\
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OPERATION
AND
MAINTENANCE
INSPECTION
GUIDE
(RCRA Ground-Water Monitoring Systems)
FINAL
m
RCRA Enforcement Division
Office of Waste Programs Enforcement
U.S. Environmental Protection Agency
March 1988
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TABLE OF CONTENTS
Section
Preface [[[ ii
1.0 Overview of the Operation and Maintenance Inspection
1 . 1 Enforcement Objectives of the Operation and Maintenance
Inspection [[[ 1
1.2 Regulatory Basis for the Operation and Maintenance Inspection
[[[ 2
1.3 Relationship of the Operation and Maintenance Inspection to
Other RCRAInspections [[[ 8
1.4 The Operation and Maintenance Inspection Process ................... 9
Office Preparation for the Inspection
The Field Inspection
Post-Inspection Debriefing
Enforcement Follow-up
2.0 Office Preparation for the Field Inspection 12
Analysis of Sampling Plan or Permit Conditions
Review of Permitting and Enforcement Actions
Development of Site-Specific Inspection Instructions
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TABLE OF CONTENTS
Continued
Section Pace
4.0 Compliance Decision-Making 14
Appendices
Appendix A Example of Permit Conditions for an Operation and
Maintenance Program
Appendix B Generic Operation and Maintenance Inspection Form
Appendix C Guide to the Operation and Maintenance of Gas
Displacement Bladder Pumps
Appendix D Questions and Answers
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PREFACE
The 1988 RCRA Implementation Plan introduces the Operation and
Maintenance Inspection (RCRA Ground-Water Monitoring Systems) as a
new type of inspection. This guidance manual has been written for EPA and
state enforcement staff. It describes the Operation and Maintenance (O&M)
Inspection, explains how it fits into EPA's overall enforcement effort, and
explains how to plan and conduct an O&M inspection.
The manual has been organized and written to conform to the steps
enforcement officials would follow in planning and conducting O&M
inspections.
Section One discusses the regulatory basis for O&M inspections, describes
the enforcement objectives underlying O&M inspections, and explains how
the O&M inspection relates to EPA's overall RCRA enforcement program.
Section Two explains how to prepare for the O&M inspection. It describes
what should be done in the office prior to conducting the field inspection and
explores the relationship of the enforcement official and the field inspector.
Section Three describes how to conduct an O&M inspection. A generic
O&M field inspection report form is included as an appendix to help the
inspector focus field activities and record field observations to support
potential enforcement actions.
Section Four describes how to review the inspection report form and decide
if there is direct evidence of violations or whether the possibility exists that
the owner/operator is in violation of the RCRA requirements.
The Appendices include the generic operation and maintenance inspection
form, an example of permit language for operation and maintenance
programs, a guide to operation and maintenance of gas displacement bladder
pumps, and a list of questions and answers. The reader may wish to refer to
the question and answer section (Appendix D) to obtain a quick overview of
this guidance manual.
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SECTION ONE
OVERVIEW OF THE OPERATION AND
MAINTENANCE INSPECTION
1.1 Enforcement Objectives of the Operation and Maintenance
Inspection
The 1988 RCRA Implementation Plan introduces the Operation and
Maintenance (O&M) Inspection as a new type of inspection. The O&M
inspection adds a new perspective and focus to EPA's efforts to ensure the
proper implementation of the RCRA ground-water monitoring regulations.
By the end of FY 1988, enforcement officials will have conducted
Comprehensive (Ground Wate*) Monitoring Evaluations (CMEs) at all
RCRA land disposal facilities. The CMEs conducted to date have focused
heavily on site characterization and on the design of ground-water
monitoring systems. Enforcement actions have been taken to promote the
timely issuance of RCRA land disposal permits. Through these enforcement
and/or permitting actions, EPA and the states will have had the opportunity
to scrutinize the design of every active ground-water monitoring system
regulated under RCRA.
The focus of the enforcement program in FY 1988 and beyond is now
shifting from design review to the review of facility operations
particularly those facility operations related to the generation of ground-
water monitoring data. In general, the O & M inspection focuses on how
owners/operators operate and maintain their ground-water monitoring
systems. Specifically, EPA has designed the O&M inspection to achieve the
following enforcement objectives.
Determine that the owner/operator's personnel who collect ground-
water samples are collecting them properly:
- in accordance with the owner/operator's Part 265 (interim
status) Sampling and Analysis plan or
- in accordance with conditions associated with the sampling and
analysis section of the owner/operator's RCRA permit.
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Determine that the owner/operator's sampling devices are in
working order and that the owner/operator is abiding by
maintenance provisions as outlined in the Sampling and Analysis Plan
(interim status) or in the RCRA permit (permit status).
Determine that individual monitoring wells and
piezometers/observation wells within a ground-water monitoring
system continue to yield representative ground-water samples and
reliable ground-water samples and reliable hydrologic data.
Identify flagrant violations in operation and maintenance programs,
and/or trigger a more thorough scrutiny of the owner/operator's
ground-water monitoring program (i.e., trigger a Case Development
Inspection).
Identify issues or concerns that the enforcement staff should assess in
a future Comprehensive (Ground Water) Monitoring Evaluation.
Collect ground-water elevation data; determine direction(s) of
ground-water flow; and assess, generally the viability of past
decisions made by the owner/operator regarding the number and
placement of monitoring wells.
1.2 Regulatory Basis for the Operation and Maintenance
Inspection
The authority of EPA to require an owner/operator to implement an O&M
program and the authority of the enforcement official to take actions against
poor O&M programs is firmly rooted in regulations under Sections 265,
264, and 270 of RCRA. Table 1 lists those regulations which give EPA the
authority to take enforcement actions related to ground-water monitoring
O&M programs.
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TABLE 1
SUMMARY OF REGULATIONS RELATED TO
OPERATION AND MAINTENANCE PROGRAMS
Interim Status
Description
265.15(b)(l)
265.15(b)(2)
265.15(b)(3)
265.15(b)(4)
265.15(d)
265.73(a)
265.73(b)
265.74(a)
"The owner/operator must develop and follow a written
schedule for inspecting all monitoring equipment,..- and operating and
structural equipment., that are important to preventing, detecting, or
responding to environmental or human health hazards."
"He must keep this schedule at the facility."
"The schedule must identify the types of problems (e.g. malfunctions or
deterioration) which are to be looked for during the inspection..."
"The frequency of inspection...should be based on the rate of possible
deterioration of the equipment...."
"The owner or operator must record inspections in an inspection log or
summary. He must keep these records for at least three years from the
date of inspection. At a minimum, these records must include the date
and time of inspection, the name of the inspector, a notation of the
observations made, and the date and nature of any repairs or other
remedial actions."
"The owner or operator must keep a written operating record at his
facility."
"The following information must be recorded, as it becomes available,
and maintained in the operating record until closure of the facility:..."
(5) "Records and results of inspections..."
(6) "Monitoring, testing, or analytical data..."
"All records, including plans, required under this pan must be furnished
upon request, and made available at reasonable times for inspection..."
"[The owner or operator must report to the Regional Administrator]
Ground-water contamination and monitoring
data as specified in §265.93 and 265.94..."
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TABLE 1
Interim Status
Description
265.90(a)
265.92(a)
265.92(a)
265.94(a)(l)
265.94(a)(2)
"...the owner or operator of a surface impoundment, landfill, or land
treatment facility ... must implement a ground-water monitoring
program capable of determining the facility's impact on the quality of
groundwater in the uppermost aquifer...11
"The owner or operator must obtain and analyze samples from the
installed ground-water monitoring system. The owner or operator must
develop and follow a ground-water sampling and analysis plan..."
"...The plan must include procedures and techniques for:
(1) Sample collection;
(2) Sample preservation and shipment;
(3) Analytical procedures; and
(4) Chain of custody control.
"[The owner or operator must] keep records of the received analyses...,
the associated ground-water surface elevations..."
"[The owner or operator must] report the following ground-water
monitoring information to the Regional Administrator:"
[annual reports of required ground-water monitoring results including
ground-water elevation data].
Permit Status
Description
264.15(a)
264.15(b)(l)
264.15(b)(2)
264.15(b)(3)
264.15(b)(4)
"The owner or operator must inspect his facility for malfunctions and
deterioration, operator errors, and discharges..."
"The owner or operator must develop and follow a written schedule for
inspecting monitoring equipment, safety and emergency equipment,
security devices, and operating and structural equipment..."
"He must keep this schedule at the facility."
"The schedule must identify the types of problems
(e.g. malfunctions or deterioration) which are to be looked for during
the inspection..."
"The frequency of inspection...should be based on the rate or possible
deterioration or the equipment."
"The owner or operator must record inspections in an inspection log or
summary. He must keep these records for at least three years from the
date of the inspection. At a minimum, these records must include the
date and time of the inspection, the name of the inspector, a notation of
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TABLE 1
Permit Status
Description
264.73(a)
264.73(b)
264.74(a)
264.77(c)
264.97(a)(2)
264.97(d)
264.97(e)
264.97(0
264.98(d)
the observations made, and the date and nature of any repairs or other
remedial actions."
"The owner or operator must keep a written operating record
at his facility."
"The following information must be recorded, as it becomes available,
and maintained in the operating record until closure of the facility:
"(5) Records and results of inspections,..
"(6) Monitoring, testing, or analytical data..."
"All records, including plans, required under this part must
be furnished upon request and made available at reasonable times for
inspection...."
"(The owner or operator must report to the Regional Administrator]
As... required by Subpart F..."
"[The ground-water monitoring system must] represent the quality of
groundwater passing the point of compliance."
"The ground-water monitoring program must include consistent
sampling and analysis procedures that are designed to ensure
monitoring results that provide a reliable indicaton
of groundwater quality below the waste management area.
At a minimum, the program must include procedures and techniques
for
(1) Sample collection;
(2) Sample preservation and shipment;
(3) Analytical procedures; and
(4) Chain of custody control."
"The ground-water monitoring program must include
sampling and analytical methods that are appropriate for groundwater
sampling and that accurately measure hazardous constituents in ground
water samples."
"The ground-water monitoring program must include
a determination of the groundwater surface elevation each
time ground-water is sampled."
"The owner or operator must determine ground-water quality at each
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TABLE 1
Permit Status
Description
264.98(e)
264.98(f)
264.99(d)
264.99(e)
264.100(g)
270.30(e)
270.30(j)(l)
270.14(c)(4)
270.30(e)
monitoring well at the compliance point at least semi-annually [when
conducting a detection monitoring program]..."
"The owner or operator must determine the ground-water flow rate and
direction in the uppermost aquifer at least annually [when conducting a
detection monitoring program]."
"The owner or operator must use procedures and methods for sampling
and analysis that meet the requirements of §264.97 (d) and (e).
'The owner or operator must determine the concentration of hazardous
constituents in ground-water at each monitoring well at the compliance
point at least quarterly [when conducting a compliance monitoring
program]..."
"The owner or operator must determine the ground-water flow rate and
direction in the uppermost aquifer at least annually (when conducting a
compliance monitoring program)."
"The owner or operator must report in writing to theRegional
Adminitrator on the effectiveness of the corrective action program. The
owner or operator must submit these reports semi-annually."
"In conjunction with a corrective action program, the owner
or operator must establish and implement a ground-water monitoring
program to demonstrate the effectiveness of the corrective action
program. Such a monitoring program may be based on the requirement
for a compliance monitoring program under §264.99..."
"The owner or operator must report in writing to the Regional
Administrator on the effectiveness of the corrective action program.
The owner or operator must submit these reports semi-annually."
The owner/operator must describe "...any plume of contamination that
has entered the ground-water..."
"Proper operation and maintenance. The permittee shall at all times
properly operate and maintain all facilities and systems of treatment
and control (and related appurtenances) which are installed or used by
the permittee to achieve compliance with the conditions of this permit.
Proper operation and maintenance includes effective performance,
adequate funding, adequate operator staffing and training,..."
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TABLE 1
Permit Status
Description
270.30
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It is important to note that these regulations should not be read and applied
individually. They were written to be applied in a conjunctive manner.
Some of the regulations listed in Table 1 are broad in nature whereas some
are very specific as to actions or conditions that are required of the
owner/operator. When taken as a whole, these regulations require owner/
operators to design and implement a comprehensive operation and
maintenance program for ground-water monitoring systems. They also give
EPA the authority to take action against those owner/operators who fail to do
so. Section Five in this guide, describes how these specific regulations relate
to "Compliance Decision-making" violations EPA is likely to encounter.
1.3 Relationship of the Operation and Maintenance Inspection to
Other RCRA Inspections
There are four types of RCRA compliance inspections that exist in addition to
the O&M inspection. They are: the Comprehensive (Ground Water)
Monitoring Evaluation (CME); the RCRA Compliance Evaluation Inspection
(CEI); the RCRA Case Development Inspection (GDI); and the RCRA
Laboratory Audit Inspection (LAI). Each of these inspections (with the
exception of the LAI) is described in the FY 1988 RCRA Implementation
Plan.
Section 1.1 described, in general, the relationship between the CME and the
O&M inspection. The O&M inspection is less resource-intensive than the
CME, is conducted more frequently, focuses on less detail than the CME, and
often acts as a trigger for additional enforcement actions in the form of a
Case Development Inspection. All RCRA land disposal facilities will receive
either a CME or an O&M inspection each year. All RCRA land disposal
facilities which accept wastes from Superfund sites must receive a CME each
year. Up to one-third of the RCRA land disposal facilities in total will
receive a CME each year. The rest of the population of land disposal
facilities will receive an O&M inspection.
A Case Development Inspection is a comprehensive effort to compile
evidence to support litigation or administrative enforcement actions against
an owner/operator or to establish the need for such actions. Case
Development Inspections are often performed on an as-needed basis in
response to the results from other RCRA inspections (e.g., O&M, CEI,
CME). The O&M inspection may, thus, act as a trigger for CDI.
A Compliance Evaluation Inspection is an examination of all aspects of a
facility's compliance with the RCRA regulations. CEIs are conducted more
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frequently than O&M inspections and are more general in their scope and
application.
EPA has designed the RCRA Laboratory Audit Inspection (LAI) to ensure
that ground-water samples are analyzed properly in the laboratory and that
the laboratory produces high quality analytical data. The RCRA O&M
inspection focuses heavily on the field performance of the owner/operator's
staff in collecting ground-water samples and on the evaluation of the
integrity of the owner/operator's monitoring system. Thus, the O&M
inspection focuses on those activities and procedures which ensure the
collection of representative ground-water samples. The LAI focuses on
those activities and procedures which ensure the generation and reporting of
high quality analytical data.
1.4 The Operation and Maintenance Inspection Process
The Operation and Maintenance inspection requires the participation of a
variety of persons including: field inspectors; enforcement officials
(chemists, hydrogeolegists, and/or engineers); and enforcement counsel.
Table 2 illustrates the generic process regions and states follow in conducting
an O&M inspection. It is important to note the regions and states may, in
fact, use variants of the generic process. The process is not as limited as
illustrated in Table 2.
In Step 1, the field inspector and the enforcement official will meet. The
purpose of their meeting is to plan out the field portion of the O&M
inspection. They will review the owner/operator's sampling and analysis
program, review enforcement and permitting actions taken to date at the
facility, review the owner/operator's operation and maintenance program,
and prepare a list of site-specific observations the field inspector should make
at the facility. In addition to planning out site-specific activities during Step
1, the inspector should make a decision as to the type and level of health and
safety protection that is needed during the inspection (refer to the RCRA
Inspection Manual for guidance). After completion of Step 1, the field
inspector will be prepared to conduct the field portion of die O&M
inspection.
In Step 2, the field inspector will visit the facility. The field inspector will
complete the O&M inspection report form and carry out any special
instructions generated during Step 1.
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TABLE 2
Overview of the
Operation And Maintenance Inspection
1.
STEP
Office
preparation for
field inspection
2.
3.
4.
WHO
Enforcement
official
Field inspector
WHAT
> Review owner/operator's
sampling md analysis program
> Review enforcement and
permitting actions taken to date |
Review the owner/operttor'i
O&M program
Prepare site-specific inspection
instructions
Fill out generic O&M
inspection report
Field inspection
Field inspector
Carry out special
instructions
Review O&M inspection
report and inspector's
observations
Enforcement
official
Post-inspection
debriefing
Make decision
_ Initiate a Case
Development Inspection
- No enforcement action
-Go to step4
Field inspector
Enforcement
official
Issue complaint for
violations
Enforcement
follow-up
Enforcement
counsel
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In Step 3, the field inspector and the enforcement official will meet again.
They will review the O&M inspection report form and discuss the inspector's
observations. The enforcement official will make a decision to pursue one of
the following actions:
initiate a Case Development Inspection,
issue a compliant, or
take no further action.
If enforcement action is warranted, the enforcement official will meet with
counsel. They will prepare and issue a complaint to the owner/operator for
violations detected through the O&M inspection.
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SECTION TWO
OFFICE PREPARATION FOR THE FIELD INSPECTION
The field inspector and the enforcement official work together in
preparation for the O&M field inspection. There are four tasks the field
inspector and the enforcement official must complete prior to the field
inspection. They are:
1. Review and summarize the enforcement and permitting actions
taken to date at the facility.
2. Review and summarize owner/operator's sampling and analysis
program.
3. Review and summarize owner/operator's O&M program.
4. Prepare site-specific inspection objectives.
The field inspector and the enforcement official will use Part One of the
Operation and Maintenance Inspection Form (RCRA Ground-Water
Monitoring Systems) to guide them through the tasks listed above. It has
been written so that when the field inspector and the enforcement official
complete it, they will know:
the number and location of monitoring wells and piezometers at the
facility;
the procedures and techniques the owner/operator uses to collect
ground-water samples;
the details of the owner/operator's operation and maintenance
program in place at the facility; and
the existence and nature of any permitting or enforcement action
which may affect the field inspection.
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SECTION THREE
THE FIELD INSPECTION
The field inspector will complete four tasks during the field inspection. They
are:
1. Review the operating record to identify evidence of deficiencies in the
owner/operator's sampling and/or operation and maintenance program.
2. Visually inspect each well and piezometer for evidence of damage or
deterioration.
3. Obtain site data (i.e., depth to water and depth to bottom of well) for each
well and piezometer.
4. Visually observe the owner/operator's sampling crew as they collect
ground-water samples.
The field inspector will use Part Two of the Operation and Maintenance
Inspection Form (RCRA Ground-Water Monitoring Systems) to guide
him/her through the tasks listed above. Part Two has been written so when
completed, the field inspector will have:
assessed whether the owner/operator's sampling crew departed from
written sampling and analysis procedures contained in the
owner/operator's sampling and analysis plan (interim status) or in
the owner/operator's RCRA permit (permit status);
identified deficiencies in the owner/operator's program to ensure
ongoing maintenance of sampling devices and monitoring
wells/piezometers;
identified deficiencies in the owner/opertor's operating record; and
collected field data that will allow the enforcement official to
construct potentiometric maps and assess the viability of individual
wells.
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SECTION FOUR
COMPLIANCE DECISION-MAKING
The field inspector and the enforcement official will meet after the field
inspection and review Parts One and Two of the Operation and Maintenance
Inspection Form (RCRA Ground-Water Monitoring Systems). With the
inspector's help, the enforcement official will complete three tasks. The
enforcement official will:
1. Construct a potentiometric map using data collected by the field inspector
and compare the map to those generated by the owner/operator.
2. Identify violations in the owner/operator's sampling program and/or
operation and maintenance program (use table as a guide).
3. Identify wells with siltation problems or other problems which may
compromise the integrity of the wells.
After the enforcement official has completed the tasks above, he/she will
choose one of following four options:
1. By virtue of the evidence collected by the field inspector, there are
sufficient grounds to issue a complaint: work with enforcement
counsel to develop and issue the complaint.
2. By virtue of the evidence collected by the field inspector, there may
be sufficient grounds to pursue an enforcement action: initiate a
Case Development Inspection.
3. The field inspection has not indicated compliance problems at the
facility or problems are minor in nature: do not pursue additional
enforcement action.
4. Tnere is cause for concern that the owner/operator may need to
redesign all or a portion of the monitoring system. Concern is not
great enough, however, to prompt the initiation of a Case
Development Inspection. Prepare detailed notes for the file
describing how the next CME at the facility should be focused.
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APPENDIX A
Example of Permit Conditions for an
Operation and Maintenance Program
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APPENDIX A
EXAMPLE OF PERMIT CONDITIONS FOR AN OPERATION
AND MAINTENANCE PROGRAM
The following are excerpts of conditions for a land disposal facility in
detection monitoring. The facility manages a variety of wastes with organic
constituents. The owner/operator was required to install 32 new stainless
steel/PVC wells (i.e., stainless steel in the saturated zone) to supplement 11
existing PVC wells in the monitoring system. The permit writer ordered the
owner/operator to install dedicated gas displacement bladder pumps in
existing and new wells. The permit writer also ordered the owner/operator
to:
collect ground-water samples and water level data on a semi-annual
basis (§264.98);
test the structural integrity of PVC/stainless steel wells every fifth
year and the integrity of PVC wells on an annual basis (§264.15);
implement a written operation and maintenance plan and document
its implementation (§264.15, §264.97, §264.98,270.30).
The permit conditions below relate to the specific requirements written into
the permit by the permit writer. The enforcement official would base
enforcement actions upon the conditions below.
I. Well/Piezometer Installation or Replacement
A. The Permittee shall construct, develop, and equip all new
monitoring wells (32 wells total), as required by permit conditions xxx
through xxx (i.e., permit conditions related to design and
construction), within 270 calendar days after the effective date of this
permit. If a monitoring well must be replaced for any reason during
the term of this permit, it shall be replaced within 30 calendar days of
the date taken out of service. The Permittee shall provide, in the
operating record and in the next annual report, information regarding
the new well including the well construction log and site location.
B. Any replacement piezometers that may be required during the life
of this permit shall be installed as close as practicable to the piezometer
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being taken out of service and, to the extent possible, shall be installed
in accordance with the design and specifications of the piezometer
being taken out of service. If a piezometer must be replaced for any
reason during the term of this permit, it shall be replaced within 30
calendar days of the date taken out of service. The Permittee shall
provide, in the operating record and in the next annual report,
information regarding the new piezometer including the construction
log and site location.
II. Monitoring Program Operation
A. The Permittee shall include all monitoring wells as required by permit
conditions xxx and xxx in the detection monitoring program.
Additionally, each piezometer as required by permit condition xxx
shall be included in the detection monitoring program, for the purpose
of determining direction and rate of flow.
B. The Permittee shall obtain water level (or piezometric head)
measurements from all monitoring wells and from all piezometers for
which water level elevations (or piezometric heads) have stabilized
after construction, prior to each sampling event Measurements for
each monitoring well shall be obtained prior to purging of the well.
The Permittee shall use this data to determine the rate and direction of
ground-water flow annually, as required by 40 CFR §264.98(e). The
Permittee shall use these data, adjusted for barometric efficiency at
each well, to construct water table elevation (or piezometric surface)
contour maps for Level 1 and Level 2 of the xxx Aquifer. These maps
shall be maintained in the operating record and shall be submitted to
the Director and the Administrator with the annual report of ground-
water sample results. Additionally, the Permittee shall submit, with
the contour maps, a written review of the adequacy of the ground-
water monitoring system relative to observed ground water flow
directions.
C. The Permittee shall begin sampling of each new ground-water
monitoring well at the next semi-annual sampling event following
completion of construction of that well, irrespective of the
construction status of other new monitoring wells.
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III. Monitoring Well/Piezometer Maintenance
A. The Permittee shall prepare a written inventory of all sampling
equipment and sampling devices in use at the facility. The Permittee
will also follow written operating, calibration, and maintenance
procedures for each piece of equipment. Documentation of
implementation of procedures will be kept in the operating record.
B. The Permittee will remove all dedicated pumps from the wells in the
monitoring system at least once per year in order to (1) visually
inspect the mechanism and service it, if necessary, and (2) to measure
the total depth of the well. The Permittee will notify the Director of
the date upon which this activity will commence. The maintenance of
pumps shall not interfere with the collection of samples. The results of
this inspection are to be documented and maintained in the operating
record.
Further, any additional maintenance recommended by the
manufacturer shall be documented in the operation and maintenance
record and followed by the Permittee. Malfunctioning pumps are to
be serviced or replaced at once so as not to interfere with the collection
of water quality samples or data pertaining to aquifer characteristics.
The Permittee shall have available either additional pumps or
alternatives (e.g. bailers). Malfunctioning pumps are to be reported
within seven days to the Director, and recorded in the operation and
maintenance record. (Refer to Appendix C for detailed operation and
maintenance procedures for dedicated gas displacement bladder
pumps.)
C. The Permittee shall inspect the integrity of the casing and screen of
each PVC well (wells 1-11) once every year using a down-the-hole
camera; calipers or, if applicable, electrical techniques. The results of
this testing shall be maintained in the operating record. Should casing
and/or screen sustain such damage or strain as to expose the interior of
the well or prevent introduction of sampling devices from above, the
well shall be decommissioned. Prior to the decommissioning, the
Permittee shall apprise the Director of the rationale for the decision.
At that time, a schedule for replacement of the well shall be prepared
and implemented. Replacement shall occur before the subsequent
scheduled sampling. All well repairs and/or replacements shall be
documented in the operating record.
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To summarize:
1. Identify the problem;
2. Apprise the Director/submit schedule for
repair/replacement;
3. Implement repair/replacement; and
4. Resume regularly scheduled sampling.
D. The Permittee shall maintain borehole integrity of each monitoring
well and piezometer, as required by 40 CFR §264.97(c). The
Permittee shall sound each well and piezometer on a routine basis
every year, beginning with the first sampling event after the
completion of construction of all new monitoring wells which are
specified in permit condition xxx. The Permittee shall maintain
records of the depth of well measurements and the silt/sediment
accumulation in the operation and maintenance record for the term of
this permit
E. The Permittee shall redevelop any monitoring well or piezometer
when either of the following two conditions occur.
1. Silt or sediment is determined to have entered the well or
piezometer and has accumulated to a depth of one foot, or
20% of the screen length, whichever is less*; or
2. Yield from the well or piezometer is noted to have
significantly decreased or recovery time has significantly
increased, indicating clogging of the screen and/or sand filter.
F. The Permittee shall maintain all monitoring wells and piezometers in
good working order, making necessary repairs in a timely manner so
that the sampling program is not hindered or delayed in any way. The
Permittee shall maintain an adequate supply of replacement parts and
repair equipment to ensure that each sampling event proceeds on
schedule.
G. The Permittee shall follow the procedures in the Inspection Plan.
Table xx and Rgure xx, which are included in Attachment x of this
* This permit condition is applicable to conditions at this site.
Requirements such as mis should be written to meet site specific
conditions.
O&M Inspection Guide...A-5
-------
OSWER 9950-3
permit for routine inspection of monitoring wells and piezometers.
Visual evidence of damage to, or deterioration of wells or piezometers
must be noted in the operating record.
H. The Permittee shall name a suitably qualified individual to implement
the operation and maintenance program at the facility.
O&M Inspection Guide...A-6
-------
APPENDIX B
Generic Operation and Maintenance
Inspection Form
Part OnePre-Inspection Planning Guide
Part TwoField Inspection Guide
Part ThreeCompliance Decision Making
-------
APPENDIX B
Part One
Pre-Inspection Planning Guide
-------
OSWER-9950-3
PART ONE
The field inspector and the enforcement official will meet and complete four
tasks. Those tasks are: 1) review enforcement and permitting actions taken to date at
the facility, 2) review the owner/operator's sampling and analysis program, 3) review
the owner/operator's O&M program, and 4) prepare site-specific inspection
objectives.
1. Facility identification number
2. Name of facility contact
phone number ( )
3. Address of facility
4. Does the facility have:
Interim Status? (go to 5a)
detection monitoring
assessment monitoring
corrective action (§3008(h))
Permit Status? (go to 5b)
detection monitoring
compliance monitoring
corrective action
5a. Past actions taken at facility (interim status)
Type Datete)
Operation and Maintenance Inspection
Comprehensive (Ground-Water)
Monitoring Evaluation
Case Development Inspection
RCRA Facility Assessment
Compliance Evaluation Inspection
Ground-Water Task Force Investigation
O&M Inspection Guide.. B-1
-------
OSWER-9950-3
Complete the following questions in regard to the actions listed on the previous
page:
Do you have a copy of completed inspection reports or
site studies? Yes No
For each, summarize deficiencies identified in the owner/operator's
sampling program and/or the owner/operator's operation and
maintenance program.
Go to 6a.
O&M Inspection Guide...B-2
-------
OSWER-9950-3
5b. Actions taken at the facility (permit status)
Type Date
Permit Issuance
Operation and Maintenance Inspection
Comprehensive (Ground-Water)
Monitoring Inspection
Case Development Inspection
Compliance Evaluation Inspection
Other
Complete the following in regard to the actions listed above:
Do you have a copy of the permit and copies of inspection reports
completed after permit issuance? Yes No
Summarize deficiencies identified after permit issuance regarding the
owner/operator's operation and maintenance program.
Go to 6b
O&M Inspection Guide...8-3
-------
OSWER-9950-3
6a. Identify enforcement actions issued to the facility in regard to interim status
violations.
Action Datefs^
§3008(a) complaint/order
§3013 complaint/order
§3008(h) complaint/order
§7003 complaint/order
Referral for litigation
Other
Complete the following regarding the actions listed above:
For each, identify if the enforcement action is focused on the owner
operator's sampling and analysis program and/or the owner/operator's
operation and maintenance program. Summarize relevant requirements
imposed on the owner/operator.
Goto?
O&M Inspection Guide. B-4
-------
OSWER-9950-3
6b. Identify enforcement actions issued to the facility after the permit issuance
date.
Action Date(s>
§3008(a) complaint/order
§3013 complaint/order
§3008(h) complaint/order
§7003 complaint/order
Referral for litigation
Other
Complete the following regarding the actions listed above:
For each, identify if the enforcement action focused on the owner/operator's
sampling and analysis program and/or the owner/operator's operation
and maintenance program. Summarize relevant requirements imposed
on the owner/operator.
Goto?
O&M Inspection GukJe...B-5
-------
OSWER-9950-3
7. Review and summarize the owner/operator's sampling
and analysis plan. (Note: Revise or add to the table if permit
conditions dictate a different requirement the owner/operator
must follow.) Does the Sampling and Analysis Plan:
Include provisions for the measurement of static water elevations in each
well prior to each sampling event?
Specify the device to be used for measuring water level elevations?
Specify the procedure for measuring water levels?
Provide for the measurement of depth to standing water and depth to the
bottom of the well to 0.01 feet?
Explain whether dedicated or non-dedicated sampling equipment is used
and the type of sampling equipment?
Describe procedures for evacuating wells?
Provide for the use of sampling devices constructed of inert materials such as
fluorocarbon resin or stainless steel?
Provide for dedicated sampling devices for each well or alternately
provide for decontamination of sampling devices and the collection of
blanks between wells?
Provide for the collection and containerization of samples in the order of
volatilization potential?
Identify the preservation methods and sample containers the
owner/operator will use?
Describe procedures for transferring samples to off-site laboratories?
Describe a chain-of-custody program which includes the use of sample
labels, sample seals, field logbooks, chain-of-custody records, sample
analysis request sheets, and laboratory logbooks?
Include provisions for collection of field, trip, and equipment blanks?
include an inventory of sampling equipment and sampling devices used
as part of the monitoring program?
Include detailed operating, calibration, and maintenance procedures for
each sampling device?
Y/N
O&M Inspection Guide. .6-6
-------
OSWER-9950-3
(Continued from previous page)
Include maintenance schedules for sampling equipment? (Refer to Appendix D for
discussion of maintenance techniques for gas bladder pumps.)
Include decision criteria to be used to replace or repair sampling equipment and/or
monitoring wells?
*Describe in detail sample handling procedures in place at the owner/operator's
laboratory (refer to RCRA Laboratory Audit Inspection Guide for more detail)?
*Describe in detail the procedures that will be used to perform analyses in the
owner/operator's laboratory (refer to RCRA Laboratory Audit Inspection Guide
for more detail)?
*Describe in detail quality assurance/quality control procedures in place? (refer to
RCRA Laboratory Audit Inspection Guide for more detail.)
Y/N
*NOTE: The RCRA Laboratory Audit Inspection Guide (RCRA Ground-Water
Monitoring Systems) describes the information the owner/operator should
include in the Sampling and Analysis Plan regarding the owner/operator's
laboratory program. The inspector may want to supplement the checklist
in this manual with the checklist in the RCRA Laboratory Audit
Inspection Guide while planning an operation and maintenance
inspection.
Go to 8
O&M Inspection Guide.. B-7
-------
OSWER-9950-3
COMMENTS ON SAMPLING AND ANALYSIS PLAN
O&M Inspection Guide...B-8
-------
8. Complete the following table. Use a separate entry for each well and piezometer in the monitoring
system:
Identification
Number
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Type of Well
Sampling Equipment
(pump or bailer)
Depth to Water
Last Inspection
(if available)
Depth to Bottom
Last Inspection
(if available)
Notes/Comments
-------
OSWER-9950-3
After working through Part One, the enforcement official and the field inspector
should know:
the number and location of monitoring wells and piezometers at the
facility;
the procedures and techniques the owner/operator uses to collect
ground-water samples;
the details of the owner/operator's operation and maintenance program in-
place at the facility; and
the existence and nature of any permitting or enforcement action which may
affect the field inspection.
The inspector will need the following equipment to conduct the field inspection:
facility map with locations of wells and piezometers
bound field notebook
camera
weighted tape measure or electronic water level indicator (made of inert
material),
deionized water, hexane (or laboratory strength cleaner), and sterile,
disposable paper towels or gauze for decontamination of tape measure
or probe
surveyor's chain
(Note: additional equipment will be needed if the inspector wishes to
obtain a split sample from the owner/operator.)
O&M Inspection Gukte...B-10
-------
APPENDIX B
Part Two
Field Inspection Guide
-------
OSWER-9950-3
PART TWO
The field inspector will complete four tasks during the field inspection. They are:
1) review the operating record to identify evidence of deficiencies in the owner/operator's sampling
and/or operation and maintenance programs; 2) visually inspect each well and piezometer for
evidence of damage or deterioration; 3) obtain measurements from the operations record of depths
of water levels and well depths for each well and piezometer; and 4) visually observe the owner/
operator's field crew as they collect ground-water samples.
Name of inspectors)
Date(s) of inspection
1. Review the operating record of the facility.
Does the operating record:
Include annual reports of ground-water monitoring results including ground-water level
data from each well and piezometer in the monitoring system?
Include an inventory of all sampling devices and purging equipment in use at the
facility and information on model number, serial number and manufacurers name?
Include detailed operating, calibration and maintenance procedures for each sampling
device?
Describe decision criteria to be used to replace or repair sampling equipment and/or
monitoring wells?
Include schedules for performing operation and maintenance activities related to the
ground- water monitoring system?
Include records for ground- water monitoring which provide information on 1) the date,
exact place and time of sampling or measurements; 2) the individual(s) who performed
the sampling or measurements; 3) the date(s) analyses were performed; 4) the analytical
techniques or methods used; and 5) die results of such analyses?
Include records of all monitoring information including all calibration and maintenance
records?
Include records of monitoring information including determination of ground- water
surface elevations?
Include a determination of ground- water flow rate and direction(s) in the uppermost
aquifier on an annual basis (e.g., prepare a potentiometric map annually using data
collected during the year)?
Provide for more frequent and intensive inspection of wells constructed of non-inert
casing such as PVC? (Refer to Appendix A for permit example.)
Y/N
O&M Inspection GukJe...B-l2
-------
OSWER-9950-3
COMMENTS ON OPERATING RECORD
O&M Inspection Guide...8-13
-------
2. Visually inspect each well and piezometer and complete the table below (one line entry for each well
or piezometer):
Well/
Piezometer
Survey
Mark
Present?
Standing or
Ponded
Water?
Evidence of
Collision
Damage?
Evidence of
Frost
Heaving?
Evidence of
Casing De-
gradation?
Lock in
Place?
Evidence of
Well Sub-
sidence?
Photograph
Taken?
-------
3. Obtain data on depth to standing water and depth to the bottom of each monitoring well and piezometer in the
owner/operator's monitoring system. Record depth measurements to the nearest 0.01 feet. Record the measurements
Dat«
Well/
Piezometer
I.D. No.
Depth to
Water
(04)1')
Depth of Well/
Piezometer
(0.01')
Key:
A - survey elevation marie
B - protective outer casing
C-gas vent
D - concrete apron
E-fitted lock
F - primary casing ""Mf-rial
G - cap for primary casing
H- borehole seal
I - annular space seal
J-well screen
K-filler pack
L-height of riser
M - elevation difference
N - diameter of outer casing
O - diameter of primary casing
P- radius of apron
Q - water level below surface
1. The field inspector has several options in
collecting ground water elevation data.
The inspector may:
a. obtain past data from the operating
record;anoVor
b. take his/her own depth measurements;
and/or
c. obtain data from the owner/operator's
sampling crew.
fi«
-------
OSWER-9950-3
4. Observe the owner/operator's staff as they collect ground-water samples at
several wells. Complete the following table for each well (Note: revise or add to
the table if permit conditions dictate a different requirement the owner/operator must
follow):
Position/Title
Name
Sampling Experience (years and type)
Well Identification Number
Did the sampling crew measure static water levels in the well and well
depths prior to the sampling event?
Did the sampling crew use a steel tape or electronic device totake depth
measurements?
Did the sampling crew record depths to +/- 0.01 feet?
Did the sampling crew follow these procedures:
1. remove locking and protective cap;
2. sample the air in the well head for organic vapors;
3. determine the static water level; and
4. lower an interface probe into Che well to detect
immiscible layers.
If immiscible samples were collected, were they collected prior to well
purging?
Did the sampling crew evacuate low yielding wells to dry ness prior to
sampling?
Did sampling crew evacuate high yielding wells so that at least three
casing volumes were removed?
Did the sampling crew collect the purge water for storage and analysis
or for shipment off-site to a RCRA treatment facility?
Were sampling devices constructed of fluorocarbon resins or stainless
steel?
Y/N
Photograph
Taken
Y/N
O&M Inspection GukJe...B-16
-------
OSWER-9950-3
(Continued)
Well Identification Number
Y/N
Photograph
Taken
Y/N
If the sampling crew used dedicated samplers, did they disassemble and
thoroughly clean the devices between samples?
If samples are collected for organic analyses, did the cleaning procedure
include the following steps:
1. non phosphate detergent wash
2. tap water rinse
3. disnlled/deionized water rinse
4. acetone rinse
5. pesticide-grade hexane rinse?
If samples are collected for inorganic analyses, does the cleaning
procedure include the following steps:
1. dilute acid rinse (HNO3 or HCL)
2. distilled/de-ionized water rinse?
Did the sampling crew take trip blanks, field blanks and equipment
blanks?
If the sampling crew used bailers, were they bottom valve bailers?
If the sampling crew used bailers, was "teflon" coated wire, single strand
stainless steel wire or monofilament used to raise and lower the bailer?
If the sampling crew used bailers, did they lower the bailer slowly to the
well?
If the sampling crew used bailers, were the bailer contents transferred to
the sample container to minimize agitation and aeration?
Did the sampling crew take care to avoid placing clean sampling
equipment, hoses, and lines on the ground or other contaminated surfaces
prior to insertion in the well?
If the sampling crew used dedicated bladder pumps:
Was the compressed gas from an oilless compressor certified quality commercial
compressed gas cylinder? If not, was a suitable oil removal purification system
installed and maintained?
W?.s the bladder pump controller capable of throttling the bladder pump
discharge flow to 100 mi/min or less for continuous periods of at least
20-30 seconds without restricting liquid discharge?
O&M Inspection Guide...B-l7
-------
OSWER-9950-3
(Continued)
W?ll T
-------
OSWER-9950-3
COMMENTS ON SAMPLING PROGRAM
O&M Inspection Guide...B-19
-------
OSWER-9950-3
After working through Part Two, the Held inspector will have:
assessed whether the owner/operator's sampling crew departed from written
sampling and analysis procedures as contained in the owner/operator's sampling
and analysis plan (interim status) or in the owner/operator's RCRA permit (permit
status);
identified deficiencies in the way the owner/operator's sampling crew collected
ground-water samples;
identified deficiencies in the owner/operator's program to ensure on-
going maintenance of sampling devices and monitoring wells/piezometers;
identified deficiencies in the owner/operator's operating record (Does theoperating
record have all the information in it that is required?); and
collected field data that will allow the enforcement official to construct
potentiometric maps and assess the viability of individual wells.
O&M Inspection Guide...B-20
-------
APPENDIX B
Part Three
Compliance Decision-Making
-------
OSWER-9950-3
PART THREE
The field inspector and enforcement official will meet after the field inspection and
review Parts One and Two. The enforcement official will construct a potentiometric
or water table contour map using data collected by the field inspector. The
enforcement official will compare ground-water flow directions (as indicated on the
potentiometric map) by the owner/operator. (Note: the enforcement official will find
owner/operator generated maps in the Part B permit application, in annual reports
and/or from on-site records collected by the field inspector.) Significant differences in
direction of flow may trigger a closer look at the owner/operator's data. The
enforcement official will also identify evidence of violations in the owner/operator's
sampling or operation and maintenance program. After completion of this exercise,
the enforcement official will take one of the following actions:
issue a complaint in conjunction with enforcement counsel for
violations uncovered by the field inspector,
initiate a Case Development Inspection to gather additional
information;
take no follow-up action (no evidence of violations); or
take no follow-up action but prepare instructions to guide a future
CME at the facility.
O&M Inspection Gukte...8-22
-------
OSWER-9950-3
1. Construct a potentiometric (or water level contour) map using water level data
collected by the field inspector. Does the direction of ground-water flow match
owner/operator generated information? Y/N
If yes, go to 2.
If no, goto la.
la. Use all past water level information generated by the owner/operator and
redraw the potentiometric map(s). Does the direction of ground-water flow
match information on the owner/operator's map(s)? Y/N
If yes, go to 2.
If no, consider initiating a Case Development Inspection.
2. Compare well depth information collected by the field inspector to design
specifications of each well in the system. Identify wells with siltation problems.
For wells with siltation problems, consider issuing an order to the owner/operator
requiring the redevelopment or abandonment of the well.
3. Use Table 3 and check violations (or possible violations) uncovered by the field
inspector.
4. Choose one of the following options:
By virtue of the evidence collected by the field inspector, there are
sufficient grounds to issue a complaint. Work with enforcement counsel
to develop and issue me complaint Go to 5.
By virtue of the evidence collected by the field inspector, there may be
sufficient grounds to pursue an enforcement action. Initiate a Case
Development Inspection.
The field inspection has not indicated compliance problems at the facility
or problems are minor in nature. Do not pursue additional enforcement
action.
There is cause for concern that the owner/operator may need to redesign
all or a portion of the monitoring system. Concern is not great enough,
however, to prompt the initiation of a Case Development Inspection.
Prepare detailed notes for the file describing how the next CME at the
facility should be focused.
O&M Inspection Guide...8-23
-------
OSWER-9950-3
Table 3
Relationship of Technical Inadequacies to Ground-Water Standards
This table illustrates examples of situations which may constitute noncompliance on the pan of the
owner/operator. The enforcement official should apply this table in determining if an enforcement
action is warranted on a site-specific basis.
Regulatory
Objectives
Examples of Technical
Inadequacies That
May Constitute Violations
Regulatory
Citations
1. Owner/Operator
must follow
specified
procedures for
collecting ground-
water samples
Failure of owner/operator's
sampling crew to follow written
sampling and analysis plan for
collecting ground-water samples
(interim status)
Failure of owner/operator's
sampling crew to follow permit
conditions related to the collection of
ground water samples (permit status)
265.92(a)
264.97(d)
264.97(e)
264.98(f)
264.99(g)
2. Owner/Operator
must maintain an
operating record
Failure of owner/operator to keep a
written operating record
Failure of owner/operator to keep the
operating record on- site
Failure of the owner/operator to
maintain an operating record which
covers all O&M activities for the prior
three years (Le., gaps in the operating
record)
Inability of owner/operator to
produce a complete operating record at
the time of inspections
264.73(a)
265.73(a)
264.73(b)
265.73(b)
270.30
-------
OSWER-9950-3
(Continued)
TABLES
Regulatory
Objectives
Examples of Technical
Inadequacies that May
Constitute Violations
Regulatory Citations
3. Owner/operator
must implement a
suitable operation
and maintenance
program for ground
water monitoring
systems
(continued)
Failure of owner/operator to describe
decision criteria to be used to replace or
repair sampling equipment and/or
monitoring wells
Failure of owner/operator to maintain
schedules for performing operation and
maintenance activities related to the
ground-water monitoring system
Failure of the owner/operator to
maintain records for ground-water
monitoring which provide information
on 1) the date, exact place, and time of
sampling or measurement; 2) the
individual(s) who performed the
sampling or measurement; 3) the date(s)
analyses were performed; 4) the
analytical techniques or methods used;
and 5) the results of such analyses
Failure of the owner/operator to
maintain records of all monitoring
information including all calibration and
maintenance records
Failure of the owner/operator to
maintain records of monitoring
information including determination of
ground-water surface elevations
Failure of the owner/operator to
assess ground-water flow rate and
direction(s) in the uppermost aquifer on
an annual basis (e.g., each year draw
potentiometric maps(s) using data
collected during the year)
Failure of the owner/operator to
develop procedures to assess degradation
of well casing (refer to Appendix A and
question #13 in Appendix D)
270.30(e)
264.15(b)(3)
265.15(b)(3)
264.15(b)
265.15(b)
264.73(b)(6)
264.15(b)(2)
270.3
-------
OSWER-9950-3
(Continued)
TABLE3
Regulatory
Objectives
Examples of Technical
Inadequacies that May
Regulatory Citations
4. Owner/Operator
must ensure the
continued integrity of
individual wells in the
monitoring system
Wells in monitoring system are silted
in
Wells in monitoring system are
cracked, corroded, or degraded
Wells show high levels of pH
Wells show evidence of frost heaving,
subsidence, or collision damage
Wells show evidence of biolgical
fouling
The hydraulic performance
characteristic(s) of wells changes
Ground-water elevation data collected
by field inspector indicate wells are
improperly placed
Owner/operator does not replace wells
which have failed
265.91 (a)
265.9 l(c)
264.97(a)
264.97(c)
5. Owner/Operator's
ground-water
monitoring system
must continue to
satisfy its design
objectives
Ground-water elevation data collected
by field inspector indicate wells are
improperly placed
Owner/operator does not replace wells
which have failed
270.30(e)
265.9 l(a)
265.9 l(c)
264.97(a)
..
6. Owner/Operator
must collect
ground-water
samples properly
Failure to evacuate stagnant water from the
well before sampling
* Failure to sample wells within a reasonable
amount of time after well evacuation
Improper decisions regarding iltering or non-
filtering of samples prior to analysis (e.g., use of
filtration on samples to be analyzed for volatile
organics)
265.90(a)
265.92(a)
265.93(d)(4)
270.14(c)(4)
O&M Inspection Guide.. B-26
-------
OSWER-9950-3
(Continued)
TABLE 3
Regulatory
Objectives
Samples of Technical
Inadequacies that May
Regulatory Citations
o. Owner/Operator
must collect ground-
water samples
properly
Use of an inappropriate sampling
device
Use of improper sample
preservation techniques
Samples collected with a device
that is constructed of materials
that interfere with sample
integrity
Samples collected with a non-
dedicated sampling device that is
not cleaned between sampling
events
Improper use of a sampling
device such that sample quality is
affected (e.g., degassing of sample
caused by agitation of bailer)
Improper handling of samples
(e.g., failure to eliminate
headspace from containers of
samples to be analyzed for
volatiles)
Failure of the sampling plan to
establish procedures for
sampling immiscibles (i.e.,
"floaters" and "sinkers")
Failure to follow appropriate
QA/QC procedures
(See previous page)
C3&M Inspection uuiae.,.b
-------
OSWER-9950-3
(Continued)
TABLE 3
Regulatory
Objectives
Examples of Technical
Inadequacies that May
Regulatory Citations
6. Owner/Operator
must collect ground-
water samples properly
Failure to ensure sample
integrity through the use of
proper chain-of-custody
procedures
Failure to demonstrate suitability
of methods used for sample
analysis other than those
specified in SW-846
Failure to perform analysis in
the field on unstable parameters
or constituents (e.g., pH, Eh,
specific conductance, alkalinity,
dissolved oxygen)
Use of sample containers that
may interfere with sample quality
(e.g., synthetic containers used with
volatile samples)
Failure to make proper use of
sample blanks
(See previous page)
O&M Inspection Guide...B-28
-------
OSWER-9950-3
5. Keep the following questions in mind as you write the complaint:
What specific regulatory violations do you plan to cite in the complaint?
Is the evidence (i.«., field observations) collected by the field inspector
unassailable?
What do you want the owner/operator to change or add to the operation
and maintenance program?
What do you want the owner/operator to change or add to the sampling
program?
O&M Inspection Guide...B-29
-------
APPENDIX C
Guide to the Operation and Maintenance of
Gas Displacement Bladder Pumps
The RCRA Ground-Water Monitoring Technical Enforcement Guidance
Document (TEGD) strongly endorses the use of dedicated gas displacement
bladder pumps at RCRA facilitities. Appendix C describes important operation and
maintenance considerations regarding gas displacement bladder pumps.
-------
OSWER 9950-3
APPENDIX C
BLADDER PUMP SAMPLING SYSTEM OPERATION
I. Introduction
Bladder pumps are pneumatically operated pumps specifically designed to
deliver ground-water samples with minimal alteration of the sample's
chemical and physical properties. The bladder is the critical element in the
pump, as it serves to isolate the sample from the drive gas and any
contaminants the gas itself may convey. In the first half of the pumping cycle
(see Figure 1), compressed gas is used to squeeze the bladder and force the
sample out the top of the pump and up into the discharge tubing. In the
second part of the pumping cycle, the compressed gas is exhausted to
atmosphere (see Figure 1), allowing fresh well water to refill the pump
bladder through the bottom inlet The discharge and refill cycle sequence is
then repeated for continued pumping, usually through use of an automatic
pump cycle controller.
In addition to bladder pumps, wells are often equipped with separate purge
pumps to achieve higher pumping rates than sampling pumps are designed to
deliver. Gas displacement purge pumps (see Figure 2) operate similarly to
bladder pumps but do not include a bladder and therefore are not appropriate
for actual sample collection.
II. Operating Instructions
Safety, sample quality, and pump flow performance are important
considerations in the selection of compressed gas source used to operate
bladder pumps and gas displacement purge pumps. The compressed gas
source should not exceed the pressure rating of the pump controller, pump,
or tubing. The gas source should be free of cross contaminants, such as
lubricating oils, which could enter the well through leakage from the bladder
pump tubing. Finally, the gas source flow rate should be high enough to
achieve the expected flow rates.
OiM Inspection Guide...C-2
-------
OSWER 9950-3
Figure 1
Bladder Pump Operating Sequence
WATER
AIR
AIR
BLADDER
Discharge Cycle
WATER
Refill Cycle
O&M Inspection Guide...C-3
-------
OSWER 9950-3
Figure 2
Displacement Purge Pump
Only a representation. Not intended as an accurate technical drawing.
O&M Inspection Guide...C-4
-------
OSWER 9950-3
Well Purging
1. Connect the compressed gas source to the pump controller, and the
pump controller to the bladder pump air fitting on the pump cap,
using the instruction and hoses provided by the manufacturer.
2. Activate the compressed gas source to begin pumping. A number of
pump discharge-refill cycles are normally required before the water
fills the discharge tubing and flows to the surface.
3. Typical pump operating cycles have a duration of 6-8 seconds for
both discharge and refill. To achieve maximum flow rate for
purging, follow the sequence below.
a. Adjust the controller flow throttle to maximum
pressure, normally by turning fully clockwise.
b. Adjust the refill and discharge cycles for maximum
length, such as 15 seconds each, and measure the water
volume discharged in a single discharge cycle.
c. Shorten the refill cycle until the volume discharged per
cycle is five to ten percent less than the maximum
determined in step b. Common volumes of commercial
bladder pumps range from 300 to 500 ml.
d. Shorten the discharge cycle until the end of the
discharge cycle just begins to coincide with the end of
water flow from the bladder pump discharge tube.
***
Sample Pumping
Slow flow rates in the range of 100 ml/minute are desired to fill sample
containers without aeration or splashing.
1. Set the discharge cycle to maximum length or approximately 20 to 30
seconds.
2. Adjust the flow throttle for reduced flow, normally fully
counterclockwise.
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OSWER 9950-3
3. During the next discharge cycle slowly increase the flow throttle setting,
normally clockwise, until the desired slow rate is achieved.
***
General Operating Guidelines
1. Deeper wells require higher drive gas pressures and longer refill and
discharge cycles. Collect samples from the bladder pump discharge tube
only (not from the gas contact purge pump for wells so equipped).
2. The compressed gas source is applied to the bladder pump to discharge
water during the discharge cycle. The pump is vented to atmosphere to
refill during the refill cycle.
3. The typical range of useful refill and discharge cycle lengths is
approximately 8 to 20 seconds each.
4. Higher compressed gas pressure levels provide higher pumping rates.
Lower compressed gas pressure levels pump more water per unit
volume of gas.
5. If the pumping rate is unsatisfactory, recheck the cycle lengths according
to the three-step procedure. If the pumping rate is still unsatisfactory,
check all air fitting connections for leaks.
III. System Troubleshooting
Typical bladder pump failure modes and potential causes are listed below,
followed by a system check-out procedure which can be employed prior to
sampling.
1. No or Low Flow Rate.
a. Solids obstructing pump bladder or valves. Too close to pump
bottom or excessive solids present in well. Pump inlet screens may
be advisable.
b. Air leaks in air hoses, tubing, connectors, or at pump. Check system
for leaks. Leaks at pump will be indicated by presence of water
inside air tube.
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OSWER 9950-3
c. Controller settings improper. Check flow throttle and cycle control
positions.
d. Discharge lines frozen. Check drain down weep hole in pump or
tubing for plugging.
2. Bubbles entrained in bladder pump discharge.
a. Bladder puncture. Check pump for signs of sharp or abrasive
solids.
Bladder Pump System Maintenance Procedures
1. Compressor should be true oilless type or include an oil removal system
maintained according to the manufacturer's service schedule, with a visual
indicator of effectiveness of oil removal.
Additionally, any compressor used to operate a bladder pump with a
discharge tube common to the gas contact purge pump should incorporate
additional vapor and paniculate nitration to ensure that sample
conveyance surfaces and tubing are not contaminated.
2. Bladder pump controllers should be tested annually for ability to throttle
pump flow during sample collection without use of restrictor valves in
discharge tubing. The controller should be capable of reducing the output
pressure to the bladder pump to zero PSI while maintaining discharge
(pressure) cycle duration of approximately 20-30 seconds.
3. Bladder pumps' bladder integrity should be checked before every sample
collection by observing whether the sample discharge flow contains gas
bubbles. Bladder leaks will result in gas bubbles in the sample, especially
if long discharge cycles (20-30 seconds) are employed.
In the special case of multilayer bladders with non-fluorocarbon layers,
the pumps should be removed from the well semi-annually for disassembly
and visual inspection of bladder integrity.
Any bladders with leaks should be replaced immediately prior to further
sample collection.
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4. Bladder pump operational condition should be monitored by comparing
trends in maximum flow rate and discharge volume per cycle, as observed
during successive sampling events. Decreases of 20% or more in flow or
discharge volume are generally indicative of either solids accumulating in
the pump or gas leaks in the system. Pump removal and inspection is
required to ascertain the source of the problem.
5. For wells which incorporate gas contact pumps for purging, clear
indication must be given that samples are being collected from the bladder
pump discharge tube and not from the purge pump discharge tube.
6. For combination sample-purge pumps which house the bladder pump
within the gas contact purge pump body, operation of the purge pump
should be controlled at all times to avoid drive gas contact with the sample,
the bladder pump interior, or the interior of the bladder pump discharge
tubing.
O&M Inspection Guide ..C-8
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APPENDIX D
Questions and Answers
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APPENDIX D
QUESTIONS AND ANSWERS
1. What is the purpose(s) of a RCRA Operation and Maintenance
Inspection?
In general, EPA has developed the Operation and Maintenance (O&M)
Inspection to ensure that owner/operators properly collect ground-water
samples and to evaluate the continued viability/integrity of an
owner/operator's ground-water monitoring system. Specifically EPA has
designed the O&M Inspection to accomplish the following:
Determine that the owner/operator's personnel are collecting
ground-water samples properly. For example,
- in accordance with the owner/operator's Part 265 (interim
status) Sampling and Analysis Plan; or
- in accordance with conditions associated with the sampling
and analysis section of the owner/operator's RCRA permit
(permit status).
Collect ground-water elevation data, determine direction(s) of
ground-water flow and assessin a general sensethe viability of
past decisions made by the owner/operator about the number and
placement of monitoring wells.
Determine that individual monitoring wells and
piezometers/observation wells within a ground-water monitoring
system have not deteriorated such that their ability to yield
representative ground-water samples or their ability to yield reliable
hydrologic data have not been compromised.
Determine that the owner/operator's sampling devices are in
working order and that the owner/operator is following the
maintenance provisions as outlined in the Sampling and Analysis Plan
(interim status) or in the RCRA permit (permit status).
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Identify flagrant violations of O&M programs and/or trigger a more
thorough scrutiny of the owner/operator's ground-water monitoring
program (i.e., trigger a Case Development Inspection).
identify issues or concerns the enforcement staff should assess in a
future Comprehensive (Ground Water) Monitoring Evaluation.
2. What is the difference between a RCRA Comprehensive
(Ground Water) Monitoring Evaluation (CME) and a RCRA
Ground-Water Monitoring Operation and Maintenance
Inspection (O&M)?
By the end of FY 1988, enforcement officials should have conducted
Comprehensive (Ground Water) Monitoring Evaluations at all RCRA land
disposal facilities. The CMEs conducted to date have focused heavily on site
characterization and on the design of ground-water monitoring systems (e.g.,
number and placement of wells). Enforcement actions have been taken to
promote the timely issuance of RCRA land disposal permits.
In general, the O&M Inspection is a less resource intensive effort than the
CME. It is conducted more frequently, focuses on less detail than the CME,
and often acts as a trigger for additional enforcement scrutiny in the form of
a Case Development Inspection (CDI). It also acts to focus CMEs which
follow the O&M Inspection in subsequent years.
3. What are the generic phases or steps in an Operation and
Maintenance Inspection? What expertise is needed to support
preparation, field implementation and compliance decision-
making associated with an O&M Inspection?
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Overview of the
Operation And Maintenance Inspection
1.
STEP
Office
preparation for
field inspection
3.
4.
WHO
Enforcement
official
Field inspector
WHAT
Review ownerfoperaior's
sampling and analysis program
Review enforcement and
permitting actions taken to date ]
Review the owner/operator's
O&M program
> Prepare site-specific inspection
instructions
Fill out generic O&M
inspection report
Reid inspector
Field inspection
Cany out special
instructions
Review OAM inspection
report and inspector's
observations
Enforcement
official
Post-inspection
debriefing
Make decision
-Initiate a Case
Development Inspection
- No enforcement action
-Go to step4
Field inspector
Enforcement
official
Issue complaint for
violations
Enforcement
follow-up
Enforcement
counsel
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4. How often should an Operation and Maintenance Inspection
be conducted by enforcement personnel?
All RCRA land disposal facilities will receive either a CME or an O&M
Inspection each year. All RCRA land disposal facilities which accept
Superfund waste site must receive a CME each year. Up to one third of the
RCRA facilities in total will receive a CME each year. The rest of the
population of land disposal facilities will receive an O&M Inspection.
5. What resources (e.g., person loading) are associated with an
average Operation and Maintenance Inspection?
The average O&M Inspection will take approximately 25 person-days to
perform.
6. What is the difference between a RCRA O&M Inspection and
a RCRA Lab Audit Inspection (LAI)?
The RCRA O&M Inspection focuses heavily on the field performance of the
owner/operator's staff in collecting ground-water samples and on the
evaluation of the integrity of the owner/operator's monitoring system. The
O&M Inspection will help EPA and the states ensure that owner/operators
collect representative ground-water samples. The RCRA Lab Audit
Inspection (LAI) focuses on ensuring that ground-water samples are
analyzed properly and that analytical data is reported properly. Thus, the
O&M Inspection focuses on those activities and procedures which ensure the
collection of representative ground-water samples. The LAI focuses on
those activities and procedures which ensure the generation and reporting of
high quality analytical data.
7. Is an Operation and Maintenance Inspection primarily the
responsibility of field inspection personnel, office personnel
(such as engineers, geologists, chemists), or a shared
responsibility?
The O&M Inspection is a shared responsibility between field and office
personnel. Any inspection may ultimately lead to a decision by enforcement
officials to initiate and pursue an enforcement action against an
owner/operator. The O&M Inspection involves the review of documents
which describe die owner/operator's sampling program, collection of field
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OSWER 9950-3
data, review of on-site records, and analysis of field data in the context of
compliance decision-making. The work may involve the talents of field
inspection personnel, office personnel (such as engineers, geologists,
chemists), and enforcement counsel.
8. Should Operation and Maintenance Inspections normally be
scheduled to coincide with an owner/operator's sampling
event?
Yes. One of the major objectives of the O&M Inspection is to ensure that the
owner/operator's field personnel collect ground-water samples properly.
The inspector will observe the owner/operator's field personnel as they
collect samples from several wells. The inspector will watch to ensure that
the owner/operator's field personnel sample wells using techniques and
procedures as described in the owner/operator's Sampling and Analysis Plan
(interim status) or the owner/operator's RCRA Permit (permit status).
Departures from the techniques/procedures described in these documents
could become the basis of an administrative order issued by an enforcement
official.
9. What is the relationship between an owner/operator's
operation and maintenance program and the owner/operator's
ground-water sampling and analysis program?
During interim status, the owner/operator must prepare and implement a
written Sampling and Analysis Plan. This plan should include provisions for
sampling of wells along with provisions for the ongoing maintenance of
sampling equipment and individual wells within a monitoring system. RCRA
land disposal permits should also include similar provisions for the operation
and maintenance of monitoring systems.
10. What are examples of violations that may be uncovered in the
course of conducting an Operation and Maintenance
Inspection?
Examples of possible violations which may be uncovered in the course of
conducting an O&M Inspection include the following:
Failure of the owner/operator to have a written Sampling and
Analysis Plan (interim status) which includes suitable operation and
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OSWER 9950-3
Failure of the owner/operator's Sampling and Analysis Plan to
include provisions for:
- maintenance of sampling equipment;
- detection and correction of problems related to the
integrity of individual wells in the system;
- schedules related to Inspection and maintenance of
sampling equipment; and
- recordkeeping to document adherence to the operation
and maintenance program.
Failure of the owner/operator's field personnel to follow procedures
described in the Sampling and Analysis Plan (interim status) or the
RCRA permit (permit status).
Failure to replace wells which have failed in a timely or appropriate
manner.
Failure to implement procedures to prevent or minimize
deterioration of wells in a monitoring system.
Failure or inability of owner/operator to produce as-built drawings
of individual wells.
Use of data by the owner/operator from wells which do not yield
representative samples for analysis.
Failure to maintain records which document the implementation of
the owner/operator's operation and maintenance program.
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11. What are examples or circumstances which would prompt an
enforcement official to decide an individual well within a
monitoring system has failed (i.e. is unable to produce a
representative ground-water sample and/or reliable
hydrologic data)?
Examples of situations which would lead the enforcement official to decide a
monitoring well is not producing representative samples and/or reliable
hydrologic data include:
visual evidence of physical degradation of casing material (cracks,
corrosion, dissolving);
high pH levels in ground-water data (grout contamination);
significant change in recovery time or other hydraulic characteristics
of the well;
highly turbid samples;
excessive siltation of a well;
subsidence or frost heaving of casing or riser;
evidence of collision or impact damage to the well; or
biological fouling of the well.
12. At a facility with a large number of wells in the RCRA
monitoring system, does the Operation and Maintenance
Inspection require scrutiny of every well in the system, or
may a targeted population of wells be selected for closer
scrutiny?
It is not necessary for the inspector to observe the owner/operator's field
personnel taking ground-water samples at every well within the system. The
field inspector should, however, take depth measurements (to ground water
and to bottom of the well) at all wells in the monitoring system.
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OSWER 99503
13. In reviewing the viability and integrity of individual wells in
a monitoring system, should the Operation and Maintenance
Inspection address construction material choices made by the
owner/operator? For example, if some of the wells in an
owner/operator's ground-water monitoring system are not
constructed of inert materials and the owner/operator
disposes of (or may dispose of) wastes with organic
constituents, should the owner/operator's operation and
maintenance program be designed to detect and assess
physical degradation of casing materials?
Yes. Some casing and screen materials may degrade upon contact with
hazardous constituents. Current research on how different well construction
materials will stand up to exposure to varying levels of contaminants over
time is not conclusive. Until research is more definitive, it is appropriate for
enforcement officials (and permit writers) to insist on a higher standard for
an owner/operator's operation and maintenance program if that
owner/operator's wells are constructed of less inert materials. An operation
and maintenance program to assess degradation of well casing due to attacks
by chemicals may include periodic inspection of the well by the
owner/operator using instruments such as borehole cameras or well calipers.
(Refer to Appendix A for an example of permit conditions.)
14. Is special equipment needed to conduct an Operation and
Maintenance Inspection?
Usually, special equipment is not required to conduct an O&M Inspection.
Equipment the inspector will normally take into the field will include a water
level measurement device (electronic or steel tape) and instruments to take
field readings such as pH, specific conductance, and temperature of ground-
water samples. If collection of samples is deemed necessary by the
enforcement official, the inspector will normally obtain a split sample from
the owner/operator. In some cases, the enforcement official may be
concerned about the physical integrity of individual monitoring wells and/or
piezometers. More sophisticated equipment may be required to assess these
wells including borehole television cameras and well calipers. The
enforcement official may rely on the Technical Enforcement Support (TES)
Contract to obtain these services or, if warranted, could insist the
owner/operator collect this information as an on-going activity in an O&M
program or as a special study effort to prove or disprove degradation of the
monitoring system (e.g. issue a Section 3013 order to compel the
owner/operator to conduct the study).
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15. Are there Held measurements that the inspector will or could
make independently of the owner/operator's field personnel?
Yes. The inspector will normally take depth measurements at all or a
majority of monitoring wells within the owner/operator's ground-water
monitoring system during an O&M Inspection. The inspector will measure:
a) depth to ground water from an established datum point on the
well casing, and
b) depth to the bottom of the well.
Measurements of depth to ground water will allow enforcement officials to
construct potentiometric maps to illustrate the direction of ground-water
flow. This will allow the enforcement official to assessin a general sense
the viability of past decisions made by the owner/operator on the number and
placement of monitoring wells. Measurement of depth to the bottom of a
well will allow the enforcement officials to determine if an individual
monitoring well is silting in. In addition, the inspector may choose to
conduct pump or slug tests at individual wells to assess the hydraulic
performance of wells.
16. What type of documentation should the field
inspector/enforcement official produce after completing an
Operation and Maintenance Inspection?
The field inspector should complete the Operation and Maintenance Field
Inspection Form enclosed in the Operation and Maintenance Inspection
Guide. In addition, the inspector will document observations unique to the
facility at hand. The field inspection and the enforcement official will meet
prior to the field visit and decide how the inspection will differ from the
generic inspection guide and will meet after the inspection to review the
inspector's observations. The enforcement official will rely on the field
inspector's observations to decide if additional enforcement scrutiny of the
facility is warranted.
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17. What is an example of a situation which could lead the
enforcement official to suspect that the owner/operator's
original design assumptions for the existing ground-water
monitoring system are no longer valid?
Perhaps the easiest check of the continued viability of an owner/operator's
system design is the collection and graphical presentation of ground-water
level data (e.g., construction of potentiometric maps). If ground-water flow
directions have shifted (or appear to have shifted) the owner/operator's
original system design may no longer be sufficient to detect or assess the
leakage of hazardous waste or constituents to ground water. Additional
scrutiny of the system design may be necessary via a Case Development
Inspection or a future CME.
18. In cases where the enforcement official suspects that
individual wells in a monitoring system have degraded, does
the enforcement official have the authority to order the
owner/operator to undertake a study to prove or disprove
that degradation has occurred?
Yes. The enforcement official may use Section 3013 authority to order such
a study.
19. If an owner/operator is unable to supply "as-built" drawings
of an individual well within a monitoring system or the "as-
built" drawings do not coincide with field observations, is the
enforcement official justified in insisting that the well not be
used as part of the owner/operator's RCRA ground-water
monitoring system?
Yes. Moreover, the enforcement official may wish to pursue an enforcement
action against the owner/operator in this case.
20. What should an owner/operator include in a ground-water
monitoring operation and maintenance program?
An operation and maintenance program should minimally include the
following:
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OSWER 9950-3
an inventory of sampling equipment and sampling devices used as
part of the owner/operator's monitoring program;
detailed written operating, calibration, and maintenance procedures
for each piece of equipment used in the monitoring program;
periodic checks on past design decisions (i.e. number and placement
of wells) through the collection and graphical representation of
water level data;
an annual maintenance schedule describing what will be done on a
routine basis to ensure sampling devices are operating properly and
to ensure that individual monitoring wells remain as viable
components of the owner/operator's monitoring system;
written decision criteria the owner/operator will use to replace or
repair sampling devices or monitoring wells;
a written record of completed repairs, replacement, and calibration
of sampling devices and monitoring wells;
the appointment of a program manager to oversee the
implementation of the owner/operator's operation and maintenance
program.
21. What records or data generated or held by the
owner/operator will the enforcement official review in the
course of an Operation and Maintenance Inspection?
The primary source of information the inspector will look for on-site is the
owner/operator's operating record An owner/operator is required to have
an operating record as per the requirements of Section 265.73 (interim
status) and Section 264.73 (permit status). Question 20 described the items
the owner/operator should include in an operation and maintenance
program. Proof that the owner/operator has, in fact, properly carried out
the operation and maintenance program can be found in the operating
record.
O&M Inspection Gufde...D-l2
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