WASTE MANAGEMENT AREA (WMA)
                  and
    SUPPLEMENTAL WELL (SPW)

              GUIDANCE
      United States Environmental Protection Agency
              Office of Solid Waste
              401 M Street, S.W.
            Washington, B.C. 20460
                  FINAL

                 June 1993

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                                                                EC-G-2002-127
15322,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
             WASHINGTON, D.C. 20460
                                 Jill 2 01393
                                                                  Oh' f- ICE O^
 MEMORANDUM                                      SOLID WASTE AND EMERGENCY RESPONSE


 SUBJECT:  Waste Management Area and Supplemental Well Guidance
 FROM:     Dev Barnes, Di
             Permits and State Programs Division, OSW
                                                     jf*

             Susan Bromm, Director^U^^VjO^
             RCRA Enforcement Division, OWPE

 TO:        RCRA Branch Chiefs,
             Regions I-X

       Attached is the June, 1993 "Waste Management Area (WMA) and Supplemental
 Well (SPW) Guidance." This document is intended to provide guidance to regulators
 regarding the implementation of the  WMA and SPW approaches of the proposed
 Ground- Water Amendments Rule (53 FR 28160, July 26, 1988) prior to promulgation of
 the final rule.  We appreciate your earlier thoughtful reviews of this document.

       The proposed Amendments Rule is designed to increase flexibility in the RCRA
 ground-water monitoring program so that monitoring systems may be tailored to site-
 specific conditions and designed to foster the early defection of contaminant releases.
 We believe that the WMA and SPW approaches will provide greater protection of
 human health and the environment, and that EPA can immediately implement the
 approaches in individual facility permits and orders under the authority of the RCRA
 omnibus provision (RCRA §3005(c)(3) and 40 CFR 270.32(b)(2)).

       We have also included an unbound  copy of the guidance so  that you can easily
 make additional copies. If you have  any questions about this guidance or the
 Amendment's Rule, please contact Hugh Davis at (703)  308-8633.

 Attachment

 cc:    Dave Fagan, OSW
       Ken Gigliello, OWPE
       Mimi Newton, OE
       Larry Starfield, OGC
                                                                    Printed on Recycled Paper

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                             TABLE OF CONTENTS


OVERVIEW	, . .  . ill

INTRODUCTION	  1

      1.1    Background and History of the Ground-Water Amendments Rule 	  1
      1.2    Summary  of  the  Multiple Waste  Management  Area (WMA)  and
            Supplemental Well (SPW) Approaches	  2
      1.3    Overlap of the Waste  Management  Area  and  Supplemental  Well
            Approaches	  2
      1.4    Purpose of this Document	  3
      1.5    Organization of this Document	  4

THE MULTIPLE WASTE MANAGEMENT AREA APPROACH 	  5

      2.1    Description and  Intent  of the  Multiple Waste Management  Area
            Approach	  5
      2.2    Criteria for Defining Waste Management Areas	  7
            2.2,1  Number, Spacing, and Orientation of Units  	  7
            2.2.2  Waste Type Handled	   10
            2.2.3  Hydrogeologic Setting	   12
            2.2.4  Site History	   19
            2,2,5  Engineering Design of Units	   21
      2.3    New, Replacement, or Expansion Units	   21
      2.4    Situations Where A Single WMA Is Appr9priate  	   22

THE SUPPLEMENTAL MONITORING WELL APPROACH	   23

      3.1    Description and Intent of the Supplemental Well Approach	   23
      3.2    Defining the Need for Supplemental Monitoring Wells  	   23
      3.3    Hydrogeologic  Site  Conditions  That Might  Require  Supplemental
            Monitoring Wells		   24
            3.3.1  Zones of High Hydraulic Conductivity    	   25
            33.2  Fractures and Fracture Flow	   26
            3.3.3  Perched Water Tables	   29
            3.3,4  Conduits and Conduit Flow in Karst Terrains	   29
            3.3.5  Dipping Geologic Units	   32
            3.3.6  Strong Vertical Gradients	   32
            3.3.7  Natural Fluctuations in Ground-Water Flow Direction	   32
            3.3.8  Human-Induced Fluctuations in Ground-Water
                  Flow Direction  	   35

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      3.4   Presence of Nonaqueous Phase Liquids (NAPLs)  ,	   37

      3.5   Relationship Between SPWs and Point of Compliance (POC) Wells .....   39
            3.5.1   Can Supplemental Monitoring Wells be Used for the Same Purpose
                   as Point of Compliance Wells?	.	,	   39
            3.5.2   What is the Relationship Between Supplemental Monitoring Wells
                   and Background Monitoring Wells?	   42

      3.6   The Use of SPWs for Interim Measures and Corrective Action	   42
            3.6.1   What if Supplemental  Monitoring Wells Indicate the Need for
                   Corrective Action?	   42
            3.6,2   Can Supplemental Monitoring Wells be Used to Implement a
                   Corrective Action?	   42
            3.6.3   Can Supplemental Monitoring  Wells be Used  to  Monitor the
                   Effectiveness of Corrective Action?	,,.,...   43
            3.6.4   Can Supplemental Monitoring Wells be Used  to Implement or
                   Monitor the Effectiveness of Interim Measures or Stabilization?  . .   43

IMPLEMENTING THE MULTIPLE WMA AND THE  SPW APPROACHES  .......   45

      4.1   Permit Application	   45
      4.2   Permit Modification	 ,	   46
      4,3.   Permit Renewal	   47
      4.4   Designating Multiple Monitoring Programs in the Permit	   47

REFERENCES	,	   49

APPENDIX I		,,	A-l

APPENDIX II	A-5

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                                      OVERVIEW
       EPA proposed Amendments to the RCKA Subtitle C ground-water monitoring
regulations on July 26, 1988.  The Agency presently is evaluating comments received from
the public on the proposed rule and is developing the final rule.  The proposed rule contains
several provisions, including the waste management area (WMA) and the supplemental well
(SPW) provisions,  that are intended to increase flexibility in the RCRA ground-water
monitoring program so that monitoring systems may be better tailored to site-specific
conditions and designed to foster the early detection of contaminant releases,  EPA believes
that the WMA and SPW provisions of the proposed rule would provide greater protection of
human health and the environment, and that EPA can immediately implement the WMA and
SPW approaches in individual facility permits under the authority of the RCRA omnibus
provision (RCRA §3005 (c)(3); 40 CFR 27Q.32(b)(2)),  The purpose of this document is to
provide guidance to RCRA permit writers and other interested parties regarding the
implementation of these approaches prior to promulgation of the final rule.1
    1   The policies and procedures established in this document are intended solely as
guidance and are not intended and cannot be relied upon to create any rights, substantive or
procedural, that are enforceable by any party in litigation with the United States,  EPA
reserves the right to act at variance with these policies and procedures and to change them at
any time without public notice.
                                          iii

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                                    CHAPTER 1                       "     :
                                  INTRODUCTION

1.1    Background and History of the Ground-Water Amendments Rule
       The Environmental Protection Agency (EPA) first promulgated regulations governing
ground-water monitoring at hazardous waste management units on July 26, 1982, under
Subtitle C of the Solid Waste Disposal Act, as amended by the Resource Conservation and
Recovery Act of 1976 (RCRA), and the Hazardous and Solid Waste Amendments of 1984
(HSWA).  Under these regulations (40 CFR Part 264, Subpart F), facility owners or
operators are required to install ground-water monitoring systems and to sample ground
water to determine whether there is a release of hazardous constituents from the facility and
contamination of ground water.  If contamination exceeds statistically  significant levels, the
owner or operator must perform compliance monitoring or implement a corrective action
program in accordance with §§264,99 and 264,100,

       EPA proposed Amendments to the Subpart F regulations (hereafter referred to as the
"proposed rule" or "proposed Amendments Rule") on July 26, 1988.  The Agency presently
is evaluating comments received from the public on the proposed rule and is developing the"
final rule.   The proposed rule is intended to increase flexibility in the RCRA ground-water
                                                  » !
monitoring program so that monitoring systems may be tailored to site-specific conditions
and designed to foster the early detection of contaminant releases.  The proposed
Amendments Rule contains a number of provisions, including  the waste management area
(WMA), the supplemental well (SPW), and the unsaturated zone (USZ) provisions. The
SPW and WMA provisions are the subjects of this guidance document. The Agency plans to
implement these provisions in the context of individual permit decisions pursuant to the
authority of the RCRA omnibus provision  (RCRA §3005  (c)(3) and 40 CFR 270 J2(b)(2))
prior to promulgation of the final Amendments Rule. The Office of Solid Waste currently is
developing a companion guidance document for the implementation of the USZ provision.

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1.2    Summary of the Multiple Waste Management Area (WMA) and Supplemental
       Well (SPW) Approaches
       The proposed Amendments Rule contains a provision that allows for the establishment
of multiple WMAs at a facility. The intent of this provision is to provide for protective
point of compliance (POC) ground-water monitoring systems that can detect releases earlier,
or in some cases, detect releases that may otherwise bypass a single POC monitoring system.
This provision also would allow for a separate monitoring program or corrective action for
each WMA at a site, thereby more efficiently focusing resources on areas with releases.  The
designation of a specific area within a facility as a WMA for purposes of a ground-water
monitoring or corrective action program does not limit or otherwise affect EPA's corrective
action authority under RCRA §§3004(u) and 3008(h), which extends  to all contiguous
property under  the owner or operator's control.

       The proposed Amendments Rule also contains the SPW provision that would allow
the Regional Administrator (RA) to require the installation  of wells to supplement the POC
system. The intent of this provision is to allow installation of additional wells where
complicated site conditions caused by hydrogeologic or contaminant characteristics could
allow contaminants to migrate past or away from the POC  without being detected,  SPWs
may function as standard ground-water monitoring wells, piezometers, or as monitoring wells
designed to monitor specific hydrogeologic or contaminant  conditions such as perched water
tables,  fractured bedrock, or nonaqueous phase liquids (NAPLs).  SPWs may be necessary to
improve the performance of the facility's POC ground-water monitoring system.

1.3    Overlap of the Waste Management Area and Supplemental Well Approaches
       The authorities of the proposed  SPW and WMA provisions  may overlap in certain
site-specific cases. This overlap may occur because both proposed provisions allow for extra
wells in cases where releases might not be detected by conventional POC monitoring systems
that are required under §264.91,  [The proposed WMA provision also is intended to promote
earlier  detection of releases that would be detected otherwise].  In general, however, there
are several distinctions between the use of the two approaches.  Where only a few additional

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wells are necessary, or where conditions that warrant additional wells (e.g., reversal of
ground-water flow caused by extreme storm surges) are infrequent, SPWs may be more
appropriate.  SPWs may include wells, such as piezometers, that perform functions other
than standard ground-water monitoring,  as would be conducted at the POC of a WMA.  In
cases where a large number of additional wells are needed to detect a potential release, such
as from a multi-acre unit overlying complex faydrogeology, forming a WMA with an
individualized monitoring program around the unit would be preferred over designating
multiple SPWs.  Chapters 2 and 3 of this document give additional examples of the uses of
the two approaches.

1.4    Purpose of this Document
       The purpose of this document is to provide guidance to RCRA permit writers and
other interested parties regarding the implementation of the WMA and SPW approaches of
the proposed Amendments Rule,  This document will assist permit writers in defining single
or multiple WMAs, and includes a description of the proposed criteria to be considered when
defining WMAs.  The document also provides guidance for identifying the need for SPWs,
describes the difference between SPWs and POC wells, and explains the use of SPWs for
corrective action.  Throughout the document, real and hypothetical sites are presented as
examples.
                                                  > >

       Although EPA has not yet finalized the proposed Amendments Rule, the WMA and
SPW provisions  of the proposed rule ensure greater protection of human health and the
environment, and EPA will immediately implement these approaches  in the context of
individual permit decisions under the authority of the RCRA omnibus provision
(§3005(c)(3) and 40 CFR 270.32(b)(2)). The final Amendments Rule, if adopted in a form
similar to that proposed, would make the multiple WMA and SPW requirements more
explicit and the provisions more readily  implementable.

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1.5    Organization of this Document
       The remainder of this guidance document is organized as follows:

       »     Chapter 2 provides a detailed discussion of the multiple WMA approach and
             discusses each of the factors that should be considered when designating
             WMAs.  Chapter 2 also describes  those situations where a single WMA might
             be appropriate,

       •     Chapter 3 provides a detailed discussion of the SPW approach and describes
             some of the hydrogeologie settings and waste characteristics that may warrant
             implementation of the SPW approach.  Chapter 3 also discusses the
             relationship between SPWs and POC wells, and discusses the use of SPWs for
             interim measures and corrective action,

       •     Chapter 4 concludes this guidance  document by describing how to implement
          .   the WMA and SPW approaches.

Appendix I to this guidance document contains proposed modifications to the model permit
language to be used in implementing the WMA and SPW approaches.  Appendix n compares
                                                   *',
and contrasts the objectives and uses of WMAs and corrective action management units
(CAMUs).

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                                    CHAPTER 2
            THE MULTIPLE WASTE MANAGEMENT AREA APPROACH

2.1    Description and Intent of the Multiple Waste Management Area Approach
       For facilities that contain more than one regulated hazardous waste management unit,
§264.95(b)(2) currently  states that the WMA is described by an imaginary line
circumscribing ail of the regulated units.  A point of compliance (POC) ground-water
monitoring system is located at the downgradient margin of the WMA. The POC is the
point at which both the ground-water protection standard must be met and monitoring must
be conducted, [The POC is defined as a vertical surface located at the hydraulically
downgradient limit of the waste management area that extends down into  the uppermost
aquifer underlying the regulated units.]  However, the current regulations establishing a
single WMA for the entire facility may prevent the early detection of ground-water
contamination in certain circumstances.  For example, if a  contaminant release occurred at
the upgradient edge of a WMA, ground-water contamination would not be detected until the
release migrated to a POC well.  Such a scenario  could result  in extensive contamination of
the uppermost aquifer prior to detection of the release.  The WMA provision of me proposed
Amendments Rule (§264.95{b)(3)) and its implementation in individual permits through the
omnibus provision, is intended to provide an additional margin of safety above that provided
                                                  j',
by the existing regulations in such cases.

       As depicted schematically  in the following diagram, §264,95(b)(3) of the proposed
Amendments Rule would allow the Regional Administrator (RA) to designate the WMA in
individual permits as:  (1) an imaginary line circumscribing a number of  waste management
units, and/or (2) imaginary  lines circumscribing individual  waste management units.
Similarly, permit writers may require such provisions in individual permits where  deemed
necessary  to protect human health and environment based on the omnibus authority.  The
multiple WMA approach would allow individual monitoring requirements to  be defined at
each WMA to:  (1) promote ground-water monitoring and phased corrective  action strategies
that correspond to the magnitude of the contamination hi each waste management area (e.g.,

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one portion of the facility could be in corrective action while another portion is in detection
monitoring), (2) eliminate the potential for a required response action at one unit to
unnecessarily trigger a response action for all units, (3) minimize the time from when a
release occurs to when it is detected, and (4) minimize the volume of aquifer potentially
contaminated prior to detection of a release. The multiple WMA approach will ensure
greater protection of human health and the environment and eliminate unnecessary
monitoring programs or remediation measures.
  Case 1:  WMA is designated by
  an imaginary line circumscribing
  more than one waste
  management unit.

•

Unit A

UnitB



Case 2:  WMAs are designated
by imaginary lines
circumscribtng individual waste
management units.






_
\
.0.

c,
^
^•h.
Unit A
[ \
• A
	 -9'—

Unit B
' i
^*. ^k.

[
—9


*
^^






     POCWell
     Ground-water flow direction
      Waste management areas (WMAs) and corrective action management units (CAMUs)
which are authorized by §264.552 of Subpart S, both circumscribe areas or units containing
hazardous wastes or constituents.  The two designations are made for different purposes,
however, and are independent of one another from a regulatory standpoint. A comparison of
WMAs and CAMUs is given in Appendix II of this document.

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2.2    Criteria for Defining Waste Management Areas
       To determine whether it is appropriate to define single or multiple WMAs, the permit
writer should consider the following five factors:
       1) number, spacing, and orientation of units;
       2) waste types handled;
       3) hydrogeologic setting;
       4) site history; and
       5) engineering design of units.
These criteria are summarized in Table 2-1 and are discussed in the following sections.

       To select a WMA configuration that is protective of human health and the
environment, the five factors should be assessed as to how they affect:

       »      Early detection or lack of detection of releases from the unit(s); and
       •      Ease or difficulty of corrective action.
          *
2,2.1  Number, Spacing, and Orientation of Units
       The number, spacing, and orientation of the waste management units may
significantly affect the designation of WMAs and monitoring programs.   The spatial
                                                     *•,
relationship between units must be  considered in conjunction with other  factors such as
hydrogeology and waste characteristics.  The distance between regulated units may be
sufficient such lhat releases go undetected, or are not detected promptly  with a single WMA.
Example 1 demonstrates how a release from an isolated waste management unit located
within a larger WMA may not be detected until extensive contamination has taken place.

       When the regulated units within a WMA are closely spaced, it usually will not be
necessary to establish separate ground-water monitoring systems for each unit.  However, in
some cases, closely-spaced units should be designated as separate WMAs.  For example, if
the contaminants of concern are not highly mobile, the designation of separate WMAs for
individual units will better provide  for early detection of contaminant releases.

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                                 Table 2-1
                     Criteria Influencing Designation of
                     Multiple Waste Management Areas
 - Number
 - Spacing
 - Orientation
  of Units
* There is more than one regulated unit.
» There are great distances between units.
» Closely-spaced units are oriented such that a monitoring
  system for one unit may not detect releases from the other
  unit(s),  or the source of a release cannot be distinguished.
Waste Type
  Wastes are not highly mobile.
  Wastes managed in closely-spaced units are identical.
  Nonaqueous Phase Liquids (NAPLs) are present.
 Hydrogeologic
   Setting
  There is a ground-water divide between units.
  There is a change in geology between units that influences
  ground-water flow (e.g., due to stratigraphy,  structure,
  fractures, faults, solution channels, etc.).
  A surface water body influences the hydrogeology (e.g., tidal
  influences, gaining/losing streams).
  Perched water zones or other preferred contaminant
  migration pathways are present.
  There are natural or human-induced fluctuations
  in ground-water flow direction
Site History
• Waste type has changed over lime.
» Regulated units are located near solid waste management units
  (SWMUs).
• A unit has been subject to compliance monitoring or
  corrective action in the past.
Engineering
  Design
* There are buried pipes, utility trenches, etc., where a point
  source leak might occur.
» Type of unit is different than adjacent units.
• A unit is poorly constructed or has a high potential for
  failure or leakage.

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                                   WMA Example 1
                   Designation of Multiple Waste Management Areas
                       Due to Significant Distance Between Units
       An automotive parts assembly plant is located in the glaciated central region of the
United States.  The water table is approximately 30 feet below ground surface.  A WMA
comprised of three waste management units (Units A, B, and C) is located in the southwest
portion of the site. An isolated waste management unit, Unit D, is located greater than
1,000 meters upgradient from Units A, B, and C. If all four units were included in one
WMA,  a release from  Unit D would travel a significant distance beneath the WMA prior to
detection at the POC wells. If the resulting contamination were to remain undetected for a
substantial period  of time,  the potential for exposure to contaminants would be greater and
the remediation more complex and expensive.  Alternatively, the release might not migrate
along a straight path towards the POC wells  and might miss the POC  wells and go
undetected. A more protective strategy would be to designate three WMAs (WMA 1, WMA
2, and WMA 3), each  with its own background well(s) to better differentiate sources of
          *
contamination, as  shown hi the figure below.
                        WMA1
                       N
                                        V
                                 POC Wells
                                          Meters
                                  0   150   300    450   600
POC Well
Background Well
                                                         Scale

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                                                                           .
       Finally, the orientation of the units may affect the designation of WMAs. Example 2
shows a large facility with a series of regulated units whose long axis is approximately
parallel to the direction of ground-water flow.  In this example, a release from the most
upgradient unit would not be detected until it had migrated the entire length of the WMA.  In
this situation, it may be appropriate to break the WMA into two or more  WMAs and to
install additional POC wells to ensure more immediate detection of a release.  Alternatively,
supplemental monitoring wells (SPWs, discussed in Chapter 3) may be used to assure
detection of a release from the upgradient regulated units.  SPWs  are intended to supplement
POC  systems that might not adequately detect releases.   If only two or three wells are needed
to assure the detection of a release,  SPWs might be a better option than designating multiple
WMAs,  However, if larger numbers of wells are needed, or if corrective action of any unit
is triggered, subdividing the WMA  into multiple WMAs could direct resources more
efficiently for monitoring and cleanup purposes.

2.2.2  Waste Type Handled
       The. type of waste that each unit contains or has contained in the past can affect
chemical fate and transport or the likelihood of a release. These factors can influence
whether units should be monitored as a single WMA, whether different types  of waste
require different monitoring systems or programs, or whether units or groups of units
                                                     i'>
containing wastes with distinctive properties are appropriate candidates for multiple WMAs.
Two of the most important factors to consider with regard to waste type include the physical
state of the waste (liquid (including  presence of light and dense nonaqueous phase liquids
(LNAPLs and DNAPLs)),  solid,  sludge) and waste chemistry, including such factors as
toxicity, mobility, solubility, and pH.

       The physical state of the waste may influence the likelihood of a release. For
example, if the a  liquid waste is managed in the unit, a leak or structural  failure of the unit
may result in an immediate release to pound water or the unsaturated zone.  Structural
failure of a unit containing solid wastes may not result in contamination of ground water until
infiltrating rain water mobilizes the  contaminants.
10

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                                   WMA Example 2
    Designation of Multiple WMAs Due* to Orientation of Waste Management Units

       A large facility located in the Atlantic Coastal Plain operates a series of surface
impoundments that have been designated as a single WMA, as shown below in Figure A.
The long axis of this single WMA is parallel to the direction of ground-water flow. If a
release from the most upgradient impoundment occurred, the  release would not be detected
until it had migrated the entire length of the WMA to the POC wells. In addition, small
changes in the ground-water flow direction might cause a release to remain undetected as it
migrated to the side of the POC wells.  In this  situation, dividing the existing WMA into two
or more WMAs as indicated in Figure B would have been more protective of human health
and the environment.
J
1 r
Ground-water |
flow t i
"' M|
Release to
ground water
100 M
i
1

JSK^v



^


Point of
N Compliance
Wells
I
i
i
j
boundary

1
1 r
Ground-water |
flow j
I *
New Point of **"^
Compliance Wells r
100M


t. -J

f "t
t. J




I
I
1
WMA
^ WMA
i 	 	 	 1 A .A. — *
• W 9
T f
N Point of
Compliance Wells
                 Figure A
Figure 8
                                                                                    11

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                                                                           t
       Waste chemistry also should be considered in designating WMAs.  For example,
highly soluble or mobile contaminants might be readily detected with a single ground-water
monitoring system monitoring a multi-unit WMA, whereas less mobile contaminants may be
released into the subsurface for a long period of time before they are detected.  Thus, at sites
where there are multiple units containing relatively immobile constituents, a multiple WMA
designation may facilitate the detection of a release prior to extensive subsurface
contamination.  Factors such as pH, hardness of ground water, and organic matter content
can affect the mobility of certain metals.  For example, at high pH and in oxidizing
conditions, trivalent chromium can convert to hexavalent chromium, which is a more mobile
and toxic form.

       LNAPLs and DNAPLs  are particularly difficult to remediate and may require unique
monitoring systems.  Units with the potential to release LNAPLs or DNAPLs should be
considered candidates for designation as single WMAs  so that a sufficiently protective
ground-water monitoring program can be implemented. NAPLs are discussed further in
Section 3,4 of this document.

       It may be possible to  differentiate between releases from multiple units within a single
WMA if waste types differ significantly among units.  In such a situation, multiple WMAs
                                                    >',
may not be needed,  since a release may be readily attributable to the unit containing the
constituents present  in the release.

2.2.3  Hydrogeologic Setting
       The hydrogeologic setting of a facility strongly  influences the potential transport and
migration of contaminants once a release has occurred.  The permit writer should evaluate
flow net and  conceptual geologic/hydrogeologic models to determine if appropriate zones are
being monitored and if the horizontal and vertical placement of the wells is sufficiently
protective.  If different or complex hydrogeologic settings exist at a facility, it might be more
protective to  establish multiple  WMAs at the facility. Key elements of the hydrogeologic
setting that may influence the need to designate multiple WMAs include:
12

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       »     Depth to ground water;
       •     Perched water tables;
       •     Lateral and vertical changes in natural water chemistry;
       •     Geologic structures;
       •     Ground-water flow directions, gradients, and rates; and
       •     Waste management unit effects.

       The SPW approach (discussed in Chapter 3 of this document) also may be applied at
sites with varied or complex hydrogeologic settings.   The SPW approach is intended to
allow for the placement of additional wells when the existing POC wells might not detect
releases.  SPWs can be used for the same purposes as POC wells, or may be specialized
wells (e.g., for monitoring intermittent perched water tables) or simple piezometers.  If few
additional wells are needed, SPWs  may be an appropriate complement to the POC well
system. However, if a large number of additional wells are needed, the designation of an
additional WMA with its own monitoring program may be the most appropriate response.
         *
Ground-Water FlowJDirections. Gradients,  and Rates
       Ground-water flow directions, gradients,  and rates may be the most significant
hydrogeologic factors affecting the  designation of multiple waste management units.  The
permit writer should evaluate flow  nets and potentiometric surface maps submitted by the
owner/operator to assess  the presence of ground-water divides, the potential effects of nearby
surface water bodies (e.g., ponds, lakes, gaining or losing streams, oceans), seasonal or tidal
affects on the water table elevations and hydraulic gradients, effects of pumping of nearby
water supply wells (e.g., local public, facility, or agricultural supply wells), and the presence
of steep downward or upward hydraulic gradients, or other gradients, such as radial flow
from human-made ponds. In certain cases, potentiometric surface maps must be constructed
from measurements made during periods of potential change in ground-water flow direction,
such as during seasonal agricultural pumping or during high or low tides, in order to detect
complex or variable  flow directions.
                                                                                   13

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       Example 3 shows how the presence of a ground-water divide at a facility may affect
the designation of WMAs.  Example 4 shows how the presence of a surface water body at a
facility can affect the designation of WMAs.  Example 5 demonstrates how the use of
multiple WMAs may enhance detection of releases at a site with strong downward hydraulic
gradients.

Depth to Ground Water
       Depth to the saturated zone, when considered with the characteristics of the geologic
material beneath the regulated units, can have a substantial influence on the potential
migration of contaminants released to ground water.  The thickness and transport
characteristics of the unsaturated zone (used synonymously with "vadose zone" in this
document), as well as the contaminant characteristics, influence the potential for contaminant
migration to ground water. If depth to ground water is  shallow, a release from the unit may
result in an immediate release to ground water.  However, even with great depths to the
saturated zone, contaminants released in sufficient quantity also can migrate to the water
table.  In certain situations, such as when depth to the saturated zone is great, monitoring of
the unsaturated zone may enable detection of releases prior to extensive contamination of the
subsurface.  The proposed Amendments Rule contains a provision to allow for unsaturated
zone monitoring at hazardous waste sites.  The Office of Solid Waste currently is
                                                    »',
developing a document to provide guidance on the design and implementation  of unsaturated
zone monitoring systems. Additional information and guidance on unsaturated zone
characterization and monitoring  can be found in Permit Guidance Manual on Unsaturated
Zone Monitoring for Hazardous Waste Land  Treatment  Units (USEPA, 1986) and
Monitpring In the Vadose Zone: A Review of Technical Elements and Methods (USEPA,
1980).

       If depth to ground water is great, the permit writer should  evaluate the potential for
monitoring perched water tables.  The importance of monitoring perched water is discussed
in the following subsection.
14

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                                 WMA Example 3                      ?
            Designation of WMAss in the Vicinity of a Ground-Water Diyide

       A facility located in the nongiaeiated central region of the U.S. is positioned over a
ground-water divide as shown in the figure below.  In this example, the presence of the
ground-water divide affects the appropriate designation of WMAs.  Although closely-spaced,
WMA  1 requires POC wells located on the west side of the WMA, while WMA 2 requires
POC wells located on the east side of the WMA,
                   WMA1
WMA 2
                     Ground-Water Divide
               Ground-Water Flow in Plan View
               Ground-Water Flow in Cross Section
               POC Well
                                                                                 15

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                                 WMA Example 4
                   Effect of Surface Water Body and Ground-Water
                       Flow Direction on Designation of WMAs
      A pesticide manufacturing facility manages sludge in two waste management units.
Ground-water flow in the uppermost aquifer at the facility is towards a stream, which bisects
the site.  The waste management units are located on either side of the stream.  In this
situation, it is appropriate to designate two WMAs as shown in the figure below to detect
releases from each waste management unit.
                   WMA1
                                                                       WMA 2
                 Ground-water Flow in Plan View
                 Ground-water Flow in Cross Section
                 POC Well
                             (Modified from Heath, 1982)
16

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1-730
 -710
 -690
 -670
 -650
 •630
                                         WMA Example 5                       ,
                    Effect of High Downward Gradients on Designation of WMAs

              A pharmaceutical manufacturing facility manages fly ash in two landfills,  A
       hydrogeologic investigation of the facility indicated that a strong downward hydraulic
       gradient is present in a silty sand unit with a relatively low horizontal hydraulic conductivity
       that underlies the landfills. In this scenario, monitoring the uppermost aquifer at wells Cl,
       C2, and C3 would not detect a release from Landfill 1 for many years, and thus would not
       be protective  of human health and the environment.  The hydrogeologic conditions at this
       facility make  it necessary to designate two WMAs as shown in the figure and to install POC
       wells at the downgradient margin of each WMA,
POC wails
(or WMA 1
                                                     200
  400
                                    (Modified from Sara, 1991)
                                                                                         17

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Perched Water Tables
       In more complex unsaturated zone environments, perched water tables may be
present.  These discontinuous saturated lenses may act as conduits or migration pathways for
contaminants released from a waste management unit.  A perched zone may develop on
lower hydraulic conductivity lenses or within lenses or layers of higher hydraulic
conductivity.  A perched zone can be seasonal as it is recharged by precipitation events or by
a fluctuating water table.  Ground-water flow in a perched zone might not follow the local
ground-water flow direction.  Because of these complexities, separate ground-water
monitoring strategies are often needed for perched water tables. A waste management unit
or group of units overlying zones of perched water may be designated as a single WMA.

Lateral  and Vertical Changes in Natural Water Chemistry
       Lateral and vertical changes in sediment  and rock type across a facility can influence
the natural ground-water chemistry and consequently are important factors that must be
considered in the designation of WMAs.  Current EPA  guidance (RCRA Ground-Water
Monitoring:  Draft Technical Guidance. 1992) suggests  that the owner/operator screen
background and POC monitoring wells hi equivalent stratigraphic horizons to obtain
comparable ground-water quality data.  In cases where the geology is complex,  it may be
necessary to designate multiple WMAs so that background and  POC wells are hydraulically
connected.                                          ,,

Geologic Structures
       Geologic structures can have a significant impact on ground-water movement by
acting as preferential flow paths or by acting as barriers or conduits for ground-water flow.
Examples of structures that may influence ground-water movement and direction include
faults, fractures, and folded or dipping formations.

       Steeply dipping alternating formations of differing hydraulic conductivities can cause
preferential  movement of ground water along the strike  of the geologic units with higher
hydraulic conductivities.  Changes in structural characteristics can result in variations in the
direction of ground-water movement at a single  site.
18

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       Faults may serve as either conduits or as barriers to pound-water movement.  If the
fault zone consists of finely ground rock and clay, the material may have a very low
hydraulic conductivity (e.g., less than 1 x  lO^cm/s) resulting in significant differences in
water level across the fault.  If a fault that acts as a barrier to ground-water movement
transects a multi-unit WMA, it may be appropriate to designate separate WMAs for the
hydrogeologically distinct areas on each side of the fault.

Waste Management Unit Effects
       The presence of a waste management unit (e.g.,  a landfill) can affect ground-water
flow under and adjacent to the unit.  For example, the compaction of the clay subgrade and
any overlying clay liners during landfill construction can have a temporary effect (estimated
six months to five or more years) on  the potentiometrie  surface, producing a depression in
the water table.  In other materials, such as silts, surface loading caused by the landfill,
especially the embankments,  produces consolidation of the underlying sediment.  This
consolidation may increase the capillarity of the sediment and result to mounding of the
ground water beneath the unit.

       Because the owner/operator is required to make an annual determination of ground-
water flow direction and rate (including construction of potentiometric surface maps), the
                                                    * '*
permit writer should assess on an ongoing  basis whether the effects of waste management
units on ground-water flow are sufficient to require a modification of WMAs.

2,2.4  Site History
    -  Historical  operating practices at a facility may influence the present-day ground-water
monitoring regime.  Changes in waste management activities and in waste  types handled, the
historical or current  presence of other solid waste management units  (SWMUs), and any
associated remedial actions taking place may influence the need for designating multiple
WMAs.  Example 6 provides an illustration of a  facility at which site history influenced the
designation of a new WMA.
                                                                                     19

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                                   WMA Example 6
             Influence of Site History on the Designation of Multiple WM As  .

       A facility located in the Blue Ridge Region of the eastern United States is located on
thick, layered river deposits.  Ground-water flow is to the west, towards a river.  The site
includes an older SWMU that has contributed to ground-water contamination and is  adjacent
to two regulated waste management units (currently managed as a single WMA, WMA 1).
The two regulated units are  in compliance monitoring.  Two new state-of-the-art regulated
units (New Unit 1 and New Unit 2) are to be constructed upgradient of the older units.  In
this example,  it is appropriate to delineate a new WMA, WMA 2, solely to monitor the  new
waste management units.  If all four regulated units were designated as one WMA with the
same POC wells, all the units would be in compliance monitoring, as Subpart F regulations
require all  regulated units in a WMA to be under the same monitoring program.
                                                                 WMA 2
                                                               (New WMA)
                                                      Ground-water Flow
                                 Older Regulated
                                  Units (WMA 1)
     » POCWell
20

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2.2.5  Engineering Design of Units
       The nature and design of each unit,* including any associated engineered structures and
ancillary equipment, should be considered in the designation of WMAs.  For example, if a
unit is poorly constructed or has a high potential for failure or leakage, the permit writer
should consider monitoring the unit as a single WMA.  Key factors to consider when
evaluating engineering design aspects of waste management units are:

       *     Type of unit (e.g., landfill, surface  impoundment,  or waste pile);
       •     Size of units or WMAs; and
       •     Potential point sources of contaminant releases.

       The type of unit and its design can affect its potential for release and the
appropriateness of its designation as a WMA.  For example, construction materials for liners
of surface impoundments can vary from clay to state-of-the-art double liners with leachate
collection systems.
         *
       The size of a waste management unit also may be a significant factor when considered
along with the geology and hydrogeology beneath  the unit.  If the hydrogeologic setting
changes beneath a unit, the most protective strategy  for the unit may be designating it as a
                                                   *'»
single WMA with an individual ground-water monitoring system.  See Section 2.2.3 of this
guidance for a discussion of hydrogeologic factors influencing the designation of WMAs.

       Point source contaminant releases can occur where ancillary equipment such as buried
pipes and utility trenches are located. Failure of a waste management unit can occur due to
age of the unit, poor design,  proximity to a hill or slope, or excessive liquid pressure in a
pipe or containment vessel.  The potential for point  source contaminant releases or unit
failure should be considered during the designation of WMAs.

2.3    New, Replacement, or Expansion Units
       If a new, replacement, or expansion unit is built adjacent to an existing unit, it may
be appropriate to incorporate the additional unit into the WMA of the existing unit, thus
                                                                                     21

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expanding the WMA overall.  If the additional unit is downgradient of the existing unit, the
POC for a new combined WMA could be at the hydraulically downgradient limit of the
additional unit.  The original POC wells at the existing unit could become informational
wells and would no longer be subject to POC well monitoring requirements.  If old POC
wells must be decommissioned, as in the case of expansion of an existing unit, they must be
decommissioned properly (American Water Works Association, 1988). If the new unit is
upgradient of the existing unit, either the POC for the new combined WMA would remain
the same, or it would be necessary to create a new WMA. In both cases,  it might be
necessary to install new upgradient wells.

2.4    Situations Where A Single WMA Is Appropriate
       Many facilities will not require the designation of multiple WMAs to ensure adequate
protection of human health and the environment.  Four examples of where the designation of
a single WMA generally is appropriate include:

1,     When units are closely spaced and designating multiple WMAs offers neither
       significant increase in protection to human health and the environment, nor earlier
       detection of a release;
                                                    i',
2.     When units contain unique types of waste.  It is easy to identify the source of release
       by correlating the type of contamination  with the waste contained in each unit;

3.     When several units are located over materials with high hydraulic conductivity, such
       as unconsolidatcd beach sand, and detection of a release would not be subject to an
       unacceptable delay; and

4.     When a small number of wells is needed for  additional protection, or the event that
       necessitates additional wells is infrequent, and SPWs are added (for further
       discussion, see Section 1.3).
22

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                                   CHAPTERS
             THE SUPPLEMENTAL MONITORING WELL APPROACH

3.1   Description and Intent of the Supplemental Well Approach
      The proposed Amendments Rule would modify §264,95(a)(2) to allow the Regional
Administrator (RA) to require installation of supplemental wells (SPWs) where complicated
site conditions caused by hydrogeology or contaminant characteristics could allow
contaminants to move past or away from the point of compliance (POC) without detection,
Similarly,  under the authority of the omnibus provision (RCRA §3005(c)(3) and  40 CFR
270.32(b)(2)), the RA may require  such provisions in permits or orders where deemed
necessary to protect human health and the environment.  Monitoring the uppermost aquifer at
the POC will continue to be the primary component of the Subpart F pound-water
monitoring program. However,  in certain cases, SPWs may be necessary to improve the
performance of the facility's POC ground-water monitoring system to protect human health
and the environment.
         •
      SPWs are intended to serve  multiple purposes and, by definition, are supplemental to
the wells required by the RA at the POC.  SPWs may function as standard ground-water
monitoring wells, piezometers,  or monitoring wells designed to monitor specific
                                                 *,
hydrogeologic or contaminant conditions such as perched water tables, fractured  bedrock, or
nonaqueous phase liquids (NAPLs). In addition,  it may be necessary in some cases for the
RA to modify the location, number, and depth of monitoring wells at the POC.  For
example, if SPWs are needed where contamination could bypass POC wells without
detection, the  RA may remove the POC well(s) from the monitoring program.

3.2   Defining the Meed for Supplemental Monitoring Wells
      SPWs may be designated by the RA in cases where site conditions might  allow
contaminants to migrate past or  away from the POC without being detected.  The need for
SPWs must be determined after considering the site  hydrogeology, waste and contaminant
characteristics, and the POC monitoring well system.  The information used to determine
whether SPWs are necessary and to designate SPWs will include existing site characterization
                                                                                23

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data and any other available hydrogeologic studies.  The need for SPWs can be evaluated
during the permitting process or following1 subsequent ground-water monitoring (Chapter 4).

       In general, as site hydrogeology increases in complexity, and as sites increase in size
or number of units, the need for SPWs will be greater.  The following sections (3,3 and 3.4)
describe several hydrogeologic settings and waste characteristics which may warrant the use
of SPWs,  Each section includes real and hypothetical case studies.  These case studies do
not include all possible uses of SPWs, but provide examples of likely scenarios that would
result in contaminant releases going undetected without the use of SPWs,
3.3    Hydrogeologic Site Conditions That Might Require Supplemental Monitoring
       Wells
       The hydrogeologic  characteristics of a site control the movement of ground water and
contaminants.  Consequently, the design of the monitoring system and the need for SPWs
should take into consideration the hydrogeologic characteristics of a site, such as:

       »  "    The subsurface materials below the owner/operator's hazardous waste facility,
              including:
                    The lateral md vertical extent of the uppermost aquifer;
                    The lateral and vertical extent of upper and lower confining
                    units/layers;
                    The geology at the owner/operator's facility (e.g., stratigraphy,
                    lithology, structural setting);  and
                    The chemical properties of the uppermost aquifer and its confining
                    layers relative to local ground-water chemistry and hazardous waste
                    managed at the facility;
       •      Ground-water flow below the owner/operator's hazardous waste facility,
              including:
                    The vertical and horizontal directions of ground-water flow in the
                    uppermost aquifer;
                    The vertical and horizontal hydraulic gradient(s) in the uppermost
                    aquifer;
24

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                    The hydraulic conductivities of the materials that comprise the
                    uppermost aquifer and its confining units/layers; and
                    The average linear horizontal velocity of ground-water flow in the
                    uppermost aquifer.

       If geologic units beneath a site are discontinuous, exhibit variations in thickness
and/or dip, are highly fractured, or contain conduits, hydraulic conductivity and hydraulic
gradients may exhibit frequent and significant variations across a site.  Natural and human-
induced factors such as fluctuating water levels in nearby surface water bodies and on- or
off-site pumping wells also may influence hydraulic gradients and ground-water flow
directions.

       If a hydrogeologic investigation indicates the existence of such complex hydrogeologic
conditions, careful consideration must be given to the need for SPWs to assure the detection
of contaminant releases that might not be intercepted by POC weUs.  The more common
types of  complex hydrogeologic settings that may require SPWs include:
          •              *
       »     Zones of high hydraulic conductivity;
       •     Presence of fractures and fracture flow;
       »     Perched water tables;                    »•,
       •     Presence of conduits and conduit flow in karst terrains;
       •     Dipping geologic units;
       •     Strong vertical gradients;
       •     Natural fluctuations in ground-water flow direction; and
       »     Human-induced fluctuations in ground-water flow direction.

       The following sections provide a discussion of each of these complex hydrogeologic
settings.

3.3.1  Zones of High Hydraulic Conductivity
       In geologic formations consisting of units or zones of largely different hydraulic
conductivities, ground  water generally flows toward, and preferentially migrates in, the zones

                                                                                     25

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with higher hydraulic conductivity.  Examples of higher hydraulic conductivity zones
contained within lower hydraulic conductivity formations include:

       »      Buried river or stream channels;
       •      Buried bedrock valleys;
       •      Fill materials; and
       »      Buried glacial deposits (e.g., eskers, kames, outwash).

       Zones of high hydraulic conductivity located in lower hydraulic conductivity materials
may effectively direct contaminant migration away from POC wells, causing a release to go
undetected.  As shown in Example 1, SPWs can he located in zones of higher hydraulic
conductivity to ensure that a contaminant release will be detected.

3.3.2  Fractures and Fracture Flow
       The migration of contaminants in ground water can be controlled by the orientation,
density, and connectivity of fractures or faults in bedrock (e.g., shale, limestone, granite).
Fractures can increase the hydraulic conductivity of otherwise "impermeable" bedrock and
may provide a conduit or preferential pathway for contaminant migration.  If monitoring
wells have been installed without consideration of the location of fractures and the direction
                                                     »'>
of fracture flow, contaminants might migrate past the POC without being detected.  Although
regional flow patterns are generally  established during site investigations, flow through
fractures is often difficult to predict. Facilities overlying fractured bedrock require additional
investigative techniques (e.g., fracture trace analysis, detailed geologic mapping, geophysical
investigations, fracture  analysis of cores, pump tests to assess anisotropy) to adequately
determine ground-water flow pathways  and to design a protective ground-water monitoring
system.  Example 2 illustrates the use of SPWs  in areas where contaminants might migrate
within bedrock fractures.
26

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                                  SPW Example i
                        Zones of High Hydraulic Conductivity

       The figure below depicts a geologic setting where ground-water flow under a waste
management unit is affected by a buried river channel.  The hydraulic conductivity of the
channel deposit is significantly greater than the surrounding geologic materials and provides a
preferential pathway for ground-water flow and contaminant migration.  The ground-water
flow direction under the waste management unit is complex, with flow lines on the left side
of the unit converging towards the buried channel, because it has high hydraulic conductivity.
A SPW was placed within the buried channel to detect releases that could potentially migrate
down the channel deposits away from the POC wells.
                SPW
                         Location
                        of Buried
                           River
                         Channel
                                 /'funit
to/
                                    Unit
    • POC Well
    O SPW
    -"*- Preferential pathway of
        contaminant migration into
        the buried river channel
    —*- Local ground-water flow
        direction
                                                                                 27

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                                           SPW Example 2
                   Supplemental Wells to Monitor Contaminant Migration in Fractures,

               At a RCRA facility located in Tennessee, contaminants were released into fractured
         bedrock.   The bedrock is made up of highly faulted and jointed  siltstones, shales, and
         limestones with complex ground-water flow that is difficult to monitor.  The facility
         performed a fracture trace analysis, drilled soil borings, and performed surface and borehole
         geophysical investigations to determine the probable locations of subsurface  fracture zones
         that might act as preferential pathways of contaminant migration from  the unit. Because the
         studies revealed that the POC wells were not located in subsurface fracture zones, a SPW
         was installed at the intersection of two identified fracture traces  to intercept  a release that
         might not be detected by the POC wells, as depicted in the plan view below. The cross
         section depicts the subsurface in the vicinity of the SPW.
               CEpSS SECTION
         PLAN VIEW
       FmctunTnc*
                                                                 \ SPW
                                                                                    Unit
MO J-
 • POCWM
 O SPW
--- FncmraTna
                                     (Modified from USEPA, 1991)
         28

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3.3.3  Perched Water Tables
       Geologic formations consisting of interbedded lenses or units of sand and silt or clay
may contain lower hydraulic conductivity lenses that create perched water tables.  In some
cases, perched zones have not been considered part of the uppermost aquifer, and have not
been monitored by Subpart F POC wells.  Nevertheless, these zones of saturation may be
hydraulically connected to the uppermost aquifer (on a permanent or intermittent basis), and
may provide  a primary pathway for contaminants to migrate past the POC.  Permit writers
may need to require SPWs in perched tables to detect releases that migrate past the POC
wells undetected. In addition, if perched conditions cause a release to enter the aquifer
downgradient of the POC wells,  SPWs may be installed in the aquifer downgradient of the
compliance wells.  Example  3 illustrates a  situation where SPWs have been used to detect
contaminant migration in perched water tables.

3.3.4  Conduits and Conduit Flow in Karst Terrains
       In aquifers in karst terrains  dominated by conduit flow, contaminant releases
primarily migrate through subsurface conduits.   The placement of POC wells hi aquifers
dominated by conduit flow is rarely effective.  Conduits often drain to springs which
discharge on land or along surface  water bodies.  Early and reliable detection of contaminant
releases in many karst settings can be performed only at springs and caves,  which are
                                                    i">
commonly outside the boundary of the facility.   EPA recommends the monitoring of seeps,
springs, and cave streams  to supplement POC monitoring well systems in aquifers dominated
by conduit flow.  Springs and cave streams with proven hydraulic connections to a facility
(e.g., as demonstrated by tracer studies) are the easiest and most reliable sites at which to
monitor ground-water quality in terrains where conduit flow predominates (Field, 1988;
Quinlan, 1989; Quinlan, 1990).   A discussion of the sample frequency in aquifers dominated
by conduit flow is given in the November 1992 RCRA Ground-Water Monitoring:  Draft
Technical Guidance (pages 5-18 through 5-21).  Example 4 illustrates the use of
supplemental monitoring points at off-site springs in a karst area.
                                                                                    29

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                                    SPW Example 3
                         Intermittent or-Perched Water Tables
       At a chemical manufacturing facility in West Virginia, POC wells were installed at
the downgradient limit of a regulated waste management unit containing filter press sludge.
The POC wells were screened in the uppermost aquifer, a well-sorted sand.  Ground water
perched on clay lenses within an overlying silt layer served as an additional pathway of
contaminant migration from the unit,  A number of borings were drilled to define the
horizontal extent of potentially low hydraulic conductivity zones above the uppermost
aquifer.  Geologic cross-sections helped identify potential zones of perched water. To ensure
that contaminant migration within the perched zones would be monitored, SPWs were
screened in the perched zones.  SPWs were also screened in the uppermost aquifer at
locations downgradient from the POC wells to detect releases that might migrate past the
POC wells along unidentified perched zones.  A schematic cross-section of the subsurface
hydrogeology and the placement of the SPWs is shown in the figure below.
                               Point of
                             Compliance
                                Well
Supplemental
   Wails
       Clay
       K=lXlO*cnVsec
             Ground-Water Flow
                nun Mm i it|fc.n :
30

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3.3.3  Perched Water Tables
       Geologic formations consisting of interbedded lenses or units of sand and silt or clay
may contain lower hydraulic conductivity lenses that create perched water tables.  In some
cases, perched zones have not been considered part of the uppermost aquifer, and have not
been monitored by Subpart F POC wells.  Nevertheless, these zones of saturation may be
hydraulically connected to the uppermost aquifer (oa a permanent or intermittent basis), and
may provide  a primary pathway for contaminants to migrate past the POC.  Permit writers
may need to require SPWs in perched tables to detect releases that migrate past the POC
wells undetected. In addition, if perched conditions cause a release to enter the aquifer
downgradient of the POC wells, SPWs may be installed in the aquifer downgradient of the
compliance wells.  Example  3 illustrates a situation where SPWs have been used to detect
contaminant migration in perched water tables.

3.3.4  Conduits and Conduit Flow in Karst Terrains
       In aquifers in karst terrains dominated by conduit flow, contaminant releases
primarily migrate through  subsurface conduits.  The placement of POC wells in aquifers
dominated by conduit flow is rarely effective.  Conduits often drain to springs which
discharge on land or along surface water bodies.  Early and reliable detection of contaminant
releases in many karst settings can be performed only at springs and caves, which are
                                                   <.
commonly outside the boundary of the facility.  EPA recommends the  monitoring of seeps,
springs, and cave streams to supplement POC monitoring well systems in aquifers dominated
by conduit flow.  Springs and cave streams with proven hydraulic connections to a facility
(e.g., as demonstrated by tracer studies) are the easiest and most reliable sites at which to
monitor ground-water quality in terrains where conduit flow predominates (Field, 1988;
Quinlan, 1989;  Quinlan, 1990).  A discussion  of the sample frequency in aquifers dominated
by conduit flow is given in tie November 1992 RCRA Groand-Water Monitoring:   Draft
Technical Guidance (pages 5-18 through 5-21), Example 4 illustrates the use of
supplemental monitoring points at off-site springs in a karst area.
                                                                                   29

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                                   SPW Example 3
                         Intermittent or-Perched Water Tables
       At a chemical manufacturing facility in West Virginia, POC wells were installed at
the downgradient limit of a regulated waste management unit containing filter press sludge.
The POC wells were screened in the uppermost aquifer, a well-sorted sand.  Ground water
perched on clay lenses within an overlying silt layer served as an additional pathway of
contaminant migration from the unit. A number of borings were drilled to define the
horizontal extent of potentially low hydraulic conductivity zones above the uppermost
aquifer.  Geologic cross-sections helped identify potential zones of perched water.  To ensure
that contaminant migration within the perched zones would be monitored, SPWs were
screened in the perched zones.  SPWs were also screened in the uppermost aquifer at
locations downgradient from the POC wells to detect releases that might migrate past the
POC wells along unidentified perched zones. A schematic cross-section of the subsurface
hydrogeology and the placement of the SPWs is shown in the figure below.
                               Point of
                             Compliance
                                Wall
Supplemental
   Wells
30

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                                   SPW Example 4
                   Supplemental Monitoring Points in Karst Terrains

       The figure below is an example of a site that is located in a karst terrain where
ground-water flow is predominantly through conduits.  Monitoring wells installed at the POC
may not intercept conduits that are hydraulically connected with the hazardous waste
management unit, even though the POC wells are located more closely to the unit than off-
site springs.  Through dye tracing, investigators can determine if there is a hydraulic
connection between the waste management unit and local springs.  The permit writer can
require  a monitoring program for hydraulically connected  springs that will aid in the
detection of a release from the waste management unit.  In some cases, it also may be
possible to locate SPWs in conduits that are hydraulically connected to the waste management
unit.
                                                    Contaminant
                                                       plume
                                                                        SPW
                                                                                   31

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3.3.5  Dipping Geologic Units
       In settings where interbedded geologic units of differing hydraulic conductivities
exhibit structural or stratigraphic dip, ground-water flow can occur in the down-dip direction
or along strike in one or more of the geologic units.  As a result,  ground-water flow in
dipping geologic units can be locally complex and might not be in the direction of regional
ground-water flow. Consequently, dipping geologic units may create a preferential pathway
for contaminant  migration past the POC.

3.3.6  Strong Vertical Gradients
       Strong vertical gradients can cause ground water to take long or complex flow paths
that are difficult to monitor with standard POC  monitoring systems.   Monitoring wells must
be placed to reflect both the horizontal and the vertical components of flow.  In Example 5,
an upper unit has a strong downward gradient with a small westward flow component. This
westward flow defines the downgradient side in the upper unit from a standard POC
perspective. In contrast,  flow in the connected  underlying unit is primarily horizontal, and to
the east, iii the opposite direction.  SPWs can be used in conjunction with POC wells  to
monitor both zones of the uppermost aquifer.

3.3.7  Natural Fluctuations in Ground-Water Flow Direction
                                                    >'t
       Natural fluctuations in pound-water flow direction may result from tidal or riverine
influences, changes in recharge  rates, seasonal effects,  or precipitation events.  SPWs may be
necessary in areas  where  natural fluctuations  in water level elevations are suspected to cause
variations in ground-water flow directions that might result in contaminant migration past the
POC.  Example  6  illustrates the placement of SPWs for waste management units that are
influenced by lake levels.

       Permit writers also may  consider imposing  additional WMAs to provide a more
protective monitoring system in settings where reversals in ground-water flow direction
occur. This approach would allow for the waste management unit hi Exampje 6 to be a
32

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                                    SPW Example 5
                     Complex Flow With a Strong Vertical Gradient
       In the figure below, an upper flat-lying glacial till is hydraulieally connected to a
lower sand and gravel unit that constitutes a regional aquifer. Ground-water flow in the
upper till unit is to the west and has a strong downward gradient.  In the lower sand and
gravel unit however, ground-water flow is to the east.  Consequently, POC wells installed at
the downgradient limit (the western boundary) of the WMA in the upper till unit would be
ineffective in intercepting a contaminant release migrating downward to the lower sand and
gravel unit. Accordingly, SPWs should be installed in the sand and gravel unit on the
eastern side of the waste management unit (the upgradient side of the waste management unit
in the till).  Alternatively, if the unit were designated as a single WMA, standard POC wells
monitoring the uppermost aquifer could be installed on both sides of the WMA.
  WEST
   A
 — 730
 — 710
EAST
 A
                                                                      pitianM*!*
 -.670
 — 850
  • 630
                                    LMnrfitacialTlt
                                       20Q    4W
                                       FEET
                                         ftamUntt
                               (Modified from Sara, 1991)
                                                                                     33

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                                   SPW Example 6
     fluctuation In Ground-Water Mow Direction Caused by a Surface Water Body

       Natural fluctuations in ground-water flow directions may result from fluctuating water
levels in nearby  surface water bodies, including lakes, rivers, estuaries,  and oceans.  A
facility in northern New York provides an example of how fluctuating lake levels can result
in a reversal of ground-water flow direction, particularly in areas where the hydraulic
gradient  is very  low.  Water levels measured at Time 1 indicate ground-water flow towards
the lake, which is the prevalent ground-water flow direction.  Water levels measured at Time
2, however, indicate ground-water discharge from the lake that results in a complete reversal
of ground-water flow direction.  Depending on the magnitude and frequency of such
reversals, it may be necessary to install SPWs to detect contaminant releases hi the alternate
ground-water flow direction.  The permit could be structured, for example, to require
monitoring of the SPWs only during high lake levels.  Alternatively, if the reversals  are
frequent, the unit could be designated as a WMA and all the wells could be designated  as
POC wells.. Similar natural fluctuations in ground-water flow direction may be caused  by
seasonal  fluctuations in the water table or by major precipitation events.
                TIME1
TIME 2
                                       • POC Well
                                       OSPW
34

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separate WMA, and for POC wells to surround the periphery of the unit.  This option may
be preferred where the fluctuations in ground-water flow are frequent, such as might occur
under tidally influenced conditions.  If flow reversals are infrequent,  SPWs may be more
appropriate.  For example, the monitoring requirements for SPWs might be only to sample
when the lake level reaches a certain critical height that generates flow reversals.  Chapter 2
of this document discusses die designation of additional WMAs.

3.3,8  Human-Induced Fluctuations in Ground-Water Flow Direction
       Various human activities can alter ground-water flow directions at a site either on a
continuous or intermittent basis.  These activities include:
                                                          *i
       •      On- or off-site pumping wells;
       •      Artificial recharge;
       »      Irrigation;  and
       •      Changes in land use patterns (e.g., paving, construction).
         •
       If artificially-induced temporal changes m ground-water flow direction are occurring
or are suspected to occur, SPWs should be installed to monitor for contaminant releases
when ground-water flow  is not in the typically downgradient direction.  Example 7 illustrates
                                                    *'»
the use of SPWs for a waste management unit where ground-water flow  is influenced by
pumping wells.  Careful  consideration should be given to the need for additional background
monitoring wells under conditions where flow direction varies (discussed further in Section
3.5.2).

       As discussed in Section 1.3, the authorities of the proposed WMA and SPW
provisions overlap because both provisions allow for extra wells in cases where releases
might not be detected by POC systems.  When changes in flow direction are regular or
frequent* the multiple WMA approach may be implemented more appropriately for installing
wells that monitor the POC. However, if as in Example 7, where production wells that
cause a local flow reversal are used infrequently, SPWs are more appropriate.
                                                                                    35

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                                     SPW Example 7
         Fluctuation in Ground-Water flow Direction Caused by Pumping Wells

       Human-induced fluctuations in ground-water flow direction may be produced by
pumping wells located near a site, as shown in the figure below.  Hie pumping wells  at this
facility are only operated certain times of the year for specific batch processes.  The pumping
wells produce a cone of depression in the water table and cause ground water to flow radially
towards the pumping wells.  A pumping well can produce either temporal or continual local
and regional changes in ground-water flow direction, depending on the magnitude of
drawdown at the pumping well, the operating schedule of the well, and aquifer characteristics
(hydraulic conductivity, recharge, etc.).  Under these conditions, SPWs may be required to
detect contaminant releases flowing towards the pumping wells and away from the POC as
illustrated below.
                                                                T. Flow direction wbea water
          ,\
                                                                  supply- well a off
                                                                  supply well 1$ operating
                                                                  Point of Compliance Well '
                                                                  SPW
                                                                  Industrial Water Supply WtU
                                                             - - «* Equipotcnti*] floe when water
                                                                  supply well is operating
                                                                  Equipotential line when water
                                                                  supply will is off
36

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3.4    Presence of Nonaqueous Phase Liquids (NAPLs)
       Permit writers should carefully consider how the characteristics of wastes and
contaminants present at a site may influence their migration such that they might migrate past
the POC undetected.  In particular, waste management units that contain NAPLs may be
candidates for SPWs.  This section discusses the migration of NAPLs and provides examples
that describe how SPWs may be used to detect NAPLs,

       NAPLs are liquids that have low solubilities hi water and densities that may be
greater than or less than that of water,  NAPLs have distinctive properties that govern their
fate and transport and may prevent the early detection of contaminant releases or result in
contaminant migration past the POC.  Therefore, when contaminants that have the potential
to exist as NAPLs are present  in facility wastes, the need for SPWs to detect their release
should be considered.

       NAPLs are typically divided into two general categories;  Light nonacjueous phase
liquids (LNAPLs), which have a specific gravity less  than water, and dense nonaqueous
phase liquids (DNAPLs), which are denser than water.  Most LNAPLs are hydrocarbon oils
and fuels.  Most DNAPLs are highly chlorinated hydrocarbons (e.g., carbon tetrachloride,
tetrachloroethylene, and PCBs).  Identifying whether or not a compound exists as an DNAPL
                                                 • >
or an LNAPL can be complicated by  the substance in which it is dissolved.  For example,
free phase PCBs may be denser than water (DNAPL), but PCBs in oil can be transported as
an LNAPL.  Additional information on NAPL migration is provided by USEPA (1989),
USEPA (1991) and Huling and Weaver (1991).

       If wastes at a site contain contaminants that potentially exist as LNAPLs,  it may be
necessary to install SPWs at the water table to prevent contaminants from migrating past the
POC wells undetected. SPWs for monitoring LNAPLs should be screened at the water table
and the screened interval should intercept the water table at its ininimum and maxmium
elevation as determined from historical water level data.   LNAPLs may become trapped in
residual form in the vadose zone and  become periodically remobilized and contribute further
                                                                                37

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to aquifer contamination, either as free phase or dissolved phase contaminants, as the water
table fluctuates and precipitation infiltrates, the subsurface.
       The migration of free-phase DNAPLs may be primarily influenced by the geology,
rather tihan the hydrogeology, of the site.  That is,  DNAPLs migrate downward through the
saturated zone because their density is greater than that of water, and then migrate by gravity
along less permeable geologic units (e.g.,  sloping confining units, sloping clay lenses in more
permeable  strata, or bedrock troughs). Consequently, if wastes disposed at the site are
anticipated to exist in the subsurface as a DNAPL,  the potential DNAPL should be
monitored:

       »      At the "base" of an aquifer  (immediately above a major confining layer);
       •      In structural depressions (e.g., bedrock troughs) in lower hydraulic
              conductivity geologic units mat act as confining layers;
       •      Along lower hydraulic conductivity lenses within units of higher hydraulic
              conductivity;
       •      "Down-dip"  of lower hydraulic conductivity units that act as confining layers,
              both upgradient and downgradient of the WMA; and
       •      In higher conductivity lenses or within fractures.

       Because of the nature of DNAPL migration  (i.e., along structural or stratigrapbic
trends, rather man along hydraulic gradients), SPWs installed to monitor DNAPLs might
need to be  installed both upgradient and downgradient of the WMA.  It may be useful to
construct a structure contour map of lower hydraulic conductivity strata and identify lower
hydraulic conductivity lenses, both upgradient and downgradient of the unit,  along  which
DNAPLs may migrate,  and locate SPWs accordingly. The reader is cautioned however, that
the fate and transport of free phase DNAPL is very complex, and cannot be covered in
sufficient detail in this document.  Ruling  and Weaver (1991) provide a useful explanation
(with additional references) of the properties and behavior of DNAPLs in the subsurface.
38

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       Although NAPLs are frequently described as "immiscible" based on the physical
interface that exists between a mixture of NAPLs aid water, certain compounds found in
NAPLs can dissolve into water in concentrations that are harmful to human health and the
environment. Free phase DNAPL trapped in totergranular pore spaces or existing as pools
or pockets can "bleed" off low but harmful levels of dissolved contaminants that can
contaminate  large volumes of water over decades or longer.  The dissolved constituents from
LNAPL and DNAPL contamination will  migrate in the direction of ground-water flow in the
same fashion as other dissolved constituents.  Consequently, dissolved phase LNAPL and
DNAPL plumes can be detected downgradient of WMAs in POC wells (an exception exists
when a NAPL is diverted by structural or stratigraphic features so that it comes into contact
with the water table downgradient of POC wells, as is illustrated in Example 8).  However,
free phase LNAPLs and DNAPLs may not be detected by POC wells, and may create an
additional dissolved phase that is not detected by POC wells.  Example 8 illustrates the use
of SPWs to monitor DNAPL migration in shallow sand lenses.  Example 9 illustrates the use
of SPWs at one site to monitor for both LNAPLs and DNAPLs.
        •
3.5    Relationship Between SPWs and Point of Compliance (POC) Wells

3.5.1  Can Supplemental Monitoring Wells be Used for the Same Purpose as Point of
       Compliance Wells?                          ''
       The monitoring requirements for POC wells may be applied to SPWs when necessary
to protect human health and the environment. In certain cases, the overseeing Agency would
determine that wells at the POC may not require monitoring or may require a modified
monitoring program if SPWs provide better information on potential contaminant releases.
Ground-water monitoring systems at RCRA facilities are  intended to be tailored to the
specific site characteristics and contaminants expected at a facility; as more ground-water
data and site characterization data are gathered,  more appropriate monitoring locations could
be identified.
                                                                                39

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                                    SPW Example 8
          Supplemental Wells Used to Monitor DNAPL in Shallow Sand Lenses

       This example is based on a case study of a wood preserving facility located in the
 Upper Coastal Plain in South Carolina.  The geologic setting is characterized by an upper
 silty clay unit that overlies a sand unit,  DNAPL has migrated along grain-size discontinuities
 and in sand lenses within the unsaturated zone of the upper silty clay unit. In some areas,
 shallow sand lenses encountered during drilling contain DNAPL, while adjacent over and
 underlying silty clays contain no DNAPL,  Moreover,  the shallow sand lenses have promoted
 DNAPL migration laterally from tihe unit,  and away from POC wells. Therefore, suction
 lysimeters were installed as SPWs to monitor for DNAPL migration in the shallow sand
 lenses. [Note that most published  diagrams depict DNAPL pooling on top of low
 permeability lenses, rather than contained within high permeability lenses, as is the case at
 this actual site. DNAPL fate and transport in the vadose zone can be very complex and is a
 function of a number of factors, including  degree of saturation, entry pressure' of DNAPL,
 pore configuration, viscosity of DNAPL, and other factors.] SPWs also were installed in the
 uppermost aquifer to detect potential dissolved phase contamination emanating from DNAPL.
           CROSS SECTION
PLAN VIEW
                                                    I ,


Regulated
Unit
.m 	 .A- 	 4h 	 A-


                                                                                    o
                                                     * POCWell
                                                     Q SPW to monitor shallow sand lenses
                                                 I    9 SPW to monitor aqutferdowrigraclient of shallow sand lenses
                               Dissolved
                              DNAPL Plume
40

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                                 SPW Example 9
           Supplemental Wells Used to Monitor LNAPL and DNAPL Humes

      This example is based on a case study of a chemical manufacturing facility in Texas.
LNAPL, DNAPL, and dissolved phase contaminants have been detected in ground water at
the site.  The migration of the dissolved contaminant and LNAPL plumes is in the opposite
direction of DNAPL migration.  The DNAPL plume has migrated down dip along the
boundary of a confining layer, and occurs at a depth of approximately 60 feet, despite a
generally upward vertical hydraulic gradient. SPWs have been installed specifically to detect
the LNAPL and DNAPL plumes.
                  Supplemental
                  Monitoring Wall
                  for DNAPL
  Point of
Compliance
   Well
                                                             Supplemental
                                                             Monitoring Well
                                                             for LNAPL
                   Residual
               DNAPL & LNAPL-

                                                                Dissolved &••:••-••
                                                                Chemical %%%&
                                                                 Plume

  DNAPL Flow
  Direction  .
                                                                              41

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3.5.2  What is the Relationship Between Supplemental Monitoring Wells and Background
       Monitoring Wells?
       Background wells installed as part of the ground-water monitoring system under
§264,97(a)(l)  are not considered SPWs,  However, in certain instances, SPWs may be
designated under the omnibus authority in addition to the required background wells to obtain
supplemental information regarding background or upgradient conditions at a site.  For
example, a SPW piezometer may be installed to measure upgradient water-level changes that
are induced by intermittent pumping of agricultural wells.

       Many of the site-specific hydrogeological complexities that warrant the  use of SPWs
also will make background wells difficult to place. For example, at sites with locally
complex flow  paths,  such as might be caused by fractured and folded bedrock, determining
hydraulicaily connected upgradient locations will require thorough site investigation.  In  all
cases where SPWs are determined necessary,  an assessment of the adequacy of existing
background wells, and the need for additional wells should be made.
          *
3.6    The Use of SPWs for Interim Measures and Corrective Action

3.6.1  What if Supplemental Monitoring Wells Indicate the Need for  Corrective  Action?
                                                    r>
       The RA has the authority to require corrective  action  when necessary to protect
human health and the environment if constituents are detected above specified concentrations
in SPWs.

3.6.2  Can Supplemental Monitoring Wells be Used to Implement a Corrective Action?
       The use of SPWs for cortective action purposes is appropriate in some  circumstances
(such as for ground-water extraction,  soil flushing, venting, or vapor extraction). The RA
has the authority to require the use of SPWs for corrective action purposes under the
omnibus and corrective action authorities of RCRA §§3004(a) and (u), 300S(c)(3),  and
3008(h).
42

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3.6.3  Can Supplemental Monitoring Wells be Used to Monitor the Effectiveness of
       Corrective Action?
       SPWs can be used to monitor the effectiveness of corrective action.  SPWs may be
used to collect routine corrective action performance data such as water level measurements,
vadose zone sampling (of soil gas as well as pore water), and sampling of ground water in
the uppermost aquifer. SPWs that are installed to detect NAPL releases can be used for
monitoring the effectiveness of corrective action measures to remediate NAPL contamination.

3.6.4  Can Supplemental Monitoring Wells be Used to Implement or Monitor  the
       Effectiveness of Interim Measures or Stabilization?
       Similar to their use in corrective action, SPWs may be used to implement and monitor
the effectiveness of measures taken to stabilize the migration of contaminants until a final
corrective action is  selected.
                                                                                    43

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                                    CHAPTER 4
      IMPLEMENTING THE MULTIPLE WMA AND THE SPW APPROACHES

       The multiple WMA and the SPW approaches in this guidance may be applied under
three circumstances:  permit application,  permit modification, and permit renewal.  Pending
promulgation of the final Amendments Rule, the RCRA omnibus provision (RCRA §3005
(e)(3) and 40 CFR 270.32(b)(2)) provides authority for designating multiple WMAs and
requiring SPWs.  For each facility, information relevant to the desifnatioa of WMAs or
SPWs will be recorded in the administrative record for the permit as required under §124.9.
As with other permitting decisions, if the permittee does not agree with the oversight
authority's decision regarding the WMAs or SPWs, he or she has the right to administrative
or judicial appeal.

4.1    Permit Application
       WMAs should be designated in a  facility's permit application. Under §270.14(c)(3),
the owner/.operator must submit a proposed WMA delineation with Part B of the permit
application.  During the permit application process, the permit writer may advise owners and
operators to carefully evaluate the WMA delineation based on the considerations set out in
this guidance and the proposed  Amendments Rule,  The considerations,  which are discussed
                                                  i",
in Chapter 2, include the number,  spacing, and orientation of waste management units;  waste
type handled; hydrogeologic setting; site  history; and engineering design of units.  Depending
on the conditions at the site, each one of these criteria can affect the designation of WMAs.
The RA has the authority to accept or modify the proposed WMAs submitted by the owner
or operator under §270.14(c)(3), and should select the appropriate WMA(s) necessary to
protect human health and the environment by considering the criteria previously mentioned.
The permit must specify those actions necessary to minimize monitoring and response
complications posed by the modification to the WMA,

       SPWs also should be designated in a facility's permit application.  Under
§270.14(c)(3) and (5), the owner/operator must submit in the permit application the proposed
locations of ground-water monitoring wells and a description of the proposed ground-water
                                                                                  45

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monitoring program required under Subpart F.  If the need for SPWs is apparent during the
initial drafting of the permit, the number, location, and depth of SPWs should be specified in
the permit application.

4.2    Permit Modification
       The multiple WMA and the SPW approaches in this guidance may be applied as part
of a permit modification.  Permit modifications may take place at the request of either the
RA or the owner/operator pursuant to §§270.41 or 270,42, respectively.  If the RA feels that
there is a need for designating multiple WMAs or SPWs to protect human health and the
environment, he or she can request a modification of the permit pursuant to §270.41, and
cite the omnibus provision as authority for the modification.

       If the RA or the facility owner/operator initiates a permit modification because of the
generation of new wastes; the construction of new, expansion, or replacement waste
management units; evidence of a release; removal or delisting of waste, etc., the permit
writer should assess the existing WMA configuration at the facility. The assessment will
need to determine  if the designated WMAs continue to be sufficiently protective of human
health and the environment. The  assessment could result in a single WMA being divided
into multiple WMAs, or multiple  WMAs being even further divided.  The assessment also
                                                     j,
could result in consolidating WMAs into fewer WMAs or into a single WMA.  An
owner/operator with a multi-unit facility designated as a single WMA also may request
delineation of multiple WMAs,  This request may be made to avoid a facility-wide response
action after compliance monitoring or corrective action has been triggered (until the permit is
modified, the owner/operator would have to implement compliance monitoring or corrective
action at the designated WMA).  However, the designation of multiple  WMAs does not limit
or otherwise affect the site-wide and off-site corrective action authorities under §§3004(u),
3004(v), and 3008(h).

       The proposed SPW provision also can be applied as part of a permit modification if
the need for SPWs becomes apparent after permit issuance.  Hydrogeologic or contaminant
characteristics that create complex contaminant flow patterns might not be evident until the
46

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implementation of the monitoring program.  For example, the RA may consider the necessity
for SPWs after a Comprehensive Ground-Water Monitoring Evaluation (CME) or Operation
and Maintenance (O&M) Inspection is performed. The CME is a detailed evaluation of the
adequacy of the design and operation of ground-water monitoring systems at RCRA facilities.
The CME or O&M may show that the existing ground-water  monitoring wells would not
detect the release of contaminants from the WMA,  (Chapter  3 discusses reasons why
existing wells might not detect contamination.)  Under these  circumstances, it might be
necessary for the EPA to modify an existing permit to require SPWs.

4.3    Permit Renewal
       At the time of permit renewal, the RA and the owner/operator should evaluate the
effectiveness  of the existing ground-water monitoring system.  If a review of the criteria
discussed in Chapter 2 indicates the need to establish more than one WMA, the RA should
establish multiple WMAs under the authority of the RCRA omnibus provision  (RCRA
|3005(c)(3) and 40 CFR 270.32(b)(2)).  Similarly, if a review of site hydrogeologic
conditions, reveals that POC weEs are not sufficient for monitoring regulated units, the RA
should consider installing SPWs pursuant to  the omnibus provision.

4.4    Designating Multiple Monitoring Programs in the Permit
                                                  »">
       The proposed Amendments Rule  would give the RA the authority under 40 CFR
264.91 to designate different monitoring programs (i.e., detection, compliance, or corrective
action) for different WMAs defined at a multi-unit facility. This amendment would reduce
the potential, in the event of a one-unit release, of one unit unnecessarily causing all other
units to adopt the same monitoring or response program, regardless of the source and extent
of contamination.

       Separate ground-water monitoring systems are  not required for each regulated unit
when the RA approves a single WMA encompassing multiple units.  If it is necessary to have
multiple WMAs, then the permit will need to describe  the monitoring program for each
WMA pursuant to the requirements in §§264.98, 264.99, and 264.100.
                                                                                  47

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                                  REFERENCES
American Water Works Association. 1984. Appendix I:  Abandonment of Test Holes,
Partially Completed Wells and Completed Wells.  American Water Works Association
Standard for Water Wells, American Water Works Association, Denver, Colorado, pp. 45-
47.

Field, M.S.  1988. U.S. Eavkonmenta! Protection Agency's Strategy for Ground-Water
Quality Monitoring at Hazardous Waste Land Disposal Facilities in Karst Terrains, in Karst
Hydrogeology and Karst Environmental Protection, International Association of
Hydrogeologists (21st Congress, Guilin,  China), Proceedings, v. n, pp. 1006-1011.

Heath, Ralph C.  1982.  Basic Ground-Water Hydrology.  U.S. Geological Survey Water-
Supply Paper 2220, 84 pp.

Ruling, Scott G. and James W. Weaver.  March 1991.  Dense Nonaqueous Phase Liquids.
EPA/540/4-91-002.

Quinlan, J.F.  1990.  Special Problems of Ground-Water Monitoring in Karst Terrenes, in
D.M, Nielsen and A.I. Johnson, eds., Ground Water and Vadose Zone Monitoring. ASTM
STP 1053, American Society for Testing and Materials, Philadelphia, pp. 275-304.

Quiolan, J.F.  1989.  Ground-Water Monitoring in Karst Terranes: Recommended Protocols
and Implicit Assumptions. USEPA EPA/600/X-89/Q50, 79 pp.

Sara, Martin N.  1991.  "Ground-Water Monitoring System Design."  In Nielsen, D.M., ed.
Practical Handbook ojf Ground-Water Monitoring.  Lewis Publishers,  Chelsea, MI, pp. 17-
68.

USEPA.  1992. RCRA Ground-Water Monitoring; Draft Technical Guidance. USEPA
Office of Solid Waste, EPA/530R-93-001.

USEPA.  November 1991.  Seminar Publication: Site Characterization for Subsurface
Remediation.  EPA/625/4-91/026.

USEPA.  1989. Seminar Publication: Transport and Fate of Contaminants in the
Subsurface. EPA/625/4-89/019.

USEPA.  1986. Permit Guidance Manual on Unsaturated Zone Monitoring for Hazardous
Waste Land Treatment Units.  EPA/53Q-SW-86-Q4G.

USEPA.  1980. Monitoring in the Vadose Zone:  A Review of Technical Elements and
Methods.  EPA/600/7-80-134.
                                                                               49

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                                    APPENDIX I

               Changes to the September 1988 Model Permit Module X
                        to Incorporate Supplemental Well and
                     Multiple Waste Management Area Provisions

           (**Note: Additions to 1988 module are given in underlined bold.)
           MODULE X * GROUND-WATER DETECTION MONITORING for
           WASTE MANAGEMENT AREAS AM) SUPPLEMENTAL WELLS
[Note:  This permit module contains conditions that apply to storage, treatment, or disposal of
hazardous wastes in  any  of the following units:  surface  impoundments, waste piles, land
treatment units or landfills. These units require ground-water monitoring unless exempted under
40 CFR 264.90(b),] The goal of detection monitoring is to ensure the earliest possible detection
of contaminant leakage from the regulated units. Detection monitoring requires detected leakage
to be characterized and determines if further action is warranted. Detection monitoring entails
the following:

       1.     Development of a list of ground-water indicator parameters "and monitoring
             constituents used to indicate a release from the regulated unit(s).
         4
       2.     Establishment of sampling and statistical  analysis requirements to determine if a
             release has occurred.

       3,     Establishment of additional requirements if a statistically significant release
             occurs.]

[Note:  On July 9, 1987, a federal rule was finalized to require analysis for 40 CFR 261,
Appendix IX, rather than Appendix VIII, hazardous constituents pursuant to 40 CFR 264.98 and
264.99, if a statistically significant increase occurs for any detection monitoring parameters or
constituents. The Appendix IX list is an abbreviated Appendix VIII list with several constituents
added.  This permit module incorporates the new rule.]

[Note:  Under  40 CFR 264.9 l(b) the Regional Administrator may include one or more of the
following programs in a permit:  (1) detection monitoring (Module X), (2) compliance monitoring
(Module XI), and (3) corrective action [Module XII(A)].  Multiple waste management areas
at a facility may be  designated and more than one monitoring program at a facility may
be operated where  deemed  necessary to protect human  health and  the environment
pursuant to RCRA  S3005fc¥3> and 40 CFR 270.32  (b)(2).  Separate programs for each
supplemental  monitoring well installed  pursuant'to RCRA S3005(cK3)  and 40 CFR
270.32(b)(2) may also be established.  Monitoring programs for supplemental wells can be


                                                                                A-l

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established based on hvdrogeologic data and contaminant characteristics as necessary to
protect human  health and the environment, and can include sampling parameters and
frequency, and  appropriate response actions.  If more than one program is included in the
Permit, the Permit Writer is to specify the circumstances or conditions under which each program
will be required. It is possible that more than one program will be operable at the same time at
a facility, or that the programs will be conditional based on a sequence of events.  For example,
the sequence set  up in the Permit could include a detection monitoring program that triggers an
Appendix IX analysis that triggers a  Permittee option to apply for a variance (e.g.,  other
contamination source or sampling error) and if the Permittee fails to seek or fails to obtain a
variance* then compliance monitoring is triggered. The Permit could also set the ground-water
protection standard, with a provision for the Permittee to apply for an Alternate Concentration
Limit (ACL), and in the absence of an ACL application or denial of an ACL, or exceedence of
an ACL or pre-set  limit, the triggering of the corrective action program.  The corrective action
program could  include  plume assessment,  correction  measures  study  and design,  and
implementation of corrective action.  Setting up such  a  sequence in the Permit reduces the
number of permit modifications that may be needed and decreases the administrative time needed
to get on with subsequent steps in the process and ultimately, the time required to get corrective
action under way, if needed,]

[Note;  The Permit Writer should refer to the RCRA Permit Quality Protocol for  additional
guidance in developing or reviewing permit conditions.  See discussion of the RCRA Permit
Quality Protocol  in the Introduction to this Model Permit.]

X.A,   MODULE HIGHLIGHTS

[The Permit Writer should include a general discussion of the activities covered by this module.
The discussion should contain the following information: description of the waste management
units (including type  and number that require detection  monitoring); description of  the waste
management areas  (including which waste  management  units  comprise each waste
management area); number, location and depth  of wells;  which wells are supplemental
monitoring wells;  which wells are upgradient and downgradient; the indicator parameters and
monitoring constituents specified and their background concentrations; any unique  or special
features associated  with the operation; and a reference to any  special permit conditions.]

X.B.   WELL LOCATION. INSTALLATION AHD CONSTRUCTION

[Note:   For specific  Agency guidance on monitoring well design and construction,
hvdrogeologic site characterization and location of monitoring wells, consult the EPA RCRA
Ground-Water Monitoring Technical Enforcement Guidance Document (September 1986).]

The Permittee shall install and maintain a ground-water monitoring system as specified below:
[40 CFR 264.97]
A-2

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                                                                 ,'   ' .
X.B.1. The Permittee shall (install and) maintain ground-water monitoring wells at the
       locations specified on the map in Permit Attachment X-l and in conformance with
       the following list:

             (Note:   For each waste management area, the map must show all
             monitoring well locations and provide unique identifiers for each well.
             The number and location of monitoring wells utilized for ground-
             water monitoring is site-specific. The number and location of the wells
             must meet the requirements of 40 CFR 264.95 (Point of Compliance)
             and 40 CFR 264.97(a)  and (b), if applicable (number, location, and
             depth of wells).  The ground-water monitoring system must:  yield
             samples  in  upgradient wells that represent the  quality  of the
             background ground water unaffected by leakage from any regulated
             unit(s), and in downgradient wells yield samples that represent the
             quality of water passing the point of compliance.  The number and
             location of monitoring wells must be sufficient to identify and define
             all logical release pathways from the regulated units based on site-
             specific  hydrogeologic  characterization.  The Permit  Writer may
             require the Permittee to install and monitor supplemental monitoring
             wells where deemed necessary to protect  human  health and the
             environment, where hvdrogeologv or contaminant characteristics can
             allow contaminants  to move past or away from the  point  of
             compliance without  being detected (e.g.. perched water,table).!
   •
X.B.2, The Permittee shall (construct and) maintain the monitoring wells identified in
       Permit Condition X.B.L, in accordance with the detailed plans and specifications
       presented in Permit Attachment  X-2.

             [Note; The plans and specifications must meet the requirements of 40
             CFR 264.97(a) and  (c), and should consist of design drawings and
             design criteria applicable to all wells, and individual well specifications
             identifying total well depth and location of screened intervals.]

[Note: If determined to be necessary to protect human health or the environment,
the Permit Writer should include Permit Conditions X.B.3., specifications on how
monitoring wells  are plugged and abandoned. HSWA Section 212 provides EPA
with this authority. Several states also have regulations which cover monitoring well
abandonment.]

X.B3, All wells deleted from the monitoring .program shall be plugged and abandoned
       in accordance with Permit Attachment X-3.  Well plugging and  abandonment
       methods and certification shall be submitted to the Regional Administrator within
       [The Permit Writer should specify the submittal period.] from the date the
       wells are removed from the monitoring program.
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                                    APPENDIX H

         Waste Management Area(s) and Corrective Action Management Units:
                               Comparison and Contrast

       Both waste management areas (WMAs) and corrective action management units
(CAMUs) circumscribe areas or units containing hazardous wastes or constituents. The
objectives and use of WMAs and CAMUs  are different, however, as described below.

Regulatory Authority

       A single WMA at a site is authorized by §264.95 of Subpart F.  Subpart  F regulates
       ground-water monitoring at regulated units1.  Multiple WMAs at a site can be
       designated under the authority of the omnibus provision, as is discussed in this
       guidance document.

       A CAMU is authorized by §264.552 of Subpart S (58 FR 8658; February 16, 1993).
       Subpart S governs corrective action of solid waste management units (SWMUs)2.
Description and Intent of WMA

       A WMA is established for the purposes of defining a ground-water monitoring
       prdgram and the point of compliance (POC).  The POC is a vertical surface located at
       the hydraulically dbwngradient limit of the WMA.  The POC represents the
       location(s) at which the ground-water protection standard of §264,92 must be met and
       at which monitoring must be conducted,

       A WMA circumscribes regulated units and includes the space taken up by any liner,
       dike, or barrier designed to contain waste. Under §264.95,  if a facility contains more
       than one regulated unit, a single WMA is described by a line (specified in a RCRA
       permit) encircling the regulated units.  The proposed §264.95(b)(3) would allow the
       Regional Administrator to designate multiple waste management areas at a facility.
    1   Regulated units are surface impoundments, waste piles, land treatment units or landfills
       that receive hazardous waste after July 26,1982 subject to the requirements of §§ 264.91
       through 264.100,

    2   A SWMU is defined as any discernible unit, at a RCRA facility, at which solid wastes
       have been placed  at any time, irrespective of whether the unit was intended for the
       management of solid and/or hazardous wastes.  This definition includes tanks, surface
       impoundments, waste piles, land treatment units, landfills, incinerators, etc., as well as
       areas contaminated by "routine and systematic discharges" of wastes from process areas.
       All regulated units are SWMUs, but a SWMU is not necessarily a regulated unit (see
       footnote 1).

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Description and Intent of CAMU                                             •

       A CAMU refers to an area within a facility, designated by the implementing  agency,
       that is used for management of remediation wastes.  CAMUs  may or may not include
       pre-existing "units" such as SWMUs or, in some cases, regulated units3, CAMU
       boundaries will typically be specified on a facility map in the permit or 3008(h) order.

       CAMUs are intended to provide flexibility for decision-makers in implementing
       protective, reliable and cost effective remedies,  For example, under the CAMU
       provisions, remediation wastes can be placed into a CAMU without triggering land
       disposal restrictions and other RCRA hazardous waste disposal requirements.
Other Primary Differences end Related Issues

       Although the WMA is a surface delineation, it is linked to the POC which extends to
       the base of the uppermost aquifer; a CAMU is primarily a surface designation and is
       not linked directly to any characteristic of the underlying aquifer.

       WMA and CAMU boundaries could coincide all or in part at a facility. However,
       the two designations are made for different purposes and are independent of one
       another from a regulatory standpoint.  For example, under the present CAMU rule,
       the designation of a CAMU does  not relieve the owner/operator from requirements to
       monitor ground water at regulated units that are included within the CAMU.
       In certain circumstances, the Regional Administrator has the discretion to designate a
       regulated unit as a CAMU,  or to include a regulated unit as part of a larger CAMU.
       However, only closed or closing regulated units would be able to be so designated. The
       CAMU rule discusses in greater detail the circumstances under which this designation
       could be made.
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