US EPA Underground Injection Control Program Guidelines For Sampling And Analyses Of Motor Vehnicle Waste Disposal Wells (March 2005)

*
r
-------
TABLE OF CONTENTS
SECTION PAGE NO.
Title Page 1
Table of Contents Page 2
I. PROJECT MANAGEMENT 3
A. Background 3
B. Project Description 4
C. Data Quality Objectives and Criteria for Measurement Data 5
D. Certification 5
E. Documents and Records 6
II. DATA GENERATION AND ACQUISITION 6
A. Description of Sampling and Plan 6
B. Quality Assurance and Quality Control 8
Disclaimer: These guidelines only apply in U.S. EPA - Region 5, serving Indiana, Michigan,
Minnesota and Indian lands in U.S. EPA - Region 5. They do not replace or supercede
local or State regulations or policy. Owners are responsible for understanding and
complying with these regulations as well as applicable local and State regulations in any
sampling and analyses.
Page 2 of 9
-------
I. PROJECT MANAGEMENT
A. Background
1. Safe Drinking Water Act and the Underground Injection Control Program
In December 1974, Congress passed the Safe Drinking Water Act (SDWA) to protect the quality
of drinking water in the United States. Specifically, Part C of the SDWA mandated the
regulation of underground injection of fluids through wells to protect underground sources of
drinking water from contamination. In May 1980, the United States Environmental Protection
Agency (EPA) published final Underground Injection Control (UIC) regulations which
established the minimum permitting and other program administrative requirements for the five
major categories of injection wells (Class I, II, III, IV and V). New rules banned the
construction of new motor vehicle waste disposal wells (MVWDWs, one type of Class V well)
as of April 5, 2000, and required all operators of existing MVWDWs in source water protection
areas (SWPAs) or "other sensitive ground water areas" to close or obtain permits for their wells.
The required closure dates depend on where the well is located. If the well is in a SWPA, the
well must be closed within one year of the completion of the local source water assessment. If
the well is in an "other sensitive ground water area," the deadline is January 1, 2007.
2. Motor Vehicle Waste Disposal Wells
Class V wells present the possibility of endangering human health and the environment because
they dispose of fluids above or into underground sources of drinking water (USDW). EPA
Region 5 believes it is necessary to assess the potential for this endangerment before closing
Class V injection wells. Closure is more than just not using the well to dispose of fluids. If
hazardous wastes are present, it also may include conducting a site assessment and if necessary,
performing remediation at the site. MVWDWs are potential hazards because of the presence of
hydrocarbons and solvents in service bay areas. Contaminants from spills or from disposal of
wastes can get into the groundwater via the MVWDW at these sites. The focus of this
document is the sampling and analysis of MVWDW waste products.
3. Purpose of this Document
Some facilities may be required to sample and analyze their wastes if the EPA Region 5 believes
that there may be a risk to local private or public water supplies. Before collecting samples for
analysis, a Sampling Plan is needed. This plan must be provided to EPA Region 5 for approval
at least 30 days prior to sampling the MVWDW. The Sampling Plan is described in Section II.
A. Site assessments may be required at a MVWDW facility where it has been determined that
injection into the well may cause a violation of drinking water regulations or otherwise adversely
affect the health of persons.
For the purposes of this document,"closure" means closing the MVWDW in such a way that
motor vehicle wastes no longer have the potential to go into the groundwater. (In some cases,
some parts of the disposal system can continue to be used for other wastes, such as sanitary
Page 3 of 9
-------
wastes from a restroom.)
B. Project Description (Requirements Specific to MVWDWs)
Operators of MVWDWs should submit samples of both their waste sludge and waste water to a
laboratory for chemical analysis. Based on the review of analyses from previous sampling of
MVWDW sludge and waste water, EPA Region 5 has selected a representative set of
contaminants commonly found in MVWDW waste products. Benzene, cadmium, lead and
trichloroethene (TCE*) have been found in previous sample analyses when other contaminants
have also been detected. EPA Region 5 believes that these four constituents will provide an
adequate representation of the relative potential for contamination by the fluids discharged from
a MVWDW. This will assist EPA Region 5 in determining the need for further follow-up to
ensure the protection of the groundwater in the closure of the MVWDW. The methods to be
used to analyze samples for these constituents are shown in Table 1.
Note: It is strongly recommended that operators of MVWDWs hire an
environmental laboratory or consultant to properly collect, preserve and transport any
samples taken for analysis. Improper handling of environmental samples can render them
worthless and cause additional sampling to be required.
* Also called trichloroethylene
Page 4 of 9
-------
C. Data Quality Objectives and Criteria for Measurement Data
TABLE 1
Analyte
TC Limit
Method

(mg/L)
SW-846
Benzene
0.5
8260B

8021B
Cadmium
1.0
6010

7130

7131A
Lead
5.0
6010

7420

7421
T ri chl oroethy 1 ene
0.5
8260B

8021B
"The estimated instrumental detection limits shown are provided as a guide for an instrumental limit. The
actual method detection limits are sample dependent and may vary as the sample matrix varies."Estimated
quantitation limits taken from http://www.epa.g0v/epaoswer/hazwaste/test/8 series.htm
D. Certification
1. The individual signing any sampling results is responsible for the content, validity
and completeness of the report. All reports related to well closure activities must include the
following certification (Title 40 of the Code of Regulations (40 CFR) Section 144.32(d)):
I certify under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on
my inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility offine and
imprisonment for knowing violations.
Page 5 of 9
-------
2. State certified laboratories must be used for the sample analyses described in
Table 1. If the distance to the nearest laboratory is such that hand-delivery is not possible,
samples should be express/overnight delivered. All laboratories involved in the analysis of
samples must retain their calibration logs for two years, and laboratory data logs and sampling
labels or information from the labels for three years. All analytical tests must be performed in
accordance with methods acceptable under quality assurance guidelines.
STATE CERTIFIED LABORATORY WEBSITES
Michigan:
http://www.deq.state.mi.us/documents/deq-dwrpd-lab-Cert_Chem_Lab.pdf
Two for Indiana:
http://www.in.gov/idem/ctap/labs.html
http://www.in.gov/isdh/labs/chem2001 .htm
Three for Minnesota:
http://www.health.state.mn.us/divs/phl/cert/index.html Home page: allows different types of searches
http://www.health.state.mn.us/divs/phl/cert/contract.html Contract labs
http://www.health.state.mn.us/divs/phl/cert/noncontract.html Noncontract labs
E. Documents and Records
The facility operator must preserve records of all MVWDW sampling and analyses. EPA
Region 5 requires that the operator retain all technical information generated through the project,
such as information on specific sites, until three years after MVWDW closure. However, since
future activities at a site, such as sale of property, may necessitate evaluating past practices, in
most cases it is best to retain records of disposal activities permanently. Field information about
sampling efforts must include sample identification numbers; date and time of sample collection;
description of the location of collection; the collection method; the rationale for selecting the
samples and representativeness of the sample; and a description of any deviation from standard
protocols.
II. DATA GENERATION AND ACQUISITION
A. Description of Sampling Plan
Before taking any samples, EPA Region 5must approve your Sampling Plan. Properly trained
personnel must conduct all sampling following the approved Sampling Plan. The Sampling Plan
should describe all methods, protocols and location(s). EPA Region 5 recommends that the
operator follow the guidelines set forth in a document such as "Test Methods for Evaluating
Solid Waste", SW-846 or "Methods for Chemical Analysis of Water and Wastes", EPA Region 5
600/4-79/020. See 40 CFR Section 136.3, which includes a list of approved sample
Page 6 of 9
-------
preservation techniques. The sampling and analysis description should include the following for
each parameter:
1.
Sample description
2.
Sample collector's name (include sampling company name);
3.
Sampler's title;
4.
Sample collection method;
5.
Sample collection point;
6.
Sample preservation technique;
7.
Analytical method for parameter detection/quantification;
8.
Anticipated analytical method accuracy;
9.
Anticipated upper & lower analytical method quantification limit; and
10.
Adequate field documentation of sampling;
11.
Equipment cleaning blanks;
12.
Trip blanks;
13.
Sample chain-of-custody protocol;
14.
Equipment calibration;
15.
Data reduction;
16.
Data reporting;
17.
Internal quality control;
18.
Performance audits;
19.
System audits;
20.
Laboratory preventative maintenance;
21.
Data assessment procedures;
22.
Laboratory corrective actions, and
23.
Quality assurance reports.
B. Quality Assurance and Quality Control
Quality assurance (QA) is the process of assuring that data obtained are technically sound and
Page 7 of 9
-------
properly documented. Quality control (QC) procedures are used to measure the degree to which
quality assurance objectives are met.
This document provides guidelines on some of the minimum requirements to ensure the quality
of the data produced during sampling/analysis activities. The regulated facilities are responsible
for the quality of the data produced and are expected to provide data of known, documented and
verifiable quality.
1. Equipment cleaning blanks
Equipment blanks are taken to detect cross-contamination due to improper cleaning of sampling
equipment. After sampling the most concentrated wastestream (if known), the sampling device
should be cleaned according to the sampling plan protocol. The sampling device should then be
rinsed with de-ionized, distilled water and the rinse water collected in a container for transport to
the laboratory for analysis of, at a minimum, the same parameters in the sampling plan. If only
one sample is taken, an equipment blank should be taken prior to the sampling event.
2. Trip blanks [REQUIRED]
Trip blanks are sample containers filled with Type II reagent grade water at the laboratory,
sealed at the laboratory, which accompany the sample containers used throughout the sampling
event. The sample containers must be handled in the same manner as the samples. The trip
blank(s) should be returned to the laboratory for analysis of, at a minimum, the same parameters
in the sampling plan. At least one (1) trip blank per sampling event is recommended.
3. Sample duplicates [REQUIRED]
Sample duplicates are taken in order to check the QA/QC of the laboratory conducting the
analysis. The sample should be drawn from the site which is considered to be the most
concentrated (if known). The duplicate sample must be split from the original sample in a way
that ensures both samples are the same. The duplicate must be labeled with a sample number
which will not conflict with the other samples, but which the laboratory will not be able to
identify as a duplicate.
4. Sample chain-of-custody protocol [REQUIRED]
Sample chain-of-custody should be followed at all times during the sampling and subsequent
analysis. The chain-of-custody documents the handling and control necessary to identify and
trace a sample from collection to final analytical results. Such documentation includes records of
personnel handling the samples, labeling to prevent mixup, container seals to prevent
unauthorized tampering with the samples and secure custody.
5. Equipment calibration
The QA/QC section of the Sampling Plan should specify the frequency and type of instrument
calibration performed at the laboratory and in the field. The calibration should be done according
to instrument manufacturer specifications and at the recommended frequency.
6. Data reduction
Data reduction is the process of converting the raw data printouts and displays into the reportable
units. An example of such reduction is the proper conversion from the number of counts per
Page 8 of 9
-------
second observed on a particular instrument to the concentration of sodium in the sample in
milligram/liter. Data reduction should be specified by formula for each parameter tested and is
specific to the laboratory used.
7. Data validation
Data validation is the process of double-checking the results of analytical methods in order to
determine that they meet project objectives. This process involves review of chain-of-custody
forms, review of equipment calibration methods, as well as review of raw data and the
subsequent data reduction.
8. Internal quality control
This aspect of quality assurance deals with the standard and routine efforts which the laboratory
undertakes to ensure that all data generated meets the quality which is necessary for compliance
with its own reporting requirements. Internal quality control should be addressed by discussing
the laboratory's use of blanks, matrix spikes and matrix spike duplicates, preparation of reagents,
and laboratory duplicate or replicate analyses.
9. Laboratory audits
Laboratory audits should be conducted as part of the routine quality assurance program. There
should be periodic and dependable inspections of the laboratory facilities and personnel by
impartial parties.
10. Corrective actions [REQUIRED IF CORRECTIVE ACTION IS PERFORMED]
Corrective actions should be implemented when any aspect of the analytical or sampling method
does not achieve the project objectives. This may entail re-sampling the wastestream and/or re-
analyzing the fluid or sludge for a particular parameter, re-calibrating an analytical device, or
any other such action. The action levels for each such process should be shown in tabular form;
11. Reports to EPA Region 5 [REQUIRED]
The report to EPA Region 5 should contain all the results, data and sampling description
necessary to enable EPA Region 5 staff to assess the accuracy, completeness and
representativeness of the reported analytical results. The report should contain a table which
specifies the type of sample (blank, waste, etc.), sampling date, sampling location, analytical
method, method detection limit, validation result and analytical result. The results of analyses
and all accompanying required data, including chain-of-custody forms, should be reported to
EPA Region 5 within 45 days of the sampling event, unless conditions beyond the control of the
operator prevent it. Copies of all QA/QC information as well as copies of all sampling and
analysis data, whether submitted to EPA Region 5 or not, should be held by the MVWDW
operator for at least three years in case that information is needed for review by the EPA,
Region 5.
Page 9 of 9
-------