  shallow  aquifer he monitored upgrartient of the
 site for background data arib the deeper aquifer be monitored at
 the  downgradient POC.  We feel that  monitoring two different
 aquifers for comparison purposes is  an uneound technical proposal
 since the water quality in  each  is naturally different.  However,
 we feel that a reliable groundwater  monitoring system can  be
 installed providing certain assumptions are proven.

     The upper till aquifer transmits ground water 2-3 months
 per  year and during that period  it should be considered the
 uppemost aquifer.  Upgradient background samples from this
 aquifer can easily be obtained.  Downgradient water quality
 at ths POC nay be*obtained  from  wells installed in the frac-
 tured bedrock above the lower aquifer.  Statistical comparisions
 should he made on these samples  taken during the 2-3 nonth period
 described above.

     When wells in the upper aquifer dry out, nonitoring should
 continue in the lower aquifer. Even  though the upper aquifer
 coases to recharge the lower aquifer, potential seepage from
 leakage in the lagoons nay  continue  to percolate through the
 fractured bedrock and affect th» quality of the lower aquifer.
 wells installed in the bedrock aquifer near the Ingoons should •
 be considered ns downgradient monitoring points.   Background
 sampling points can be-located east and west of the lagoon,
 parallel to the Senoca River and out of the zone of potential
 leakage.

     Since flow in the upper aquifer iy brief and the system
 is very dynanic, a condensed sampling program should be used.
We suggest 2 to 3 downgradiont wells, 2 upgradient wella,  and
a sampling frequency of twice a month.   In the deeper aquifer,
sampling need not be as frequent;  however,  2 to 3 downgradient
wells and the same nuraber of upgradient wells should be installed.

     The suggested rnonitoring system is complicated and con-
 tingent upon many assumptions which the applicant has not  com-
pletely substantiated.   The applicant may  continue to obtain
 data to develop hydrogeologic models so that the  suggested or a
 similar grounrtwater nonitoring system may  be installed.  How-
 ever, the applicant must  be aware that since the  loc«l  ground-
water systen is complicated, an abnormally large  amount of data
                               -2-

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                        '       '                          •
 is necessary to justify any theoretical models.   Also,  the
 applicant should be required to submit more data then a similar
 facility monitoring one aquifer.             '

      We suggest that the  hydrogeologic description be complete
 by .Spring, 1985.  This is ample tine to install  additional
 wells/  establish background quality in the upper and lower
 aquifer, develop a dependable flow model,  and determine whether
 groundwater contamination is occuring, as  required in 5270.14{c).
 The  level of study during this period should be  very condensed ^
 with very frequent sampling and ground water level measurements.
 The  consultant  should review the data as received to make  any
 changes or modifications  in the investigation.   Since the  .applicant
 is in violation of 265.91(a),  the Region has the option of using
 a  compliance order under  RCRA 3003 since the applicant  is  also  ..-.."
 in violation of §270.14(c), the Region should issue a Notice of
 Deficiency and  Warning Letter to enforce a time  schedule for each
 phase of the investigation.  Guidance on1this procedure can be
 found in the September 9,  1983 memorandum  from Lee Thomas  on      ,
 late and incomplete Part  B Applications,    ..  ;       -  *
                                             •   v-v
      The applicant should be advised that  an alternative to such
 a  comprehensive monitoring!program is a double lined system as
 provided in $264.222.                  .

      We do not  recommend  issuing short term  permits when the
 applicant  has not  provided basic information to  meet the Part  B
 requirements.   This information must be provided through the
 Part B  process  so  that appropriate permit  conditions can be  .
 drafted. The best  mechanisms to address this need,  as suggested
 above,  are a clear indication  to the applicant of Part  B deficiencies
 and  a compliance order to  establish a time period for the  submission
 of information.     .

 Recommendations  -  Advise  Region II that>

   .   1.) The applicant has not adequately  defined the ground-
         water  flow direction  or groundwater quality.

      2.) A comprehensive,  concise  groundwater investigation
         should  be  conducted through  t;he Part B  process
        . to support the'location of  groundwater  monitoring wells
         and delineate any plume of  contamination  if  it  exists.
         This .investigation should  conclude by June  1985.

Contacts                .'.'.'       , ,             .:.
________          .       .   w.         ••»...    .     . .  ,
               • '•      *         '     ••'••'        "•   '
Andrew  Bellina    *                   Rich  Steimle - WH-563
U.S. EPA Region  II          '     .   .  U.S.  EPA
Air  and Waste Management Division    .Permits and  State Programs Division
26 Federal  Plaza    .                  401 M St.  SW
New  York,  N.Y.10278          -        Washington,  D.C. 20460
FTS  264-0548    .                ,     'PTS 382-4754

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