Groundwater Monitoring

CHAPTER 5
SUBPART E
GROUND-WATER MONITORING
AND CORRECTIVE ACTION
CHAPTER 5
SUBPART E
TABLE OF CONTENTS
5.1 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 211
5.2 APPLICABILITY 40 CFR §258.50 (a) & (b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 211

5.2.1 Statement of Regulation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 211
5.2.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 212
5.2.3 Technical Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 212
5.3 COMPLIANCE SCHEDULE 40 CFR § 258.50 (c) . . . . . . . . . . . . . . . . . . . . . . . . . . 214

5.3.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 214
5.4 ALTERNATIVE COMPLIANCE SCHEDULES 40 CFR 258.50 (d)(e) & (g) . . . . . 215
5.4.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 216
5.5 QUALIFICATIONS 40 CFR 258.50 (f) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 217

5.5.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 218
5.6 GROUND-WATER MONITORING SYSTEMS 40 CFR §258.51 (a)(b)(d) . . . . . . . 219

5.6.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 220
Uppermost Aquifer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 221
Determination of Background Ground-Water Quality . . . . . . . . . . . . . . . . . . 221
Multi-Unit Monitoring Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 222
Hydrogeological Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 224
Characterizing Site Geology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 225
Monitoring Well Placement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 235
206
5.7 GROUND-WATER MONITORING WELL DESIGN AND CONSTRUCTION 40
CFR §258.51 (c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 241
5.7.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 241
Monitoring Well Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 244
Well Casing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 244
Filter Pack Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 248
Surface Completion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 250
5.8 GROUND-WATER SAMPLING AND ANALYSIS REQUIREMENTS

40 CFR §258.53 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 253
5.8.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 254
Sample Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 255
Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 255
Water Level Measurements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 256
Well Purging . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 256
Field Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 258
Sample Withdrawal and Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . 258
Sample Preservation and Handling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 260
Sample Containers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 262
Sample Preservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 262
Sample Storage and Shipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 262
Chain-of-Custody Record . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 263
Sample Labels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 263
Sample Custody Seal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 264
Field Logbook . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 264
Sample Analysis Request Sheet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 265
Laboratory Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 265
Analytical Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 265
Quality Assurance/Quality Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 266
Field Quality Assurance/Quality Control . . . . . . . . . . . . . . . . . . . . . . 266
Validation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 267
Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 268
207
5.9 STATISTICAL ANALYSIS 40 CFR §258.53 (g)-(i) . . . . . . . . . . . . . . . . . . . . . . . . 268
5.9.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 270
5.9.3 Technical Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 271
Multiple Well Comparisons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 272
Tolerance and Prediction Intervals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 273
Individual Well Comparisons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 274
Intra-Well Comparisons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 274
Treatment of Non-Detects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 274
5.10 DETECTION MONITORING PROGRAM 40 CFR §258.54 . . . . . . . . . . . . . . . . . . 274

5.10.1 Statement of Regulation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 274
5.10.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 276
Independent Sampling for Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 277
Alternative List/Removal of Parameters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 279
Alternative Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 279
Notification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 280
Demonstrations of Other Reasons For Statistical Increase . . . . . . . . . . . . . . . 280
Demonstrations of Other Sources of Error . . . . . . . . . . . . . . . . . . . . . . . . . . . 281
5.11 ASSESSMENT MONITORING PROGRAM 40 CFR §258.55(a)-(f) . . . . . . . . . . . . 281

5.11.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 283
Alternative List . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 285
Alternative Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 285
5.12 ASSESSMENT MONITORING PROGRAM 40 CFR §258.55(g) . . . . . . . . . . . . . . 286

5.12.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 287
Release Investigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 288
Property Boundary Monitoring Well . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 288
Notification of Adjoining Residents and Property Owners . . . . . . . . . . . . . . 288
Demonstrations of Other Sources of Error . . . . . . . . . . . . . . . . . . . . . . . . . . . 288
Return to Detection Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 289
5.13 ASSESSMENT MONITORING PROGRAM 40 CFR §258.55(h)-(j) . . . . . . . . . . . . 289

5.13.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 290
208
5.14 ASSESSMENT OF CORRECTIVE MEASURES 40 CFR §258.56 . . . . . . . . . . . . . 291
5.14.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 291
Source Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 292
Plume Delineation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 292
Ground-Water Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 294
Corrective Measures Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 295
Active Restoration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 296
Plume Containment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 297
Source Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 298
Public Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 298
5.15 SELECTION OF REMEDY 40 CFR §258.57 (a)-(b) . . . . . . . . . . . . . . . . . . . . . . . . 298

5.15.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 299
5.16 SELECTION OF REMEDY 40 CFR §258.57 (c) . . . . . . . . . . . . . . . . . . . . . . . . . . . 299

5.16.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 300
Effectiveness of Corrective Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 301
Effectiveness of Source Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 302
Implementation of Remedial Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 302
Practical Capability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 302
Community Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 303
5.17 SELECTION OF REMEDY 40 CFR §258.57 (d) . . . . . . . . . . . . . . . . . . . . . . . . . . . 303

5.17.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 304
5.18 SELECTION OF REMEDY 40 CFR §258.57 (e)-(f) . . . . . . . . . . . . . . . . . . . . . . . . . 305

5.18.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 306
209
5.19 IMPLEMENTATION OF THE CORRECTIVE ACTION PROGRAM
40 CFR §258.58 (a) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 307
5.19.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 308
Monitoring Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 308
Interim Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 308

40 CFR §258.58 (b)-(d) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 309
5.20.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 309

40 CFR §258.58 (e)-(g) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 311
5.21.2 Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 311
5.22 FURTHER INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 313

5.22.1 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 313
210
CHAPTER 5
SUBPART E
GROUND-WATER MONITORING
AND CORRECTIVE ACTION
5.1 INTRODUCTION
The Criteria establish ground-water monitoring and corrective action requirements for all existing
and new MSWLF units and lateral expansions of existing units except where the Director of an
approved State suspends the requirements because there is no potential for migration of leachate
constituents from the unit to the uppermost aquifer. The Criteria include requirements for the
location, design, and installation of ground-water monitoring systems and set standards for ground-
water sampling and analysis. They also provide specific statistical methods and decision criteria for
identifying a significant change in ground-water quality. If a significant change in ground-water
quality occurs, the Criteria require an assessment of the nature and extent of contamination followed
by an evaluation and implementation of remedial measures.
Portions of this chapter are based on a draft technical document developed for EPA's hazardous
waste program. This document, "RCRA Ground-Water Monitoring: Draft Technical Guidance"
(EPA/530-R-93-001), is undergoing internal review, and may change. EPA chose to incorporate
the information from the draft document into this chapter because the draft contained the most
recent information available.
5.2 APPLICABILITY active life of the unit and the post-closure

40 CFR §258.50 (a) & (b) care period. This demonstration must be
certified by a qualified ground-water
5.2.1 Statement of Regulation scientist and approved by the Director of
an approved State, and must be based
(a) The requirements in this Part apply to upon:
MSWLF units, except as provided in
paragraph (b) of this section. (1) Site-specific field collected
measurements, sampling, and analysis of
(b) Ground-water monitoring physical, chemical, and biological processes
requirements under §258.51 through affecting contaminant fate and transport,
§258.55 of this Part may be suspended by and
the Director of an approved State for a
MSWLF unit if the owner or operator can (2) Contaminant fate and transport
demonstrate that there is no potential for predictions that maximize contaminant
migration of hazardous constituents from migration and consider impacts on human
that MSWLF unit to the uppermost health and environment.
aquifer (as defined in §258.2) during the
211
Subpart E
5.2.2 Applicability §258.51 through §258.55 if the owner or

operator demonstrates that there is no
The ground-water monitoring requirements potential for hazardous constituent migration
apply to all existing MSWLF units, lateral to the uppermost aquifer throughout the
expansions of existing units, and new operating, closure, and post-closure care
MSWLF units that receive waste after
periods of the unit. Owners and operators of
October 9, 1993. The requirements for
ground-water monitoring may be suspended if MSWLFs not located in approved States will
the Director of an approved State finds that no not be eligible for this waiver and will be
potential exists for migration of hazardous required to comply with all ground-water
constituents from the MSWLF unit to the monitoring requirements. The "no-migration"
uppermost aquifer during the active life of the demonstration must be certified by a qualified
unit, including closure or post-closure care ground-water scientist and approved by the
periods. Director of an approved State. It must be
based on site-specific field measurements and
The "no potential for migration" demonstra- sampling and analyses to determine the
tion must be based upon site-specific informa-
tion relevant to the fate and transport of any physical, chemical, and biological processes
hazardous constituents that may be expected affecting the fate and transport of hazardous
to be released from the unit. The predictions constituents. The demonstration must be
of fate and transport must identify the max- supported by site-specific data and predictions
imum anticipated concentrations of constitu- of the maximum contaminant migration.
ents migrating to the uppermost aquifer so Site-specific information must include, at a
that a protective assessment of the potential minimum, the information necessary to
effects to human health and the environment evaluate or interpret the effects of the
can be made. A successful demonstration following properties or processes on
could exempt the MSWLF unit from contaminant fate and transport:
requirements of §§258.51 through 258.55,
which include installation of ground-water
monitoring systems, and sampling and Physical Properties or Processes:
analysis for both detection and assessment
monitoring constituents. Preparing No- ! Aquifer Characteristics, including
Migration Demonstrations for Municipal hydraulic conductivity, hydraulic gradient,
Solid Waste Disposal Facilities-Screening effective porosity, aquifer thickness, de-
Tool is a guidance document describing a gree of saturation, stratigraphy, degree of
process owners/ operators can use to prepare fracturing and secondary porosity of soils
a no-migration demonstration (NMD) and bedrock, aquifer heterogeneity,
requesting suspension of the ground-water ground-water discharge, and ground-water
monitoring requirements.
recharge areas;
5.2.3 Technical Considerations
! Waste Characteristics, including quantity,
All MSWLF units that receive waste after the type, and origin (e.g., commercial,
effective date of Part 258 must comply with industrial, or small quantity generators of
the ground-water monitoring requirements. unregulated hazardous wastes);
The Director of an approved State may
exempt an owner/operator from the ground-
water monitoring requirements at
212
Ground-Water Monitoring and Corrective Action
! Climatic Conditions, including annual transport should be biased toward over-

precipitation, leachate generation estimating transport and the anticipated
estimates, and effects on leachate concentrations. Assumptions and site
quality; specific data that are used in the fate and
transport predictions should conform with
! Leachate Characteristics, including transport principles and processes,
leachate composition, solubility, density, including adherence to mass-balance and
the presence of immiscible constituents, chemical equilibria limitations. Within
Eh, and pH; and these physicochemical limitations,
assumptions should be biased toward the
! Engineered Controls, including liners, objective of assessing the maximum
cover systems, and aquifer controls (e.g., potential impact on human health and the
lowering the water table). These should environment. The evaluation of site-
be evaluated under design and failure specific data and assumptions may include
conditions to estimate their long-term some of the following approaches:
residual performance.
! Use of the upper bound of known aquifer
Chemical Properties or Processes: parameters and conditions that will
maximize contaminant transport (e.g.,
! Attenuation of contaminants in the hydraulic conductivity, effective
subsurface, including adsorption/ porosity, horizontal and vertical
desorption reactions, ion exchange, gradients), rather than average values
organic content of soil, soil water pH,
and consideration of possible reactions ! Use of the lower range of known aquifer
causing chemical transformation or conditions and parameters that tend to
chelation. attenuate or retard contaminant transport
(e.g., dispersivities, decay coefficients,
Biological Processes: cation exchange capacities, organic
carbon contents, and recharge
! Microbiological Degradation, which may conditions), rather than average values
attenuate target compounds or cause
transformations of compounds, ! Consideration of the cumulative impacts
potentially forming more toxic chemical on water quality, including both existing
species. water quality data and cumulative health
risks posed by hazardous constituents
The alternative design section of Chapter likely to migrate from the MSWLF unit
5.0 discusses these and other processes that and other potential or known sources.
affect contaminant fate and solute transport.
A discussion of mathematical approaches
When owners or operators prepare a no- for evaluating contaminant or solute
migration demonstration, they must use transport is provided in Chapter 5.
predictions that are based on maximum
contaminant migration both from the unit
and through the subsurface media.
Assumptions about variables affecting
213
Subpart E
5.3 COMPLIANCE SCHEDULE (4) New MSWLF units must be in

40 CFR § 258.50 (c) compliance with the ground-water
monitoring requirements specified in
5.3.1 Statement of Regulation* §§258.51 - 258.55 before waste can be
placed in the unit.
*[NOTE: EPA finalized several revisions
to 40 CFR Part 258 on October 1, 1993 5.3.2 Applicability
(58 FR 51536), and these revisions delay
the effective date for some categories of The rule establishes a self-implementing
landfills. More detail on the content of schedule for owners or operators in States
the revisions is included in the with programs that are deemed inadequate
introduction.] or not yet approved. As indicated in the
Statement of Regulation, this schedule
(c) Owners and operators of MSWLF depends on the distance of the MSWLF unit
units must comply with the ground-water from drinking water sources. Approved
monitoring requirements of this part States may specify an alternative schedule
according to the following schedule unless under §258.50 (d), which is discussed in
an alternative schedule is specified under Section 5.4.
paragraph (d):
Existing units and lateral expansions less
(1) Existing MSWLF units and lateral than one mile from a drinking water intake
expansions less than one mile from a must be in compliance with the ground-
drinking water intake (surface or water monitoring requirements by October
subsurface) must be in compliance with 9, 1994. If the units are greater than one
the ground-water monitoring mile but less than two miles from a drinking
requirements specified in §§258.51 - water intake, they must be in compliance by
258.55 by October 9, 1994; October 9, 1995. Those units located more
than two miles from a drinking water intake
(2) Existing MSWLF units and lateral must be in compliance by October 9, 1996
expansions greater than one mile but less (see Table 5-1).
than two miles from a drinking water
intake (surface or subsurface) must be in New MSWLF units, defined as units that
compliance with the ground-water have not received waste prior to October 9,
monitoring requirements specified in 1993, must be in compliance with these
§§258.51 - 258.55 by October 9, 1995; requirements before receiving waste
regardless of the proximity to a water
(3) Existing MSWLF units and lateral supply intake.
expansions greater than two miles from a
drinking water intake (surface or 5.3.3 Technical Considerations
subsurface) must be in compliance with
the ground-water monitoring For most facilities, these requirements will
requirements specified in §§258.51 - become applicable 3 to 5 years after the
258.55 by October 9, 1996; promulgation date of the rule. This period
214
Table 5-1. Compliance Schedule for Existing Units and Lateral Expansions
in States with Unapproved Programs
Time to Comply
Distance From Water Supply Intake
From October 9, 1991
One mile or less 3 Years

More than one mile but less than two 4 Years
miles
More than two miles 5 Years
should provide sufficient time for the owner compliance by October 9, 1996. In
or operator to conduct site investigation and setting the compliance schedule, the
characterization studies to comply with the Director of an approved State must
requirements of 40 CFR §258.51 through consider potential risks posed by the unit
§258.55. For those facilities closest to to human health and the environment.
drinking water intakes, the period provides The following factors should be
2 to 3 years to assess seasonal variability in considered in determining potential risk:
ground-water quality. A drinking water
intake includes water supplied to a user (1) Proximity of human and
from either a surface water or ground-water environmental receptors;
source.
(2) Design of the MSWLF unit;
5.4 ALTERNATIVE COMPLIANCE
SCHEDULES (3) Age of the MSWLF unit;
40 CFR 258.50 (d)(e) & (g)
(4) The size of the MSWLF unit;
5.4.1 Statement of Regulation
(5) Types and quantities of wastes
(d) The Director of an approved State disposed, including sewage sludge; and
may specify an alternative schedule for
the owners or operators of existing (6) Resource value of the underlying
MSWLF units and lateral expansions to aquifer, including:
comply with the ground-water
monitoring requirements specified in (i) Current and future uses;
§§258.51 - 258.55. This schedule must
ensure that 50 percent of all existing (ii) Proximity and withdrawal rate of
MSWLF units are in compliance by users; and
October 9, 1994 and all existing MSWLF
units are in (iii) Ground-water quality and
quantity.
215
Subpart E
(e) Once established at a MSWLF 5.4.2 Applicability

unit, ground-water monitoring shall be
conducted throughout the active life and The Director of an approved State may
post-closure care period of that MSWLF establish an alternative schedule for
unit as specified in §258.61. requiring owners/operators of existing units
and lateral expansions to comply with the
(f) (See Section 5.5 for technical ground-water monitoring requirements.
guidance on qualifications of a ground- The alternative schedule is to ensure that at
water scientist.) least fifty percent of all existing MSWLF
units within a given State are in compliance
(g) The Director of an approved State by October 9, 1994 and that all units are in
may establish alternative schedules for compliance by October 9, 1996.
demonstrating compliance with
§258.51(d)(2), pertaining to notification In establishing the alternative schedule, the
of placement of certification in operating Director of an approved State may use site-
record; § 258.54(c)(1), pertaining to specific information to assess the relative
notification that statistically significant risks posed by different waste management
increase (SSI) notice is in operating units and will allow priorities to be
record; § 258.54(c)(2) and (3), pertaining developed at the State level. This site-
to an assessment monitoring program; specific information (e.g., proximity to
§ 258.55(b), pertaining to sampling and receptors, proximity and withdrawal rate of
analyzing Appendix II constituents; ground-water users, waste quantity, type,
§258.55(d)(1), pertaining to placement of containment design and age) should enable
notice (Appendix II constituents detected) the Director to assess potential risk to the
in record and notification of notice in uppermost aquifer. The resource value of
record; § 258.55(d)(2), pertaining to the aquifer to be monitored (e.g., ground-
sampling for Appendix I and II; water quality and quantity, present and
§ 258.55(g), pertaining to notification future uses, and withdrawal rate of ground-
(and placement of notice in record) of SSI water users) also may be considered.
above ground-water protection standard;
§ 258.55(g)(1)(iv) and § 258.56(a), Once ground-water monitoring has been
pertaining to assessment of corrective initiated, it must continue throughout the
measures; § 258.57(a), pertaining to active life, closure, and post-closure care
selection of remedy and notification of periods. The post-closure period may last
placement in record; § 258.58(c)(4), up to 30 years or more after the MSWLF
pertaining to notification of placement in unit has received a final cover.
record (alternative corrective action
measures); and § 258.58(f), pertaining to In addition to establishing alternative
notification of placement in record schedules for compliance with ground-
(certification of remedy completed). water monitoring requirements, the Director
of an approved State may establish
alternative schedules for certain
216
sampling and analysis requirements of at existing MSWLF units, the Director of an

§§258.54 and 258.55, as well as corrective approved State may consider information
action requirements of §§258.56, 258.57, including the age and design of existing
and 258.58. See Table 5-2 for a summary facilities. Using this type of information, in
of notification requirements for which conjunction with a knowledge of the wastes
approved States may establish alternative disposed, the Director should be able to
schedules. qualitatively assess or rank facilities based
on their risk to local ground-water
5.4.3 Technical Considerations resources.
The rule allows approved States flexibility

in establishing alternate ground-water 5.5 QUALIFICATIONS
monitoring compliance schedules. In 40 CFR 258.50 (f)
setting an alternative schedule, the State
will consider potential impacts to human 5.5.1 Statement of Regulation
health and the environment. Approved
States have the option to address MSWLF (f) For the purposes of this Subpart, a
units that have environmental problems qualified ground-water scientist is a
immediately. In establishing alternative scientist or engineer who has received a
schedules for installing ground-water baccalaureate or post-graduate degree in
monitoring systems
Table 5-2. Summary of Notification Requirements
Section Description
14 day notification period after well installation

§258.51(d)(2)
certification by a qualified ground-water scientist (GWS)
14 day notification period after finding a statistical increase
§258.54(c)(1)
over background for detection parameter(s)
14 day notification period after detection of Appendix II
§258.55(d)(1)
constituents
14 day notification period after selection of corrective
§258.57(a)
measures
14 day notification period prior to implementing alternative
§258.58(c)(4)
measures
14 day notification period after remedy has been completed
§258.58(f)
and certified by GWS
217
Subpart E
the natural sciences or engineering and 5.5.3 Technical Considerations

has sufficient training and experience in
ground-water hydrology and related A qualified ground-water scientist must
fields as may be demonstrated by State certify work performed pursuant to the
registration, professional certifications, following provisions of the ground-water
or completion of accredited university monitoring and corrective action
programs that enable that individual to requirements:
make sound professional judgements
regarding ground-water monitoring, ! No potential for migration
contaminant fate and transport, and demonstration (§258.50(b))
corrective action.
! Specifications concerning the number,
5.5.2 Applicability spacing, and depths of monitoring wells
(§258.51(d))
The qualifications of a ground-water
scientist are defined to ensure that ! Determination that contamination was
professionals of appropriate capability and caused by another source or that a
judgement are consulted when required by statistically significant increase resulted
the Criteria. The ground-water scientist from an error in sampling, analysis, or
must possess the fundamental education and evaluation (§§258.54 (c)(3) and 258.55
experience necessary to evaluate ground- (g)(2))
water flow, ground-water monitoring
systems, and ground-water monitoring ! Determination that compliance with a
techniques and methods. A ground-water remedy requirement is not technically
scientist must understand and be able to practicable (§258.58(c)(1))
apply methods to solve solute transport
problems and evaluate ground-water ! Completion of remedy (§258.58(f)).
remedial technologies. His or her education
may include undergraduate or graduate The owner or operator must determine that
studies in hydrogeology, ground-water the professional qualifications of the
hydrology, engineering hydrology, water ground-water specialist are in accordance
resource engineering, geotechnical with the regulatory definition. In general, a
engineering, geology, ground-water certification is a signed document that
modeling/ground-water computer modeling, transmits some finding (e.g., that
and other aspects of the natural sciences. monitoring wells were installed according
The qualified ground-water scientist must to acceptable practices and standards at
have a college degree but need not have locations and depths appropriate for a given
professional certification, unless required at facility). The certification must be placed
the State or Tribal level. Some in the operating record of the facility, and
States/Tribes may have certification the State Director must be notified that the
programs for ground-water scientists; certification has been made. Specific
however, there are no recognized Federal details of these certifications will be
certification programs.
218
addressed in the order in which they appear representative than that provided by the
in this guidance document. upgradient wells; and
Many State environmental regulatory (2) Represent the quality of ground

agencies have ground-water scientists on water passing the relevant point of
staff. The owner or operator of a MSWLF compliance specified by the Director of
unit or facility is not necessarily required to an approved State under §258.40(d) or at
obtain certification from an independent the waste management unit boundary in
(e.g., consulting) ground-water scientist and unapproved States. The downgradient
may, if agreed to by the Director in an monitoring system must be installed at
approved State, obtain approval by the the relevant point of compliance specified
Director in lieu of certification by an by the Director of an approved State
outside individual. under §258.40(d) or at the waste
management unit boundary in
unapproved States that ensures detection
5.6 GROUND-WATER of ground-water contamination in the
MONITORING SYSTEMS uppermost aquifer. When physical
40 CFR §258.51 (a)(b)(d) obstacles preclude installation of ground-
water monitoring wells at the relevant
5.6.1 Statement of Regulation point of compliance at existing units, the
down-gradient monitoring system may be
(a) A ground-water monitoring system installed at the closest practicable
must be installed that consists of a distance hydraulically down-gradient
sufficient number of wells, installed at from the relevant point of compliance or
appropriate locations and depths, to yield specified by the Director of an approved
ground-water samples from the upper- State under §258.40 that ensures
most aquifer (as defined in §258.2) that: detection of ground-water contamination
in the uppermost aquifer.
(1) Represent the quality of background
ground water that has not been affected (b) The Director of an approved State
by leakage from a unit. A determination may approve a multi-unit ground-water
of background quality may include monitoring system instead of separate
sampling of wells that are not ground-water monitoring systems for
hydraulically upgradient of the waste each MSWLF unit when the facility has
management area where: several units, provided the multi-unit
ground-water monitoring system meets
(i) Hydrogeologic conditions do not the requirement of §258.51(a) and will be
allow the owner or operator to determine as protective of human health and the
what wells are hydraulically upgradient; environment as individual monitoring
or systems for each MSWLF unit, based on
the following factors:
(ii) Sampling at other wells will provide
an indication of background ground- (1) Number, spacing, and orientation of
water quality that is as representative or the MSWLF units;
more
219
Subpart E
(2) Hydrogeologic setting; 5.6.2 Applicability
(3) Site history; The requirements for establishing a ground-

water monitoring system pursuant to
(4) Engineering design of the MSWLF §258.51 apply to all new units, existing
units; and units, and lateral expansions of existing
units according to the schedules identified
(5) Type of waste accepted at the in 40 CFR §258.50. A ground-water
MSWLF units. monitoring system consists of both
background wells and wells located at the
(c) (See Section 5.7 for technical point of compliance or waste management
guidance on monitoring well design and unit boundary (i.e., downgradient wells).
construction.) The ground-water monitoring network must
be capable of detecting a release from the
(d) The number, spacing, and depths of MSWLF unit. A sufficient number of
monitoring systems shall be: monitoring wells must be located
downgradient of the unit and be screened at
(1) Determined based upon site-specific intervals in the uppermost aquifer to ensure
technical information that must include contaminant detection. Generally,
thorough characterization of: upgradient wells are used to determine
background ground-water quality.
(i) Aquifer thickness, ground-water
flow rate, ground-water flow direction The downgradient wells must be located at
including seasonal and temporal the relevant point of compliance specified
fluctuations in ground-water flow; and by the Director of an approved State, or at
the waste management unit boundary in
(ii) Saturated and unsaturated States that are not in compliance with
geologic units and fill materials overlying regulations. If existing physical structures
the uppermost aquifer, materials obstruct well placement, the downgradient
comprising the uppermost aquifer, and monitoring system should be placed as close
materials comprising the confining unit to the relevant point of compliance as
defining the lower boundary of the possible. Wells located at the relevant point
uppermost aquifer; including, but not of compliance must be capable of detecting
limited to: thicknesses, stratigraphy, contaminant releases from the MSWLF unit
lithology, hydraulic conductivities, to the uppermost aquifer. As discussed
porosities and effective porosities. earlier in the section pertaining to the
designation of a relevant point of
(2) Certified by a qualified ground- compliance (Section 4.4), the point of
water scientist or approved by the compliance must be no greater than 150
Director of an approved State. Within 14 meters from the unit boundary.
days of this certification, the owner or
operator must notify the State Director The Director of an approved State may
that the certification has been placed in allow the use of a multi-unit ground-water
the operating record. monitoring system. MSWLF units in
220
States that are deemed not in compliance aquifer is defined in §258.2 as "the geologic
with the regulations must have a monitoring formation nearest to the natural ground
system for each unit. surface that is an aquifer, as well as lower
aquifers that are hydraulically
A qualified ground-water scientist must interconnected with this aquifer within the
certify that the number, spacing, and depths facility property boundary." These lower
of the monitoring wells are appropriate for aquifers may be separated physically from
the MSWLF unit. This certification must be the uppermost aquifer by less permeable
placed in the operating records. The State strata (having a lower hydraulic
Director must be notified within 14 days conductivity) that are often termed
that the certification was placed in the aquitards. An aquitard is a less permeable
operating record. geologic unit or series of closely layered
units (e.g., silt, clay, or shale) that in itself
5.6.3 Technical Considerations will not yield significant quantities of water
but will transmit water through its
The objective of a ground-water monitoring thickness. Aquitards may include thicker
system is to intercept ground water that has stratigraphic sequences of clays, shales, and
been contaminated by leachate from the dense, unfractured crystalline rocks (Freeze
MSWLF unit. Early contaminant detection and Cherry, 1979).
is important to allow sufficient time for
corrective measures to be developed and To be considered part of the uppermost
implemented before sensitive receptors are aquifer, a lower zone of saturation must be
significantly affected. To accomplish this hydraulically connected to the uppermost
objective, the monitoring wells should be aquifer within the facility property
located to sample ground water from the boundary. Generally, the degree of
uppermost aquifer at the closest practicable communication between aquifers is
distance from the waste management unit evaluated by ground-water pumping tests.
boundary. An alternative distance that is Methods have been devised for use in
protective of human health and the analyzing aquifer test data. A summary is
environment may be granted by the Director presented in Handbook: Ground Water,
of an approved State. Since the monitoring Vol. II (USEPA, 1991). The following
program is intended to operate through the discussions under this section (5.6.3) should
post-closure period, the location, design, assist the owner or operator in
and installation of monitoring wells should characterizing the uppermost aquifer and
address both existing conditions and the hydrogeology of the site.
anticipated facility development, as well as
expected changes in ground-water flow. Determination of Background Ground-
Water Quality
Uppermost Aquifer
The goal of monitoring-well placement is to
Monitoring wells must be placed to provide detect changes in the quality of ground
representative ground-water samples from water resulting from a release from the
the uppermost aquifer. The uppermost MSWLF unit. The natural chemical
composition of ground water is controlled
221
Subpart E
primarily by the mineral composition of the ! The facility is located near production
geologic unit comprising the aquifer. As wells that influence the direction of
ground water moves from one geologic unit ground-water flow.
to another, its chemical composition may
change. To reduce the probability of ! Upgradient ground-water quality is
detecting naturally occurring differences in affected by a source of contamination
ground-water quality between background other than the MSWLF unit.
and downgradient locations, only ground-
water samples collected from the same ! The proposed or existing landfill
geologic unit should be compared. overlies a ground-water divide or local
source of recharge.
Ground-water quality in areas where the
geology is complex can be difficult to ! Geologic units present at downgradient
characterize. As a result, the rule allows the locations are absent at upgradient
owner or operator flexibility in determining locations.
where to locate wells that will be used to
establish background water quality. ! Karst terrain or fault zones modify flow.
If the facility is new, ground-water samples ! Nearby surface water influences ground-
collected from both upgradient and water flow directions.
downgradient locations prior to waste
disposal can be used to establish background ! Waste management areas are located
water quality. The sampling should be close to a property boundary that is
conducted to account for both seasonal and upgradient of the facility.
spatial variability in ground-water quality.
Multi-Unit Monitoring Systems
Determining background ground-water
quality by sampling wells that are not A multi-unit ground-water monitoring
hydraulically upgradient may be necessary system does not have wells at individual
where hydrogeologic conditions do not MSWLF unit boundaries. Instead, an
allow the owner or operator to determine imaginary line is drawn around all of the
which wells are hydraulically upgradient. units at the facility. (See Figure 5-1 for a
Additionally, background ground-water comparison of single unit and multi-unit
quality may be determined by sampling systems.) This line constitutes the relevant
wells that provide ground-water samples as point of compliance. The option to
representative or more representative than establish a multi-unit monitoring system is
those provided by upgradient wells. These restricted to facilities located in approved
conditions include the following: States. A multi-unit system must be
approved by the Director of an approved
! The facility is located above an aquifer State after consideration has been given to
in which ground-water flow directions the:
change seasonally.
! Number, spacing, and orientation of the
MSWLF units
222
Figure 5-1. Comparison of Single Unit and Multi-Unit Monitoring System
223
Subpart E
! Hydrogeologic setting ! The geology at the owner's/operator's

facility (e.g, stratigraphy, lithology, and
! Site history structural setting)
! Engineering design of the MSWLF units ! The chemical properties of the

uppermost aquifer and its confining
! Type of wastes accepted at the facility. layers relative to local ground-water
chemistry and wastes managed at the
The purpose of a multi-unit system is to facility
reduce the number of monitoring wells that
can provide the same information. The ! Ground-water flow, including:
conceptual design of the multi-unit system
should consider the use and management of - The vertical and horizontal directions
the facility with respect to anticipated unit of ground-water flow in the uppermost
locations. In some cases, it may be possible aquifer
to justify a reduction in the number of wells
if the waste management units are aligned - The vertical and horizontal
along the same flow path in the ground- components of the hydraulic gradient
water system. in the uppermost and any hydraulically
connected aquifer
The multi-unit monitoring system must
provide a level of protection to human - The hydraulic conductivities of the
health and the environment that is materials that comprise the upper-most
comparable to monitoring individual units. aquifer and its confining units/layers
The multi-unit system should allow
adequate time after detection of - The average linear horizontal velocity
contamination to develop and implement of ground-water flow in the uppermost
corrective measures before sensitive aquifer.
receptors are adversely affected.
The elements of a program to characterize
Hydrogeological Characterization the hydrogeology of a site are discussed
briefly in the sections that follow and are
Adequate monitoring-well placement addressed in more detail in "RCRA Ground-
depends on collecting and evaluating Water Monitoring: Draft Technical
hydrogeological information that can be Guidance" (USEPA, 1992a).
used to form a conceptual model of the site.
The goal of a hydrogeological investigation Prior to initiating a field investigation, the
is to acquire site-specific data concerning: owner or operator should perform a
preliminary investigation. The preliminary
! The lateral and vertical extent of the investigation will involve reviewing all
uppermost aquifer available information about the site, which
may consist of:
! The lateral and vertical extent of the
upper and lower confining units/layers
224
! Information on the waste management Characterizing Site Geology

history of the site, including:
After the preliminary investigation is
- A chronological history of the site, complete, the owner/operator will have
including descriptions of wastes information that he/she can use to develop a
managed on-site plan to characterize site hydrogeology
further.
- A summary of documented releases
Nearly all hydrogeological investigations
- Details on the structural integrity of include a subsurface boring program. A
the MSWLF unit and physical controls boring program is necessary to define site
on waste migration hydrogeology and the small-scale geology
of the area beneath the site. The program
! A literature review, including: usually requires more than one iteration.
The objective of the initial boreholes is to
- Reports of research performed in the refine the conceptual model of the site
area of the site derived from the preliminary investigation.
- Journal articles The subsurface boring program should be

designed as follows:
- Studies and reports available from
local, regional, and State offices (e.g., ! The initial number of boreholes and their
geologic surveys, water boards, and spacing is based on the information
environmental agencies) obtained during the preliminary
investigation.
- Studies available from Federal offices,
such as USGS or USEPA ! Additional boreholes should be installed
as needed to provide more information
! Information from file searches, about the site.
including:
! Samples should be collected from the
- Reports of previous investigations at borings at changes in lithology. For
the site boreholes that will be completed as
monitoring wells, at least one sample
- Geological and environmental should be collected from the interval that
assessment data from State and Federal will be the screened interval. Boreholes
reports. that will not be completed as monitoring
wells must be properly decommissioned.
The documentation itemized above is by no
means a complete listing of information Geophysical techniques, cone penetrometer
available for a preliminary investigation. surveys, mapping programs, and laboratory
Many other sources of hydrogeological analyses of borehole samples can be used to
information may be available for review plan and supplement the subsurface boring
during the preliminary investigation. program. Downhole geophysical techniques
225
Subpart E
include electric, sonic, and nuclear logging. ! Seasonal/temporal, natural, and

Surface geophysical techniques include artificially induced (e.g., off-site
seismic reflection and refraction, as well as production well-pumping, agricultural
electromagnetic induction and resistivity. use) short-term and long-term
variations in ground-water elevations
The data obtained from the subsurface and flow patterns
boring program should enable the owner or
operator to identify: ! The hydraulic conductivities of the
stratigraphic units at the site, including
! Lithology, soil types, and stratigraphy vertical hydraulic conductivity of the
confining layer(s).
! Zones of potentially high hydraulic
conductivity Determining Ground-Water Flow
Direction and Hydraulic Gradient
! The presence of confining formations or
layers Installing monitoring wells that will provide
representative background and
! Unpredicted geologic features, such as downgradient water samples requires a
fault zones, cross-cutting structures, and thorough understanding of how ground
pinch-out zones water flows beneath a site. Developing such
an understanding requires obtaining
! Continuity of petrographic features, such information regarding both ground-water
as sorting, grain size distribution, and flow direction(s) and hydraulic gradient.
cementation Ground-water flow direction can be thought
of as the idealized path that ground-water
! The potentiometric surface or water follows as it passes through the subsurface.
table. Hydraulic gradient (i) is the change in static
head per unit of distance in a given
Characterizing Ground-Water Flow direction. The static head is defined as the
Beneath the Site height above a standard datum of the surface
of a column of water (or other liquid) that
In addition to characterizing site geology, can be supported by the static pressure at a
the owner/operator should characterize the given point (i.e., the sum of the elevation
hydrology of the uppermost aquifer and its head and pressure head).
confining layer(s) at the site. The owner or
operator should install wells and/or To determine ground-water flow directions
piezometers to assist in characterizing site and hydraulic gradient, owners and
hydrology. The owner/operator should operators should develop and implement a
determine and assess: water level-monitoring program. This
program should be structured to provide
! The direction(s) and rate(s) of ground- precise water level measurements in a
water flow (including both horizontal sufficient number of piezometers or wells at
and vertical components of flow) a sufficient frequency to gauge both
seasonal average flow directions and
226
temporal fluctuations in ground-water flow the waste types managed at the facility) in
directions. Ground-water flow direction(s) the subsurface at the facility, both the
should be determined from water levels depth(s) to the immiscible layer(s) and the
measured in wells screened in the same thickness(es) of the immiscible layer(s) in
hydro-stratigraphic position. In the well should be recorded.
heterogeneous geologic settings (i.e.,
settings in which the hydraulic For the purpose of measuring total head,
conductivities of the subsurface materials piezometers and wells should have as short
vary with location in the subsurface), long a screened interval as possible.
well screens can intercept stratigraphic Specifically, the screens in piezometers or
horizons with different (e.g., contrasting) wells that are used to measure head should
ground-water flow directions and different generally be less than 10 feet long. In
heads. In this situation, the resulting water circumstances including the following, well
levels will not provide the depth-discrete screens longer than 10 feet may be
head measurements required for accurate warranted:
determination of the ground-water flow
direction. ! Natural water level fluctuations
necessitate a longer screen length.
In addition to evaluating the component of
ground-water flow in the horizontal ! The interval monitored is slightly
direction, a program should be undertaken greater than the appropriate screen
to assess the vertical component of ground- length (e.g., the interval monitored is
water flow. Vertical ground-water flow 12 feet thick).
information should be based, at least in part,
on field data from wells and piezometers, ! The aquifer monitored is homogeneous
such as multi-level wells, piezometer and extremely thick (e.g., greater than
clusters, or multi-level sampling devices, 300 feet); thus, a longer screen (e.g., a
where appropriate. The following sections 20-foot screen) represents a fairly
provide acceptable methods for assessing discrete interval.
the vertical and horizontal components of
flow at a site. The head measured in a well with a long
screened interval is a function of all of the
Ground-Water Level Measurements different heads over the entire length of the
screened interval. Care should be taken
To determine ground-water flow directions when interpreting water levels collected
and ground-water flow rates, accurate water from wells that have long screened intervals
level measurements (measured to the nearest (e.g., greater than 10 feet).
0.01 foot) should be obtained. Section 5.8
delineates procedures for obtaining water The water-level monitoring program should
level measurements. At facilities where it is be structured to provide precise water level
known or plausible that immiscible measurements in a sufficient number of
contaminants (i.e., non-aqueous phase piezometers or wells at a sufficient
liquids (NAPLs)) occur (or are determined frequency to gauge both seasonal average
to be potentially present after considering flow directions and temporal fluctuations in
227
Subpart E
ground-water flow directions. The USEPA (1989c) and Freeze and Cherry
owner/operator should determine and assess (1979). Methods for calculating hydraulic
seasonal/temporal, natural, and artificially gradient are provided by Heath (1982) and
induced (e.g., off-site production well- USEPA (1989c).
pumping, agricultural use) short-term and
long-term variations in ground-water A potentiometric surface or water table map
elevations, ground-water flow patterns, and will give an approximate idea of general
ground-water quality. ground-water flow directions. However, to
locate monitoring wells properly, ground-
Establishing Horizontal Flow Direction water flow direction(s) and hydraulic
and the Horizontal Component of gradient(s) should be established in both the
Hydraulic Gradient horizontal and vertical directions and over
time at regular intervals (e.g., over a 1-year
After the water level data and measurement period at 3-month intervals).
procedures are reviewed to determine that
they are accurate, the data should be used Establishing Vertical Flow Direction and
to: the Vertical Component of Hydraulic
Gradient
! Construct potentiometric surface maps
and water table maps based on the To make an adequate determination of the
distribution of total head. The data ground-water flow directions, the vertical
used to develop water table maps component of ground-water flow should be
should be from piezometers or wells evaluated directly. This generally requires
screened across the water table. The the installation of multiple piezometers or
data used to develop potentiometric wells in clusters or nests, or the installation
surface maps should be from of multi-level wells or sampling devices. A
piezometers or wells screened at piezometer or well nest is a closely spaced
approximately the same elevation in group of piezometers or wells screened at
the same hydrostratigraphic unit; different depths, whereas a multi-level well
is a single device. Both piezometer/well
! Determine the horizontal direction(s) nests and multi-level wells allow for the
of ground-water flow by drawing flow measurement of vertical variations in
lines on the potentiometric surface map hydraulic head.
or water table map (i.e., construct a
flow net); When reviewing data obtained from
multiple placement of piezometers or wells
! Calculate value(s) for the horizontal in single boreholes, the construction details
and vertical components of hydraulic of the well should be carefully evaluated.
gradient. Not only is it extremely difficult to seal
several piezometers/wells at discrete depths
Methods for constructing potentiometric within a single borehole, but sealant
surface and water table maps, constructing materials may migrate from the seal of one
flow nets, and determining the direction(s) piezometer/well to the screened interval of
of ground-water flow are provided by another piezometer/well. Therefore, the
228
design of a piezometer/well nest should be Further information can be obtained from

considered carefully. Placement of Freeze and Cherry (1979).
piezometers/wells in closely spaced
boreholes, where piezometers/wells have Determining Hydraulic Conductivity
been screened at different, discrete depth
intervals, is likely to produce more accurate Hydraulic conductivity is a measure of a
information. The primary concerns with the material's ability to transmit water.
installation of piezometers/wells in closely Generally, poorly sorted silty or clayey
spaced, separate boreholes are: 1) the materials have low hydraulic conductivities,
disturbance of geologic and soil materials whereas well-sorted sands and gravels have
that occurs when one piezometer is installed high hydraulic conductivities. An aquifer
may be reflected in the data obtained from may be classified as either homogeneous or
another piezometer located nearby, and 2) heterogeneous and either isotropic or
the analysis of water levels measured in anisotropic according to the way its
piezometers that are closely spaced, but hydraulic conductivity varies in space. An
separated horizontally, may produce aquifer is homogeneous if the hydraulic
imprecise information regarding the vertical conductivity is independent of location
component of ground-water flow. The within the aquifer; it is heterogeneous if
limitations of installing multiple hydraulic conductivities are dependent on
piezometers either in single or separate location within the aquifer. If the hydraulic
boreholes may be overcome by the conductivity is independent of the direction
installation of single multi-level monitoring of measurement at a point in a geologic
wells or sampling devices in single formation, the formation is isotropic at that
boreholes. The advantages and point. If the hydraulic conductivity varies
disadvantages of these types of devices are with the direction of measurement at a
discussed by USEPA (1989f). point, the formation is anisotropic at that
point.
The owner or operator should determine the
vertical direction(s) of ground-water flow Determining Hydraulic Conductivity
using the water levels measured in multi- Using Field Methods
level wells or piezometer/well nests to
construct flow nets. Flow nets should depict Sufficient aquifer testing (i.e., field
the piezometer/well depth and length of the methods) should be performed to provide
screened interval. It is important to portray representative estimates of hydraulic
the screened interval accurately on the flow conductivity. Acceptable field methods
net to ensure that the piezometer/well is include conducting aquifer tests with single
actually monitoring the desired wells, conducting aquifer tests with multiple
water-bearing unit. A flow net should be wells, and using flowmeters. This section
developed from information obtained from provides brief overviews of these methods,
piezometer/ well clusters or nests screened including two methods for obtaining
at different, discrete depths. Detailed vertically discrete measurements of
guidance for the construction and evaluation hydraulic conductivity. The identified
of flow nets in cross section (vertical flow references provide detailed descriptions of
nets) is provided by USEPA (1989c). the methods summarized in this section.
229
Subpart E
A commonly used test for determining to provide hydraulic conductivity data for
horizontal hydraulic conductivity with a that zone. Multiple-well tests for hydraulic
single well is the slug test. A slug test is conductivity characterize a greater
performed by suddenly adding, removing, proportion of the subsurface than single-
or displacing a known volume of water from well tests and, thus, provide average values
a well and observing the time that it takes of hydraulic conductivity. Multiple-well
for the water level to recover to its original tests require measurement of parameters
level (Freeze and Cherry, 1979). Similar similar to those required for single-well
results can be achieved by pressurizing the tests (e.g., time, drawdown). When using
well casing, depressing the water level, and aquifer test data to determine aquifer
suddenly releasing the pressure to simulate parameters, it is important that the solution
the removal of water from the well. In most assumptions can be applied to site
cases, EPA recommends that water not be conditions. Aquifer test solutions are
introduced into wells during aquifer tests to available for a wide variety of
avoid altering ground-water chemistry. hydrogeologic settings, but are often applied
Single-well tests are limited in scope to the incorrectly by inexperienced persons.
area directly adjacent to the well screen. Incorrect assumptions regarding
The vertical extent of the well screen hydrogeology (e.g., aquifer boundaries,
generally defines the part of the geologic aquifer lithology, and aquifer thickness)
formation that is being tested. may translate into incorrect estimations of
hydraulic conductivity. A qualified ground-
A modified version of the slug test, known water scientist with experience in designing
as the multilevel slug test, is capable of and interpreting aquifer tests should be
providing depth-discrete measurements of consulted to ensure that aquifer test solution
hydraulic conductivity. The drawback of methods fit the hydrogeologic setting.
the multilevel slug test is that the test relies Kruseman and deRidder (1989) provide a
on the ability of the investigator to isolate a comprehensive discussion of aquifer tests.
portion of the aquifer using a packer.
Nevertheless, multilevel slug tests, when Multiple-well tests conducted with wells
performed properly, can produce reliable screened in different water-bearing zones
measurements of hydraulic conductivity. furnish information concerning hydraulic
communication among the zones. Water
Multiple-well tests involve withdrawing levels in these zones should be monitored
water from, or injecting water into, one during the aquifer test to determine the type
well, and obtaining water level of aquifer system (e.g., confined,
measurements over time in observation unconfined, semi-confined, or semi-
wells. Multiple-well tests are often unconfined) beneath the site, and their
performed as pumping tests in which water leakance (coefficient of leakage) and
is pumped from one well and drawdown is drainage factors (Kruseman and deRidder,
observed in nearby wells. A step-drawdown 1989). A multiple-well aquifer test should
test should precede most pumping tests to be considered at every site as a method to
determine an appropriate discharge rate. establish the vertical extent of the
Aquifer tests conducted with wells screened uppermost aquifer and to evaluate hydraulic
in the same water-bearing zone can be used connection between aquifers.
230
Certain aquifer tests are inappropriate for ! In designing aquifer tests and
use in karst terrains characterized by a interpreting aquifer test data,
well-developed conduit flow system, and owners/operators should account and
they also may be inappropriate in fractured correct for seasonal, temporal, and
bedrock. When a well located in a karst anthropogenic effects on the
conduit or a large fracture is pumped, the potentiometric surface or water table.
water level in the conduit is lowered. This This is usually done by installing
lowering produces a drawdown that is not piezometers outside the influence of
radial (as in a granular aquifer) but is the stressed aquifer. These
instead a trough-like depression parallel to piezometers should be continuously
the pumped conduit or fracture. Radial flow monitored during the aquifer test.
equations do not apply to drawdown data
collected during such a pump test. This ! Owners and operators should be aware
means that a conventional semi-log plot of that, in a very high hydraulic
drawdown versus time is inappropriate for conductivity aquifer, the screen size
the purpose of determining the aquifer's and/or filter pack used in the test well
transmissivity and storativity. Aquifer tests can affect an aquifer test. If a very
in karst aquifers can be useful, but valid small screen size is used, and the pack
determinations of hydraulic conductivity, is improperly graded, the test may
storativity, and transmissivity may be reflect the characteristics of the filter
impossible. However, an aquifer test can pack, rather than the aquifer.
provide information on the presence of
conduits, on storage characteristics, and on ! EPA recommends the use of a step-
the percentage of Darcian flow. McGlew drawdown test to provide a basis for
and Thomas (1984) provide a more detailed selecting discharge rates prior to
discussion of the appropriate use of aquifer conducting a full-scale pumping test.
tests in fractured bedrock and on the This will ensure that the pumping rate
suitable interpretation of test data. Dye chosen for the subsequent pumping
tracing also is used to determine the rate and test(s) can be sustained without
direction of ground-water flow in karst exceeding the available drawdown of
settings (Section 5.2.4). the pumped wells. In addition, this test
will produce a measurable drawdown
Several additional factors should be in the observation wells.
considered when planning an aquifer test:
Certain flowmeters recently have been
! Owners and operators should provide recognized for their ability to provide
for the proper storage and disposal of accurate and vertically discrete
potentially contaminated ground water measurements of hydraulic conductivity.
pumped from the well system. One of these, the impeller flowmeter, is
available commercially. More sensitive
! Owners and operators should consider types of flowmeters (i.e., the heat-pulse
the potential effects of pumping on flowmeter and electromagnetic flowmeter)
existing plumes of contaminated should be available in the near future. Use
ground water. of the impeller flowmeter requires running
231
Subpart E
a caliper log to measure the uniformity of hydraulic properties of the tested material).
the diameter of the well screen. The well is Special attention should be given to the
then pumped with a small pump operated at selection of the appropriate test method and
a constant flow rate. The flowmeter is test conditions and to quality control of
lowered into the well, and the discharge rate laboratory results. McWhorter and Sunada
is measured every few feet by raising the (1977), Freeze and Cherry (1979), and
flowmeter in the well. Hydraulic Sevee (1991) discuss determining hydraulic
conductivity values can be calculated from conductivity in the laboratory. Laboratory
the recorded data using the Cooper-Jacob tests may provide the best estimates of
(1946) formula for horizontal flow to a hydraulic conductivity for materials in the
well. Use of the impeller flowmeter is unsaturated zone, but they are likely to be
limited at sites where the presence of low less accurate than field methods for
permeability materials does not allow materials in the saturated zone (Cantor et
pumping of the wells at rates sufficient to al., 1987).
operate the flowmeter. The application of
flowmeters in the measure of hydraulic Determining Ground-Water Flow Rate
conductivity is described by Molz et al.
(1990) and Molz et al. (1989). The calculation of the average ground-water
flow rate (average linear velocity of ground-
Determining Hydraulic Conductivity water flow), or seepage velocity, is
Using Laboratory Methods discussed in detail in USEPA (1989c), in
Freeze and Cherry (1979), and in Kruseman
It may be beneficial to use laboratory and deRidder (1989). The average linear
measurements of hydraulic conductivity to velocity of ground-water flow (v̄) is a
augment the results of field tests. However, function of hydraulic conductivity (K),
field methods provide the best estimates of hydraulic gradient (i), and effective porosity
hydraulic conductivity in most cases. (ne):
Because of the limited sample size,
laboratory tests can fail to account for v̄ = - Ki
secondary porosity features, such as ne
fractures and joints, and hence, can greatly
underestimate overall aquifer hydraulic Methods for determining hydraulic gradient
conductivities. Laboratory tests may and hydraulic conductivity have been
provide valuable information about the presented previously. Effective porosity,
vertical component of hydraulic the percentage of the total volume of a given
conductivity of aquifer materials. However, mass of soil, unconsolidated material, or
laboratory test results always should be rock that consists of interconnected pores
confirmed by field measurements, which through which water can flow, should be
sample a much larger portion of the aquifer. estimated from laboratory tests or from
In addition, laboratory test results can be values cited in the literature. (Fetter (1980)
profoundly affected by the test method provides a good discussion of effective
selected and by the manner in which the porosity. Barari and Hedges (1985) provide
tests are carried out (e.g., the extent to default values for effective porosity.)
which sample collection and preparation USEPA (1989c) provides methods for
have changed the in situ
232
determining flow rates in heterogeneous preliminary investigation to verify the

and/or anisotropic systems and should be collected information.
consulted prior to calculating flow rates.
! Determine whether laboratory and
Interpreting and Presenting Data field data corroborate and are
sufficient to define petrology, effective
The following sections offer guidance on porosity, hydraulic conductivity,
interpreting and presenting hydrogeologic lateral and vertical stratigraphic
data collected during the site relationships, and ground-water flow
characterization process. Graphical directions and rates.
representations of data, such as cross
sections and maps, are typically extremely After the hydrogeologic data are interpreted,
helpful both when evaluating data and when the findings should be reviewed to:
presenting data to interested individuals.
! Identify information gaps
Interpreting Hydrogeologic Data
! Determine whether the collection of
Once the site characterization data have additional data or reassessment of
been collected, the following tasks should existing data is required to fill in the
be undertaken to support and develop the gaps
interpretation of these data:
! Identify how information gaps are
! Review borehole and well logs to likely to affect the ability to design a
identify major rock, unconsolidated RCRA monitoring system.
material, and soil types and establish
their horizontal and vertical extent and Generally, lithologic data should correlate
distribution. with hydraulic properties (e.g., clean, well-
sorted, unconsolidated sands should exhibit
! From borehole and well log (and high hydraulic conductivity). Additional
outcrop, where available) data, boreholes should be drilled and additional
construct representative cross-sections samples should be collected to describe the
for each MSWLF unit, one in the hydrogeology of the site if the investigator
direction of ground-water flow and one is unable to 1) correlate stratigraphic units
orthogonal to ground-water flow. between borings, 2) identify zones of
potentially high hydraulic conductivity and
! Identify zones of suspected high the thickness and lateral extent of these
hydraulic conductivity, or structures zones, or 3) identify confining
likely to influence contaminant formations/layers and the thickness and
migration through the unsaturated and lateral extent of these formation layers.
saturated zones.
When establishing the locations of wells
! Compare findings with other studies that will be used to monitor ground water in
and information collected during the hydrogeologic settings characterized by
ground-water flow in porous media, the
following should be documented:
233
Subpart E
! The ground-water flow rate should be Geologic and soil maps should be based on
based on accurate measurements of rock, unconsolidated material, and soil
hydraulic conductivity and hydraulic identifications gathered from borings and
gradient and accurate measurements or outcrops. The maps should use colors or
estimates of effective porosity symbols to represent each soil,
unconsolidated material, and rock type that
! The horizontal and vertical outcrops on the surface. The maps also
components of flow should be should show the locations of outcrops and
accurately depicted in flow nets and all borings placed during the site
based on valid data characterization. Geologic and soil maps
are important because they can provide
! Any seasonal or temporal variations in information describing how site geology fits
the water table or potentiometric into the local and regional geologic setting.
surface, and in vertical flow
components, should be determined. Structure contour maps and isopach maps
should be prepared for each water-bearing
Once an understanding of horizontal and zone that comprises the uppermost aquifer
vertical ground-water flow has been and for each significant confining layer,
established, it is possible to estimate where especially the one underlying the uppermost
monitoring wells will most likely intercept aquifer. A structure contour map depicts
contaminant flow. the configuration (i.e., elevations) of the
upper or lower surface or boundary of a
Presenting Hydrogeologic Data particular geologic or soil formation, unit,
or zone. Structure contour maps are
Subsequent to the generation and especially important in understanding dense
interpretation of site-specific geologic data, non-aqueous phase liquid (DNAPL)
the data should be presented in geologic movement because DNAPLs (e.g.,
cross-sections, topographic maps, geologic tetrachloroethylene) may migrate in the
maps, and soil maps. The Agency suggests direction of the dip of lower permeability
that owners/operators obtain or prepare and units. Separate structure contour maps
review topographic, geologic, and soil maps should be constructed for the upper and
of the facility, in addition to site maps of the lower surfaces (or contacts) of each zone of
facility and MSWLF units. In cases where interest. Isopach maps should depict
suitable maps are not available, or where the contours that indicate the thickness of each
information contained on available maps is zone. These maps are generated from
not complete or accurate, detailed mapping borings and geologic logs and from
of the site should be performed by qualified geophysical measurements. In conjunction
and experienced individuals. An aerial with cross-sections, isopach maps may be
photograph and a topographic map of the used to help determine monitoring well
site should be included as part of the locations, depths, and screen lengths during
presentation of hydrogeologic data. The the design of the detection monitoring
topographic map should be constructed system.
under the supervision of a qualified
surveyor and should provide contours at a
maximum of 2-foot intervals.
234
A potentiometric surface map or water table a conceptual model. This model is the
map should be prepared for each water- integrated picture of the hydrogeologic
bearing zone that comprises the uppermost system and the waste management setting.
aquifer. Potentiometric surface and water The final conceptual model must be a site-
table maps should show both the direction specific description of the unsaturated zone,
and rate of ground-water flow and the the uppermost aquifer, and its confining
locations of all piezometers and wells on units. The model should contain all of the
which they are based. The water level information necessary to design a ground-
measurements for all piezometers and wells water monitoring system.
on which the potentiometric surface map or
water table map is based should be shown Monitoring Well Placement
on the potentiometric surface or water table
map. If seasonal or temporal variations in This section separately addresses the lateral
ground-water flow occur at the site, a placement and the vertical sampling
sufficient number of potentiometric surface intervals of point of compliance wells.
or water table maps should be prepared to However, these two aspects of well
show these variations. Potentiometric placement should be evaluated together in
surface and water table maps can be the design of the monitoring system. Site-
combined with structure contour maps for a specific hydrogeologic data obtained during
particular formation or unit. An adequate the site characterization should be used to
number of cross sections should be prepared determine the lateral placement of detection
to depict significant stratigraphic and monitoring wells and to select the length
structural trends and to reflect stratigraphic and vertical position of monitoring well
and structural features in relation to local intakes. Potential pathways for contaminant
and regional ground-water flow. migration are three-dimensional.
Consequently, the design of a detection
Hydrogeological Report monitoring network that intercepts these
potential pathways requires a
The hydrogeological report should contain, three-dimensional approach.
at a minimum:
Lateral Placement of Point of
! A description of field activities Compliance Monitoring Wells
! Drilling and/or well construction logs Point of compliance monitoring wells

should be as close as physically possible to
! Analytical data the edge of the MSWLF unit(s) and should
be screened in all transmissive zones that
! A discussion and interpretation of the may act as contaminant transport pathways.
data The lateral placement of monitoring wells
should be based on the number and spatial
! Recommendations to address data gaps. distribution of potential contaminant
migration pathways and on the depths and
The final output of the site characterization thicknesses of stratigraphic horizons that
phase of the hydrogeological investigation can serve as contaminant migration
is pathways.
235
Subpart E
Point of compliance monitoring wells In some settings, the ground-water flow

should be placed laterally along the direction may reverse seasonally (depending
downgradient edge of the MSWLF unit to on precipitation), change as a result of tidal
intercept potential pathways for influences or river and lake stage
contaminant migration. The local ground- fluctuations, or change temporally as a
water flow direction and gradient are the result of well-pumping or changing land use
major factors in determining the lateral patterns. In other settings, ground water
placement of point of compliance wells. In may flow away from the waste management
a homogeneous, isotropic hydrogeologic area in all directions. In such cases, EPA
setting, well placement can be based on recommends that monitoring wells be
general aquifer characteristics (e.g., installed on all sides (or in a circular
direction and rate of ground-water flow), pattern) around the waste management area
and potential contaminant fate and transport to allow for the detection of contamination.
characteristics (e.g., advection, dispersion). In these cases, certain wells may be
More commonly, however, geology is downgradient only part of the time, but such
variable and preferential pathways exist that a configuration should ensure that releases
control the migration of contaminants. from the unit will be detected.
These types of heterogeneous, anisotropic
geologic settings can have numerous, The lateral placement of monitoring wells
discrete zones within which contaminants also should be based on the physical/
may migrate. chemical characteristics of the contaminants
of concern. While the restriction of liquids
Potential migration pathways include zones in MSWLFs may limit the introduction of
of relatively high intrinsic (matrix) hazardous constituents into landfills, it is
hydraulic conductivities, fractured/faulted important to consider the physical/chemical
zones, and subsurface material that may characteristics of contaminants when
increase in hydraulic conductivity if the designing the well system. These
material is exposed to waste(s) managed at characteristics include solubility, Henry's
the site (e.g., a limestone layer that Law constant, partition coefficients, specific
underlies an acidic waste). In addition to gravity, contaminant reaction or degradation
natural hydrogeologic features, human- products, and the potential for contaminants
made features may influence the ground- to degrade confining layers. For example,
water flow direction and, thus, the lateral contaminants with low solubilities and high
placement of point of compliance wells. specific gravities that occur as DNAPLs
Such human-made features include ditches, may migrate in the subsurface in directions
areas where fill material has been placed, different from the direction of ground-water
buried piping, buildings, leachate collection flow. Therefore, in situations where the
systems, and adjacent disposal units. The release of DNAPLs is a concern, the lateral
lateral placement of monitoring wells placement of compliance point ground-
should be based on the number and spatial water monitoring wells should not
distribution of potential contaminant necessarily only be along the downgradient
migration pathways and on the depths and edge of the MSWLF unit. Considering both
thicknesses of stratigraphic horizons that contaminant characteristics and
can serve as contaminant migration hydrogeologic properties is important when
pathways.
236
determining the lateral placement of the boring program, and from samples
monitoring wells. collected while drilling the monitoring well.
Direct physical data can be supplemented by
Vertical Placement and Screen Lengths geophysical data, available regional/local
hydrogeological data, and other data that
Proper selection of the vertical sampling provide the vertical distribution of hydraulic
interval is necessary to ensure that the conductivity. The vertical sampling interval
monitoring system is capable of detecting a is not necessarily synonymous with aquifer
release from the MSWLF unit. The vertical thickness. Monitoring wells are often
position and lengths of well intakes are screened at intervals that represent a portion
functions of (1) hydro-geologic factors that of the thickness of the aquifer. When
determine the distribution of, and monitoring an unconfined aquifer, the well
fluid/vapor phase transport within, potential screen typically should be positioned so that
pathways of contaminant migration to and a portion of the well screen is in the
within the uppermost aquifer, and (2) the saturated zone and a portion of the well
chemical and physical characteristics of screen is in the unsaturated zone (i.e., the
contaminants that control their transport and well screen straddles the water table).
distribution in the subsurface. Well intake While the restriction of liquids in MSWLFs
length also is determined by the need to may limit the introduction of hazardous
obtain vertically discrete ground-water constituents into landfills, it is important to
samples. Owners and operators should consider the physical/chemical
determine the probable location, size, and characteristics of contaminants when
geometry of potential contaminant plumes designing the well system.
when selecting well intake positions and
lengths. The vertical positions and lengths of
monitoring well intakes should be based on
Site-specific hydrogeologic data obtained the same physical/chemical characteristics
during the site characterization should be of the contaminants of concern that
used to select the length and vertical influence the lateral placement of
position of monitoring well intakes. The monitoring wells. Considering both
vertical positions and lengths of monitoring contaminant characteristics and
well intakes should be based on the number hydrogeologic properties is important when
and spatial distribution of potential choosing the vertical position and length of
contaminant migration pathways and on the the well intake. Some contaminants may
depths and thicknesses of stratigraphic migrate within very narrow zones. Of
horizons that can serve as contaminant course, for well placement at a new site, it is
migration pathways. Figure 5-2 illustrates unlikely that the owner or operator will be
examples of complex stratigraphy that able to assess contaminant characteristics.
would require multiple vertical monitoring
intervals. Different transport processes control
contaminant migration depending on
The depth and thickness of a potential whether the contaminant dissolves or is
contaminant migration pathway can be immiscible in water. Immiscible
determined from soil, unconsolidated
material, and rock samples collected during
237
Subpart E
Figure 5-2
Upgradient and Downgradient
Designations for Idealized MSWLF
238
contaminants may occur as light non ! "Down-the-dip" of lower hydraulic

aqueous phase liquids (LNAPLs), which are conductivity units that act as confining
lighter than water, and DNAPLs, which are layers, both upgradient and
denser than water. LNAPLs migrate in the downgradient of the waste
capillary zone just above the water table. management area.
Wells installed to monitor LNAPLs should
be screened at the water table/capillary zone Because of the nature of DNAPL migration
interface, and the screened interval should (i.e., along structural, rather than hydraulic,
intercept the water table at its minimum and gradients), wells installed to monitor
maximum elevation. LNAPLs may become DNAPLs may need to be installed both
trapped in residual form in the vadose zone upgradient and downgradient of the waste
and become periodically remobilized and management area. It may be useful to
contribute further to aquifer contamination, construct a structure contour map of lower
either as free phase or dissolved phase permeability strata and identify lower
contaminants, as the water table fluctuates permeability lenses upgradient and
and precipitation infiltrates the subsurface. downgradient of the unit along which
DNAPLs may migrate. The wells can then
The migration of free-phase DNAPLs may be located accordingly.
be influenced primarily by the geology,
rather than the hydrogeology, of the site. The lengths of well screens used in
That is, DNAPLs migrate downward ground-water monitoring wells can
through the saturated zone due to density significantly affect their ability to intercept
and then migrate by gravity along less releases of contaminants. The complexity
permeable geologic units (e.g., the slope of of the hydrogeology of a site is an important
confining units, the slope of clay lenses in consideration when selecting the lengths of
more permeable strata, bedrock troughs), well screens. Most hydrogeologic settings
even in aquifers with primarily horizontal are complex (heterogeneous and
ground-water flow. Consequently, if wastes anisotropic) to a certain degree. Highly
disposed at the site are anticipated to exist heterogeneous formations require shorter
in the subsurface as a DNAPL, the potential well screens to allow sampling of discrete
DNAPL should be monitored: portions of the formation that can serve as
contaminant migration pathways. Well
! At the base of the aquifer (immediately screens that span more than a single
above the confining layer) saturated zone or a single contaminant
migration pathway may cause cross-
! In structural depressions (e.g., bedrock contamination of transmissive units, thereby
troughs) in lower hydraulic increasing the extent of contamination.
conductivity geologic units that act as Well intakes should be installed in a single
confining layers saturated zone. Well intakes (e.g., screens)
and filter pack materials should not
! Along lower hydraulic conductivity interconnect, or promote the interconnection
lenses and units within units of higher of, zones that are separated by a confining
hydraulic conductivity layer.
239
Subpart E
Even in hydrologically simple formations, would represent a fairly discrete interval in

or within a single potential pathway for a very thick formation. Formations with
contaminant migration, the use of shorter very low hydraulic conductivities also may
well screens may be necessary to detect require the use of longer well screens to
contaminants concentrated at particular allow sufficient amounts of formation water
depths. A contaminant may be concentrated to enter the well for sampling. The
at a particular depth because of its importance of accurately identifying such
physical/chemical properties and/or because conditions highlights the need for a
of hydrogeologic properties. In complete hydrogeologic site investigation
homogeneous formations, a long well screen prior to the design and placement of
can permit excessive amounts of detection wells.
uncontaminated formation water to dilute
the contaminated ground water entering the Multiple monitoring wells (well clusters or
well. At best, dilution can make multilevel sampling devices) should be
contaminant detection difficult; at worst, installed at a single location when (1) a
contaminant detection is impossible if the single well cannot adequately intercept and
concentrations of contaminants are diluted monitor the vertical extent of a potential
to levels below the detection limits for the pathway of contaminant migration, or (2)
prescribed analytical methods. The use of there is more than one potential pathway of
shorter well screens allows for contaminant contaminant migration in the subsurface at
detection by reducing excessive dilution. a single location, or (3) there is a thick
When placed at depths of predicted saturated zone and immiscible contaminants
preferential flow, shorter well screens are are present, or are determined to be
effective in monitoring the aquifer or the potentially present after considering waste
portion of the aquifer of concern. types managed at the facility. Conversely, at
sites where ground water may be
Generally, screen lengths should not exceed contaminated by a single contaminant,
10 feet. However, certain hydrogeologic where there is a thin saturated zone, and
settings may warrant or necessitate the use where the site is hydrogeologically
of longer well screens for adequate homogeneous, the need for multiple wells at
detection monitoring. Unconfined aquifers each sampling location is reduced. The
with widely fluctuating water tables may number of wells that should be installed at
require longer screens to intercept the water each sampling location increases with site
table surface at both its maximum and complexity.
minimum elevations and to provide
monitoring for the presence of contaminants The following sources provided additional
that are less dense than water. Saturated information on monitoring well placement:
zones that are slightly greater in thickness USEPA (1992a), USEPA (1990), USEPA
than the appropriate screen length (e.g., 12 (1991), and USEPA (1986a).
feet thick) may warrant monitoring with
longer screen lengths. Extremely thick
homogeneous aquifers (e.g., greater than
300 feet) may be monitored with a longer
screen (e.g., a 20-foot screen) because a
slightly longer screen
240
5.7 GROUND-WATER decommissioning of any monitoring well

MONITORING WELL DESIGN must be documented in the operating record
AND CONSTRUCTION of the facility and certified by a qualified
40 CFR §258.51 (c) ground-water scientist. Documentation is
required for wells, piezometers, sampling
5.7.1 Statement of Regulation devices, and water level measurement
instruments used in the monitoring program.
(c) Monitoring wells must be cased in a
manner that maintains the integrity of The monitoring wells must be cased to
the monitoring well bore hole. This protect the integrity of the borehole. The
casing must be screened or perforated design and construction of the well directly
and packed with gravel or sand, where affects the quality and representativeness of
necessary, to enable collection of ground- the samples collected. The well casing must
water samples. The annular space (i.e., have a screened or perforated interval to
the space between the bore hole and well allow the entrance of water into the well
casing) above the sampling depth must be casing. The annular space between the well
sealed to prevent contamination of screen and the formation wall must be
samples and the ground water. packed with material to inhibit the
migration of formation material into the
(1) The owner or operator must notify well. The well screen must have openings
the State Director that the design, sized according to the packing material
installation, development, and used. The annular space above the filter
decommission of any monitoring wells, pack must be sealed to provide a discrete
piezometers and other measurement, sampling interval.
sampling, and analytical devices
documentation has been placed in the All monitoring wells, piezometers, and
operating record; and sampling and analytical devices must be
maintained in a manner that ensures their
(2) The monitoring wells, piezometers, continued performance according to design
and other measurement, sampling, and specifications over the life of the monitoring
analytical devices must be operated and program.
maintained so that they perform to design
specifications throughout the life of the 5.7.3 Technical Considerations
monitoring program.
The design, installation, and maintenance of
§258.52 [Reserved]. monitoring wells will affect the consistency
and accuracy of samples collected. The
5.7.2 Applicability design must be based on site-specific
information. The formation material
The requirements for monitoring well (lithology and grain size distribution) will
design, installation, and maintenance are determine the selection of proper packing
applicable to all wells installed at existing and sealant materials, and the stratigraphy
units, lateral expansions of units, and new will determine the screen length for the
MSWLF units. The design, installation, and interval to be monitored. Installation
241
Subpart E
practices should be specified and overseen ! Relative ease of well completion and
to ensure that the monitoring well is development, including the ability to
installed as designed and will perform as install the well in the given
intended. This section will discuss the hydrogeologic setting.
factors that must be considered when
designing monitoring wells. Each well must In addition to these factors, USEPA (1989f)
be tailored to suit the hydrogeological includes matrices to assist in selecting an
setting, the contaminants to be monitored, appropriate drilling method. These matrices
and other site-specific factors. Figure 5-3 list the most commonly used drilling
depicts the components of a typical techniques for monitoring well installation,
monitoring well installation. taking into consideration hydrogeologic
settings and the objectives of the monitoring
The following sections provide a brief program.
overview of monitoring well design and
construction. More comprehensive The following basic performance objectives
discussions are provided in USEPA (1989f) should guide the selection of drilling
and USEPA (1992a). procedures for installing monitoring wells:
Selection of Drilling Method ! Drilling should be performed in a

manner that preserves the natural
The method chosen for drilling a monitoring properties of the subsurface materials.
well depends largely on the following
factors (USEPA, 1989f): ! Contamination and/or cross-
contamination of ground water and
! Versatility of the drilling method aquifer materials during drilling should
be avoided.
! Relative drilling cost
! The drilling method should allow for
! Sample reliability (ground-water, soil, the collection of representative
unconsolidated material, or rock samples of rock, unconsolidated
samples) materials, and soil.
! Availability of drilling equipment ! The drilling method should allow the

owner/operator to determine when the
! Accessibility of the drilling site appropriate location for the screened
interval has been encountered.
! Relative time required for well
installation and development ! The drilling method should allow for
proper placement of the filter pack and
! Ability of the drilling technology to annular sealants. The borehole should
preserve natural conditions be at least 4 inches larger in diameter
than the nominal diameter of the well
! Ability to install a well of desired casing and screen to allow adequate
diameter and depth
242
Figure 5.3. Example of a Monitoring Well Design-Single Cased Well
243
Subpart E
space for placement of the filter pack Monitoring Well Design

and annular sealants.
Well Casing
! The drilling method should allow for
the collection of representative ground- Well Casing and Screen Materials
water samples. Drilling fluids
(including air) should be used only A casing and well screen are installed in a
when minimal impact to the ground-water monitoring well for several
surrounding formation and ground reasons: to provide access from the surface
water can be ensured. of the ground to some point in the
subsurface, to prevent borehole collapse,
The following guidelines apply to the use of and to prevent hydraulic communication
drilling fluids, drilling fluid additives, and between zones within the subsurface. In
lubricants when drilling ground-water some cases, State or local regulations may
monitoring wells: specify the casing and material that the
owner or operator should use. A
! Drilling fluids, drilling fluid additives, comprehensive discussion of well casing
or lubricants that affect the analysis of and screen materials is provided in USEPA
hazardous constituents in ground-water (1989f) and in USEPA (1992a). The
samples should not be used. following discussion briefly summarizes
information contained in these references.
! The owner/operator should
demonstrate the inertness of drilling Monitoring well casing and screen materials
fluids, drilling fluid additives, and may be constructed of any of several types
lubricants by performing analytical of materials, but should meet the following
testing of drilling fluids, drilling fluid performance specifications:
additives, and lubricants and/or by
providing information regarding the ! Monitoring well casing and screen
composition of drilling fluids, drilling materials should maintain their
fluid additives, or lubricants obtained structural integrity and durability in
from the manufacturer. the environment in which they are used
over their operating life.
! The owner/operator should consider
the potential impact of drilling fluids, ! Monitoring well casings and screens
drilling fluid additives, and lubricants should be resistant to chemical and
on the physical and chemical microbiological corrosion and
characteristics of the subsurface and on degradation in contaminated and
ground-water quality. uncontaminated waters.
! The volume of drilling fluids, drilling ! Monitoring well casings and screens
fluid additives, and lubricants used should be able to withstand the
during the drilling of a monitoring well physical forces acting upon them
should be recorded. during and following their installation
and during their use -- including forces
244
due to suspension in the borehole, background wells and downgradient

grouting, development, purging, wells and including:
pumping, and sampling and forces
exerted on them by the surrounding - Natural ground-water geochemistry
geologic materials.
- Nature of suspected or known
! Monitoring well casing and screen contaminants
materials should not chemically alter
ground-water samples, especially with - Concentration of suspected or known
respect to the analytes of concern, as a contaminants
result of their sorbing, desorbing, or
leaching analytes. For example, if ! Design life of the monitoring well.
chromium is an analyte of interest, the
well casing or screen should not Casing materials widely available for use in
increase or decrease the amount of ground-water monitoring wells can be
chromium in the ground water. Any divided into three categories:
material leaching from the casing or
screen should not be an analyte of 1) Fluoropolymer materials, including
interest or interfere in the analysis of polytetrafluoroethylene (PTFE),
an analyte of interest. tetrafluoroethylene (TFE), fluorinated
ethylene propylene (FEP),
In addition, monitoring well casing and perfluoroalkoxy (PFA), and
screen materials should be relatively easy to polyvinylidene fluoride (PVDF)
install into the borehole during construction
of the monitoring well. 2) Metallic materials, including carbon
steel, low-carbon steel, galvanized
The selection of the most suitable well steel, and stainless steel (304 and 316)
casing and screen materials should consider
site-specific factors, including: 3) Thermoplastic materials, including
polyvinyl chloride (PVC) and
! Depth to the water-bearing zone(s) to acrylonitrile butadiene styrene (ABS).
be monitored and the anticipated well
depth In addition to these three categories of
materials, fiberglass-reinforced plastic
! Geologic environment (FRP) has been used for monitoring
applications. Because FRP has not yet been
! Geochemistry of soil, unconsolidated used in general application across the
material, and rock over the entire country, very little data are available on its
interval in which the well is to be cased characteristics and performance. All well
construction materials possess
! Geochemistry of the ground water at strength-related characteristics and chemical
the site, as determined through an resistance/chemical interference
initial analysis of samples from both characteristics that influence their
performance in site-specific hydrogeologic
245
Subpart E
and contaminant-related monitoring selecting monitoring well materials.

situations. Metallic casing materials are more subject
to corrosion, while thermoplastic casing
The casing must be made of a material materials are more susceptible to chemical
strong enough to last for the life of the well. degradation. The geochemistry of the
Tensile strength is needed primarily during formation water influences the degree to
well installation when the casing is lowered which these processes occur. If ground-
into the hole. The joint strength will water chemistry affects the structural
determine the maximum length of a section integrity of the casing, then the samples
that can be suspended from the surface in an collected from the well are likely to be
air-filled borehole. affected.
Collapse strength is the capability of a Materials used for monitoring well casing
casing to resist collapse by any external must not exhibit a tendency to sorb or leach
loads to which it is subjected both during chemical constituents from, or into, water
and after installation. A casing is most sampled from the well. If a casing material
susceptible to collapse during installation sorbs constituents from ground water, those
before placement of the filter pack or constituents may either not be detected
annular seal materials around the casing. during monitoring or be detected at a lower
Once a casing is installed and supported, concentration. Chemical constituents also
collapse is seldom a concern. Several steps can be leached from the casing materials by
that can be taken to avoid casing collapse aggressive aqueous solutions. These
are: constituents may be detected in samples
collected from the well. The results may
1) Drilling a straight, clean borehole indicate contamination that is due to the
casing rather than the formation water.
2) Uniformly distributing filter pack Casing materials must be selected with care
materials at a slow, even rate to avoid degradation of the well and to
avoid erroneous results.
3) Avoiding use of quick-setting (high
temperature) cements for thermoplastic In certain situations it may be advantageous
casings installation. to design a well using more than one
material for well components. For example,
Compressive strength of the casing is a where stainless steel or fluoropolymer
measure of the greatest compressive stress materials are preferred in a specific
that a casing can bear without deformation. chemical environment, costs may be saved
Casing failure due to a compressive strength by using PVC in non-critical portions of the
limitation generally is not an important well. These savings may be considerable,
factor in a properly installed well. This type especially in deep wells where only the
of failure results from soil friction on lower portion of the well is in a critical
unsupported casing. chemical environment and where tens of
feet of lower-cost PVC may be used in the
Chemical resistance/interference upper portion of the well. In a composite
characteristics must be evaluated before well design, dissimilar metallic
246
components should not be used unless an threaded joints should be used on

electrically isolating design is incorporated thermoplastic well material.
(i.e., a dielectric coupling) (USEPA, 1986).
Well Casing Diameter
Coupling Procedures for Joining Casing
Although the diameter of the casing for a
Only a limited number of methods are monitoring well depends on the purpose of
available for joining lengths of casing or the well, the casing size is generally selected
casing and screen together. The joining to accommodate downhole equipment.
method depends on the type of casing and Additional casing diameter selection criteria
type of casing joint. include the 1) drilling or well installation
method used, 2) anticipated depth of the
There are generally two options available well and associated strength requirements,
for joining metallic well casings: welding 3) anticipated method of well development,
via application of heat, or threaded joints. 4) volume of water required to be purged
Threaded joints provide inexpensive, fast, prior to sampling, 5) rate of recovery of the
and convenient connections and greatly well after purging, and 6) anticipated
reduce potential problems with chemical aquifer testing.
resistance or interference (due to corrosion)
and explosion potential. Wrapping the male Casing Cleaning Requirements
threads with fluoropolymer tape prior to
Well casing and screen materials should be
joining sections improves the watertightness
cleaned prior to installation to remove any
of the joint. One disadvantage to using
coatings or manufacturing residues. Prior to
threaded joints is that the tensile strength of
use, all casing and screen materials should
the casing string is reduced to
be washed with a mild, non-phosphate,
approximately 70 percent of the casing detergent/potable water solution and rinsed
strength. This reduction in strength does with potable water. Hot pressurized water,
not usually pose a problem because strength such as in steam cleaning, should be used to
requirements for small diameter wells (such remove organic solvents, oils, or lubricants
as typical monitoring wells) are not as from casing and screens composed of
critical and because metallic casing has a materials other than plastic. At sites where
high initial tensile strength. volatile organic contaminants may be
monitored, the cleaning of well casing and
Joints should create a uniform inner and screen materials should include a final rinse
outer casing diameter in monitoring well with deionized water or potable water that
installations. Solvent cementing of has not been chlorinated. Once cleaned,
thermoplastic pipe should never be used in casings and screens should be stored in an
the construction of ground-water monitoring area that is free of potential contaminants.
wells. The cements used in solvent welding, Plastic sheeting can generally be used to
which are organic chemicals, have been cover the ground in the decontamination
shown to adversely affect the integrity of area to provide protection from
ground-water samples for more than 2 years contamination. USEPA (1989f) describes
after well installation; only factory- the procedures
247
Subpart E
that should be used to clean casing and because the owner/operator will need to
screen materials. provide a margin of safety that will
guarantee that at least a portion of the
Well Intake Design screen always contacts the water table
regardless of its seasonal fluctuations. The
The owner/operator should design and owner or operator should not employ well
construct the intakes of monitoring wells to intake designs that cut across hydraulically
(1) accurately sample the aquifer zone that separated geologic units.
the well is intended to sample, (2) minimize
the passage of formation materials Well screen slot size should be selected to
(turbidity) into the well, and (3) ensure retain from 90 percent to 100 percent of the
sufficient structural integrity to prevent the filter pack material (discussed below) in
collapse of the intake structure. The goal of artificially filter packed wells. Well screens
a properly completed monitoring well is to should be factory-slotted. Manual slotting
provide low turbidity water that is of screens in the field should not be
representative of ground-water quality in performed under any circumstances.
the vicinity of the well. Close attention to
proper selection of packing materials and Filter Pack Design
well development procedures for wells
installed in fine-grained formations (e.g., The primary filter pack material should be a
clays and silty glacial tills) is important to chemically inert material and well rounded,
minimize sample turbidity from suspended with a high coefficient of uniformity. The
and colloidal solids. There may be best filter pack materials are made from
instances where wells completed in rock do industrial grade glass (quartz) sand or beads.
not require screens or filter packs; the State The use of other materials, such as local,
regulatory agency should be consulted prior naturally occurring clean sand, is
to completion of unscreened wells. discouraged unless it can be shown that the
material is inert (e.g., low cation exchange
The selection of screen length usually capacity), coarse-grained, permeable, and
depends on the objective of the well. uniform in grain size. The filter pack should
Piezometers and wells where only a discrete extend at least 2 feet above the screened
flow path is monitored (such as thin gravel interval in the well.
interbedded with clays) are generally
completed using short screens (2 feet or Although design techniques for selecting
less). To avoid dilution, the well screens filter pack size vary, all use the filter pack
should be kept to the minimum length ratio to establish size differential between
appropriate for intercepting a contaminant formation materials and filter pack
plume, especially in a high-yielding aquifer. materials. Generally, this ratio refers to
The screen length should generally not either the average (50 percent retained)
exceed 10 feet. If construction of a water grain size of the formation material or to the
table well is the objective, either for 70 percent retained size of the formation
defining gradient or detecting floating material. Barcelona et al. (1985b)
phases, then a longer screen is acceptable recommend using a uniform filter pack
grain size that is three to five times the size
248
of the 50 percent retained size of the operators should remember that the entire
formation material (USEPA, 1990). length of the annular space filled with filter
pack material or sand is effectively the
Filter pack material should be installed in a monitored zone. Moreover, if the filter
manner that prevents bridging and particle- pack/sand extends from the screened zone
size segregation. Filter pack material into an overlying zone, a conduit for
installed below the water table should hydraulic connection is created between the
generally be tremied into the annular space. two zones.
Allowing filter pack material to fall by
gravity (free fall) into the annular space is Annular Sealants
only appropriate when wells are relatively
shallow, when the filter pack has a uniform Proper sealing of the annular space between
grain size, and when the filter pack material the well casing and the borehole wall is
can be poured continuously into the well required to prevent contamination of
without stopping. samples and the ground water. Adequate
sealing will prevent hydraulic connection
At least 2 inches of filter pack material within the well annulus. The materials used
should be installed between the well screen for annular sealants should be chemically
and the borehole wall. The filter pack inert with the highest anticipated
should extend at least 2 feet above the top of concentration of chemical constituents
the well screen. In deep wells, the filter expected in the ground water at the facility.
pack may not compress when initially In general, the permeability of the sealing
installed. Consequently, when the annular material should be one to two orders of
and surface seals are placed on the filter magnitude lower than the least permeable
pack, the filter pack compresses sufficiently part of the formation in contact with the
to allow grout into, or very close to, the well. The precise volume of annular
screen. Consequently, filter packs may need sealants required should be calculated and
to be installed as high as 5 feet above the recorded before placement, and the actual
screened interval in monitoring wells that volume used should be determined and
are deep (i.e., greater than 200 feet). The recorded during well construction. Any
precise volume of filter pack material significant discrepancy between the
required should be calculated and recorded calculated volume and the actual volume
before placement, and the actual volume should be explained.
used should be determined and recorded
during well construction. Any significant When the screened interval is within the
discrepancy between the calculated volume saturated zone, a minimum of 2 feet of
and the actual volume should be explained. sealant material, such as raw (>10 percent
solids) bentonite, should be placed
Prior to installing the annular seal, a 1- to immediately over the protective sand layer
2-foot layer of chemically inert fine sand overlying the filter pack. Granular
may be placed over the filter pack to prevent bentonite, bentonite pellets, and bentonite
the intrusion of annular or surface sealants chips may be placed around the casing by
into the filter pack. When designing means of a tremie pipe in deep wells
monitoring wells, owners and (greater than approximately 30 feet deep),
249
Subpart E
or by dropping them directly down the When the annular sealant must be installed
annulus in shallow wells (less than in the unsaturated zone, neat cement or
approximately 30 feet deep). Dropping the shrinkage-compensated neat cement
bentonite pellets down the annulus presents mixtures should be used for the annular
a potential for bridging (from premature sealant. Bentonite is not recommended as
hydration of the bentonite), leading to gaps an annular sealant in the unsaturated zone
in the seal below the bridge. In shallow because the moisture available is
monitoring wells, a tamping device should insufficient to fully hydrate bentonite.
be used to prevent bridging from occurring.
Surface Completion
A neat cement or shrinkage-compensated
neat cement grout seal should be installed Monitoring wells are commonly either
on top of the bentonite seal and extend above-ground completions or flush-to-
vertically up the annular space between the ground completions. The design of both
well casing and the borehole wall to within types must consider the prevention of
a few feet of land surface. Annular sealants infiltration of surface runoff into the well
in slurry form (e.g., cement grout, bentonite annulus and the possibility of accidental
slurry) should be placed by the tremie/pump damage or vandalism. Completing a
(from the bottom up) method. The bottom monitoring well involves installing the
of the placement pipe should be equipped following components:
with a side discharge deflector to prevent
the slurry from jetting a hole through the ! Surface seal
protective sand layer, filter pack, or
bentonite seal. The bentonite seal should be ! Protective casing
allowed to completely hydrate, set, or cure
in conformance with the manufacturer's ! Ventilation hole
specifications prior to installing the grout
seal in the annular space. The time required ! Drain hole
for the bentonite seal to completely hydrate,
set, or cure will differ with the materials ! Cap and lock
used and the specific conditions
encountered, but is generally a minimum of ! Guard posts when wells are completed
4 to 24 hours. Allowing the bentonite seal above grade.
to hydrate, set, or cure prevents the invasion
of the more viscous and more chemically A surface seal, installed on top of the grout
reactive grout seal into the screened area. seal, extends vertically up the well annulus
to the land surface. To protect against frost
When using bentonite as an annular sealant, heave, the seal should extend at least 1 foot
the appropriate clay should be selected on below the frost line. The composition of the
the basis of the environment in which it is to surface seal should be neat cement or
be used, such as the ion-exchange potential concrete. In an above-ground completion,
of the sediments, sediment permeability, the surface seal should form at least a 2-foot
and compatibility with expected wide, 4-inch thick apron.
contaminants. Sodium bentonite is usually
acceptable.
250
A locking protective casing should be unavoidable, such as in active roadways, a

installed around the well casing to prevent protective structure, such as a utility vault
damage or unauthorized entry. The or meter box, should be installed around the
protective casing should be anchored below well casing. In addition, measures should
the frost line (where applicable) into the be taken to prevent the accumulation of
surface seal and extend at least 18 inches surface water in the protective structure and
above the surface of the ground. A 1/4-inch around the well intake. These measures
vent hole pipe is recommended to allow the should include outfitting the protective
escape of any potentially explosive gases structure with a steel lid or manhole cover
that may accumulate within the well. In that has a rubber seal or gasket and ensuring
addition, a drain hole should be installed in that the bond between the cement surface
the protective casing to prevent water from seal and the protective structure is
accumulating and, in freezing climates, watertight.
freezing around the well casing. The space
between the protective casing and the well Well Surveying
casing may be filled with gravel to allow the
retrieval of tools and to prevent small The location of all wells should be surveyed
animal/insect entrance through the drain. A by a licensed professional surveyor (or
suitable cap should be placed on the well to equivalent) to determine their X-and-Y
prevent tampering or the entry of any coordinates as well as their distances from
foreign materials. A lock should be the units being monitored and their
installed on the cap to provide security. To distances from each other. A State Plane
prevent corrosion or jamming of the lock, a Coordinate System, Universal Transverse
protective cover should be used. Care Mercator System, or Latitude/Longitude
should be taken when using such lubricants should be used, as approved by the Regional
as graphite or petroleum-based sprays to Administrator. The survey should also note
lubricate the lock, as lubricants may the coordinates of any temporary
introduce a potential for sample benchmarks. A surveyed reference mark
contamination. should be placed on the top of the well
casing, not on the protective casing or the
To guard against accidental damage to the well apron, for use as a measuring point
well from facility traffic, the owner/operator because the well casing is more stable than
should install concrete or steel bumper the protective casing or well apron (both the
guards around the edge of the concrete protective casing and the well apron are
apron. These should be located within 3 or more susceptible to frost heave and
4 feet of the well and should be painted spalling). The height of the reference
orange or fitted with reflectors to reduce the survey datum, permanently marked on top
possibility of vehicular damage. of the inner well casing, should be
determined within ±0.01 foot in relation to
The use of flush-to-ground surface mean sea level, which in turn is determined
completions should be avoided because this by reference to an established National
design increases the potential for surface Geodetic Vertical Datum. The reference
water infiltration into the well. In cases marked on top of inner well casings should
where flush-to-ground completions are be resurveyed at least once every 5 years,
251
Subpart E
unless changes in ground-water flow When development is initiated, a wide range

patterns/direction, or damage caused by of grain sizes of the natural material is
freeze/thaw or desiccation processes, are drawn into the well, and the well typically
noted. In such cases, the Regional produces very turbid water. However, as
Administrator may require that well casings development continues and the natural
be resurveyed on a more frequent basis. materials are drawn into the filter pack, an
effective filter will form through a sorting
Well Development process. Inducing movement of ground
water into the well (i.e., in one direction)
All monitoring wells should be developed to generally results in bridging of the particles.
create an effective filter pack around the A means of inducing flow reversal is
well screen, to rectify damage to the necessary to break down bridges and
formation caused by drilling, to remove fine produce a stable filter.
particles from the formation near the
borehole, and to assist in restoring the The commonly accepted methods for
natural water quality of the aquifer in the developing wells are described in USEPA
vicinity of the well. Development stresses (1989f) and Driscoll (1986) and include:
the formation around the screen, as well as
the filter pack, so that mobile fines, silts, ! Pumping and overpumping
and clays are pulled into the well and
removed. The process of developing a well ! Surging with a surge block
creates a graded filter pack around the well
screen. Development is also used to remove ! Bailing.
any foreign materials (drilling water, muds,
etc.) that may have been introduced into the USEPA (1989f) provides a detailed
well borehole during drilling and well overview of well development and should
installation and to aid in the equilibration be consulted when evaluating well
that will occur between the filter pack, well development methods.
casing, and the formation water.
Documentation of Well Design,
The development of a well is extremely Construction, and Development
important to ensuring the collection of
representative ground-water samples. If the Information on the design, construction, and
well has been properly completed, then development of each well should be
adequate development should remove fines compiled. Such information should include
that may enter the well either from the filter (1) a boring log that documents well drilling
pack or the formation. This improves the and associated formation sampling and (2)
yield, but more importantly it creates a a well construction log and well
monitoring well capable of producing construction diagram ("as built").
samples of acceptably low turbidity. Turbid
samples from an improperly constructed and
developed well may interfere with
subsequent analyses.
252
Decommissioning Ground-Water In some States, similar regulations may

Monitoring Wells and Boreholes apply to the decommissioning of monitoring
wells and boreholes. The EPA and other
Ground-water contamination resulting from involved regulatory agencies, as well as
improperly decommissioned wells and experienced geologists, geotechnical
boreholes is a serious concern. Any engineers, and drillers, should be consulted
borehole that will not be completed as a prior to decommissioning a well or borehole
monitoring well should be properly to ensure that decommissioning is
decommissioned. The USEPA (1975) and performed properly and to ensure
the American Water Works Association compliance with State law. If a well to be
(1985) provide the following reasons, decommissioned is contaminated, the safe
summarized by USEPA (1989f), as to why removal and proper disposal of the well
improperly constructed or unused wells materials should be ensured by the
should be properly decommissioned: owner/operator. Appropriate measures
should be taken to protect the health and
! To eliminate physical hazards safety of individuals when decommissioning
a well or borehole.
! To prevent ground-water
contamination
5.8 GROUND-WATER SAMPLING
! To conserve aquifer yield and AND ANALYSIS
hydrostatic head REQUIREMENTS
40 CFR §258.53
! To prevent intermixing of subsurface
water. 5.8.1 Statement of Regulation
Should an owner or operator have a (a) The ground-water monitoring

borehole or an improperly constructed or program must include consistent
unused well at his or her facility, the well or sampling and analysis procedures that
borehole should be decommissioned in are designed to ensure monitoring results
accordance with specific guidelines. that provide an accurate representation
USEPA (1989f) provides comprehensive of ground-water quality at the
guidance on performing well background and downgradient wells
decommissioning that can be applied to installed in compliance with §258.51(a) of
boreholes. In addition, any State/Tribal this Part. The owner or operator must
regulatory guidance should be consulted notify the State Director that the
prior to decommissioning monitoring wells, sampling and analysis program
piezometers, or boreholes. Lamb and documentation has been placed in the
Kinney (1989) also provide information on operating record and the program must
decommissioning ground-water monitoring include procedures and techniques for:
wells.
(1) Sample collection;
Many States require that specific procedures
be followed and certain paperwork be filed (2) Sample preservation and shipment;
when decommissioning water supply wells.
253
Subpart E
(3) Analytical procedures; §258.55(a) of this Part. Background

ground-water quality may be established
(4) Chain of custody control; and at wells that are not located hydraulically
upgradient from the MSWLF unit if it
(5) Quality assurance and quality meets the requirements of §258.51(a)(1).
control.
(f) The number of samples collected to
(b) The ground-water monitoring establish ground-water quality data must
program must include sampling and be consistent with the appropriate
analytical methods that are appropriate statistical procedures determined
for ground-water sampling and that pursuant to paragraph (g) of this section.
accurately measure hazardous The sampling procedures shall be those
constituents and other monitoring specified under §258.54(b) for detection
parameters in ground-water samples. monitoring, §258.55(b) and (d) for
Ground-water samples shall not be field- assessment monitoring, and §258.56(b) of
filtered prior to laboratory analysis. corrective action.
(c) The sampling procedures and 5.8.2 Applicability

frequency must be protective of human
health and the environment. The requirements for sampling and analysis
apply to all facilities required to conduct
(d) Ground-water elevations must be ground-water monitoring throughout the
measured in each well immediately prior active life, closure, and post-closure periods
to purging, each time ground water is of operation. Quality assurance and quality
sampled. The owner or operator must control measures for both field and
determine the rate and direction of laboratory activities must be implemented.
ground-water flow each time ground The methods and procedures constituting
water is sampled. Ground-water the program must be placed in the operating
elevations in wells which monitor the record of the facility.
same waste management area must be
measured within a period of time short For the sampling and analysis program to be
enough to avoid temporal variations in technically sound, the sampling procedures
ground-water flow which could preclude and analytical methods used should provide
accurate determination of ground-water adequate accuracy, precision, and detection
flow rate and direction. limits for the analyte determinations. Prior
to sampling, the static ground-water
(e) The owner or operator must elevations in the wells must be measured to
establish background ground-water allow determination of the direction of
quality in a hydraulically upgradient or ground-water flow and estimates of rate of
background well(s) for each of the flow. The time interval between
monitoring parameters or constituents measurements at different wells must be
required in the particular ground-water minimized so that temporal changes in
monitoring program that applies to the ground-water elevations do not cause an
MSWLF unit, as determined under
§258.54(a), or
254
incorrect determination of ground-water ! Chain of custody control

flow direction.
! Quality assurance and quality control.
Background ground-water quality must be
established at all upgradient or background The ground-water monitoring program must
wells. The background water quality may be documented in the operating record of
be determined from wells that are not the facility.
upgradient of the MSWLF unit, provided
that the wells yield representative ground- The objectives of the monitoring program
water samples. should clearly define the quality of the data
required to detect significant changes in
The sampling program must be designed in ground-water chemistry due to the operation
consideration of the anticipated statistical of the solid waste disposal facility. These
method applied by the owner or operator. data quality objectives should address:
The data objectives of the monitoring
program, in terms of the number of samples ! Accuracy and precision of methods used
collected and the frequency of collection, in the analysis of samples, including
should be appropriate for the statistical field measurements
method selected for data comparison.
! Quality control and quality assurance
5.8.3 Technical Considerations procedures used to ensure the validity of
the results (e.g., use of blank samples,
The purpose of a ground-water sampling record keeping, and data validation)
and analysis program is to establish a
protocol that can be followed throughout the ! Number of samples required to obtain a
monitoring period of the site (operating, certain degree of statistical confidence
closure, and post-closure). The protocol is
necessary so that data acquired can be ! Location and number of monitoring
compared over time and accurately wells required.
represent ground-water quality. Sample
collection, preservation, shipment, storage, Sample Collection
and analyses should always be performed in
a consistent manner, even as monitoring Frequency
staff change during the monitoring period.
The frequency of sample collection under
The owner's/operator's ground-water detection monitoring should be evaluated
monitoring program must include a for each site according to hydrogeologic
description of procedures for the following: conditions and landfill design. In States, the
minimum sampling frequency should be
! Sample collection semiannual. The background
characterization should include four
! Sample preservation and shipment independent samples at each monitoring
location during the first semi-annual event
! Analytical procedures (i.e., during the first 6 months of
255
Subpart E
monitoring). (See the discussion under Measurements of the static water level and
Section 5.10.3 on collecting independent the depth to the well bottom can be made
samples to determine background.) More with a wetted steel tape. Electronic water
frequent sampling may be selected. For level measuring devices may also be used.
example, quarterly sampling may be Accepted standard operating procedures call
conducted to evaluate seasonal effects on for the static water level to be accurately
ground-water quality. measured to within 0.01 foot (USEPA,
1992a). Water level measurements should
The frequency of sample collection during be made at all monitoring wells and well
assessment monitoring activities will clusters in a time frame that avoids changes
depend on site-specific hydrogeologic that may occur as a result of barometric
conditions and contaminant properties. The pressure changes, significant infiltration
frequency of sampling is intended to obtain events, or aquifer pumping. To prevent
a data set that is statistically independent of possible cross contamination of wells, water
the previous set. Guidance to estimate this level measurement devices must be
minimum time to obtain independent decontaminated prior to use at each well.
samples is provided in "Statistical Analysis
of Ground-water Monitoring Data at RCRA The ground-water monitoring program
Facilities - Interim Final Guidance" should include provisions for detecting
(USEPA, 1989). immiscible fluids (i.e., LNAPLs or
DNAPLs). LNAPLs are relatively
Water Level Measurements immiscible liquids that are less dense than
water and that spread across the water table
The ground-water monitoring program must surface. DNAPLs are relatively immiscible
include provisions for measuring static liquids that are more dense than the ground
water level elevations in each well prior to water and tend to migrate vertically
purging the well for sampling. downward in aquifers. The detection of an
Measurements of ground-water elevations immiscible layer may require specialized
are used for determining horizontal and equipment and should be performed before
vertical hydraulic gradients for estimation the well is evacuated for conventional
of flow rates and direction. sampling. The ground-water monitoring
program should specify how DNAPLs and
Field measurements may include the LNAPLs will be detected. The program
following: also should include a contingency plan
describing procedures for sampling and
! Depth to standing water from a surveyed analyzing these liquids. Guidance for
datum on the top of the well riser (static detecting the presence of immiscible layers
water level) can be found in USEPA (1992a).
! Total depth of well from the top of the Well Purging

riser (to verify condition of well)
Because the water standing in a well prior to
! Thickness of immiscible layers, if sampling may not represent in-situ
present. ground-water quality, stagnant water should
256
be purged from the well and filter pack prior ensure that purging does not cause
to sampling. The QAPjP should include formation water to cascade down the sides
detailed, step-by-step procedures for of the well screen. At no time should a well
purging wells, including the parameters that be purged to dryness if recharge causes the
will be monitored during purging and the formation water to cascade down the sides
equipment that will be used for well of the screen, as this will cause an
purging. accelerated loss of volatiles. This problem
should be anticipated; water should be
Purging should be accomplished by purged from the well at a rate that does not
removing ground water from the well at low cause recharge water to be excessively
flow rates using a pump. The use of bailers agitated. Laboratory experiments have
to purge monitoring wells generally should shown that unless cascading is prevented, up
be avoided. Research has shown that the to 70 percent of the volatiles present could
"plunger" effect created by continually be lost before sampling.
raising and lowering the bailer into the well
can result in continual development or To eliminate the need to dispose of large
overdevelopment of the well. Moreover, the volumes of purge water, and to reduce the
velocities at which ground water enters a amount of time required for purging, wells
bailer can actually correspond to may be purged with the pump intake just
unacceptably high purging rates (Puls and above or just within the screened interval.
Powell, 1992; Barcelona et al., 1990). This procedure eliminates the need to purge
the column of stagnant water located above
The rate at which ground water is removed the well screen (Barcelona et al., 1985b;
from the well during purging ideally should Robin and Gillham, 1987; Barcelona,
be approximately 0.2 to 0.3 L/min or less 1985b; Kearl et al., 1992). Purging the well
(Puls and Powell, 1992; Puls et al., 1991; at the top of the well screen should ensure
Puls and Barcelona, 1989a; Barcelona, et that fresh water from the aquifer moves
al., 1990). Wells should be purged at rates through the well screen and upward within
below those used to develop the well to the screened interval. Pumping rates below
prevent further development of the well, to the recharge capability of the aquifer must
prevent damage to the well, and to avoid be maintained if purging is performed with
disturbing accumulated corrosion or the pump placed at the top of the well
reaction products in the well (Kearl et al., screen, below the stagnant water column
1992; Puls et al., 1990; Puls and Barcelona, above the top of the well screen (Kearl et
1989a; Puls and Barcelona, 1989b;
al., 1992). The Agency suggests that a
Barcelona, 1985b). Wells also should be
packer be placed above the screened interval
purged at or below their recovery rate so
to ensure that "stagnant" casing water is not
that migration of water in the formation
drawn into the pump. The packer should be
above the well screen does not occur. A low
kept inflated in the well until after ground-
purge rate also will reduce the possibility of
water samples are collected.
stripping VOCs from the water, and will
reduce the likelihood of mobilizing colloids
in the subsurface that are immobile under In certain situations, purging must be
natural flow conditions. The owner/operator performed with the pump placed at, or
should immediately below, the air/water interface.
257
Subpart E
If a bailer must be used to sample the well, decontaminated prior to use. If the purged
the well should be purged by placing the water or the decontamination water is
pump intake immediately below the contaminated (e.g., based on analytical
air/water interface. This will ensure that all results), the water should be stored in
of the water in the casing and filter pack is appropriate containers until analytical
purged, and it will minimize the possibility results are available, at which time proper
of mixing and/or sampling stagnant water arrangements for disposal or treatment
when the bailer is lowered down into the should be made (i.e., contaminated purge
well and subsequently retrieved (Keeley and water may be a hazardous waste).
Boateng, 1987). Similarly, purging should
be performed at the air/water interface if Field Analyses
sampling is not performed immediately after
the well is purged without removing the Several constituents or parameters that
pump. Pumping at the air/water interface owners or operators may choose to include
will prevent the mixing of stagnant and in a ground-water monitoring program may
fresh water when the pump used to purge be physically or chemically unstable and
the well is removed and then lowered back should be tested after well purging and
down into the well for the purpose of before the collection of samples for
sampling. laboratory analysis. Examples of unstable
parameters include pH, redox (oxidation-
In cases where an LNAPL has been detected reduction) potential, dissolved oxygen,
in the monitoring well, special procedures temperature, and specific conductance.
should be used to purge the well. These
procedures are described in USEPA Field analyses should not be performed on
(1992a). samples designated for laboratory analysis.
Any field monitoring equipment or field-
For most wells, the Agency recommends test kits should be calibrated at the
that purging continue until measurements of beginning of each use, according to the
turbidity, redox potential, and dissolved manufacturers' specifications and consistent
oxygen in in-line or downhole analyses of with methods in SW-846 (USEPA, 1986b).
ground water have stabilized within
approximately 10% over at least two Sample Withdrawal and Collection
measurements (Puls and Powell, 1992; Puls
and Eychaner, 1990; Puls et al., 1990; Puls The equipment used to withdraw a ground-
and Barcelona, 1989a; Puls and Barcelona,
water sample from a well must be selected
1989b; USEPA, 1991; Barcelona et al.,
based on consideration of the parameters to
1988b). If a well is purged to dryness or is
be analyzed in the sample. To ensure the
purged such that full recovery exceeds two
sample is representative of ground water in
hours, the well should be sampled as soon as
the formation, it is important to keep
a sufficient volume of ground water has
physical or chemical alterations of the
entered the well to enable the collection of
sample to a minimum. USEPA (1992a)
the necessary ground-water samples.
provides an overview of the issues involved
All purging equipment that has been or will in selecting ground-water sampling
be in contact with ground water should be equipment, and a summary of the
258
application and limitations of various Bladder pumps are generally recognized as

sampling mechanisms. Sampling materials the best overall sampling device for both
and equipment should be selected to organic and inorganic constituents, although
preserve sample integrity. Sampling other types of pumps (e.g., low-rate
equipment should be constructed of inert submersible centrifugal pumps, helical rotor
material. Sample collection equipment electric submersible pumps) have been
should not alter analyte concentrations, found suitable in some applications.
cause loss of analytes via sorption, or cause Bailers, although inexpensive and simple to
gain of analytes via desorption, degradation, use, have been found to cause volatilization
or corrosion. Sampling equipment should of samples, mobilization of particulates in
be designed such that Viton®, Tygon®, wells and imprecise results (USEPA,
silicone, or neoprene components do not 1992a).
come into contact with the ground-water
sample. These materials have been The following recommendations apply to
demonstrated to cause sorptive losses of the use and operation of ground-water
contaminants (Barcelona et al., 1983; sampling equipment:
Barcelona et al., 1985b; Barcelona et al.,
1988b; Barcelona et al., 1990). Barcelona ! Check valves should be designed and
(1988b) suggests that sorption of volatile inspected to ensure that fouling
organic compounds on silicone, problems do not reduce delivery
polyethylene, and PVC tubing may result in capabilities or result in aeration of
gross errors when determining samples.
concentrations of trace organics in ground-
water samples. Barcelona (1985b) ! Sampling equipment should never be
discourages the use of PVC sampling dropped into the well, as this will
equipment when sampling for organic cause degassing of the water upon
contaminants. Fluorocarbon resin (e.g., impact.
Teflon®) or stainless steel sampling devices
which can be easily disassembled for ! Contents of the sampling device should
thorough decontamination are widely used. be transferred to sample containers in
Dedicating sampling equipment to each a controlled manner that will minimize
monitoring well will help prevent cross- sample agitation and aeration.
contamination problems that could arise
from improper decontamination procedures. ! Decontaminated sampling equipment
should not be allowed to come into
Sampling equipment should cause minimal contact with the ground or other
sample agitation and should be selected to contaminated surfaces prior to
reduce/eliminate sample contact with the insertion into the well.
atmosphere during sample transfer.
Sampling equipment should not allow ! Ground-water samples should be
volatilization or aeration of samples to the collected as soon as possible after the
extent that analyte concentrations are well is purged. Water that has
altered. remained in the well casing for more
than about 2 hours has had the
259
Subpart E
opportunity to exchange gases with the Once appropriate sampling equipment has
atmosphere and to interact with the been selected and operating procedures
well casing material (USEPA, 1991b). established, samples should be collected and
containerized in the order of the
! The rate at which a well is sampled volatilization sensitivity of the parameter.
should not exceed the rate at which the The preferred collection order for some of
well was purged. Low sampling rates, the more common ground-water analytes is
approximately 0.1 L/min, are depicted on the flow chart shown in Figure
suggested. Low sampling rates will 5-4.
help to ensure that particulates,
immobile in the subsurface under The ground-water monitoring program
ambient conditions, are not entrained documentation should include explicit
in the sample and that volatile procedures for disassembly and
compounds are not stripped from the decontamination of sampling equipment
sample (Puls and Barcelona, 1989b; before each use. Improperly
Barcelona, et al., 1990; Puls et al., decontaminated equipment can affect
1991; Kearl et al., 1992; USEPA, samples in several ways. For example,
1991b). Pumps should be operated at residual contamination from the previous
rates less than 0.1 L/min when well may remain on equipment, or improper
collecting samples for volatile organics decontamination may not remove all of the
analysis. detergents or solvents used during
decontamination. Specific guidance
! Pump lines should be cleared at a rate regarding decontamination of the sampling
of 0.1 L/min or less before collecting equipment is available (USEPA 1992a). To
samples for volatiles analysis so that keep sample cross-contamination to a
the samples collected will not be from minimum, sampling should proceed from
the period of time when the pump was upgradient or background locations to
operating more rapidly. downgradient locations that would contain
higher concentrations of contaminants.
! Pumps should be operated in a
continuous manner so that they do not Sample Preservation and Handling
produce samples that are aerated in the
return tube or upon discharge. The procedures for preserving and handling
samples are nearly as important for ensuring
! When sampling wells that contain the integrity of the samples as the collection
LNAPLs, a stilling tube should be device itself. Detailed procedures for
inserted in the well. Ground-water sample preservation must be provided in the
samples should be collected from the Quality Assurance Project Plan (QAPjP)
screened interval of the well below the that is included in the sampling and analysis
base of the tube. program description.
! Ground-water samples collected for

analysis for organic constituents or
parameters should not be filtered in the
field.
260
Figure 5-4
Generalized Flow Diagram of
Ground-Water Sampling Steps
261
Subpart E
Sample Containers maintains sample quality. Samples should

be cooled to 4EC as soon as possible after
To avoid altering sample quality, the they are collected. These conditions should
samples should be transferred from the be maintained until the samples are received
sampling equipment directly into a prepared at the laboratory. Sample containers
container. Proper sample containers for generally are packed in picnic coolers or
each constituent or group of constituents are special containers for shipment.
identified in SW-846 (USEPA, 1986b).
Samples should never be composited in a Polystyrene foam, vermiculite, and "bubble
common container in the field and then pack" are frequently used to pack sample
split. Sample containers should be cleaned containers to prevent breakage. Ice is
in a manner that is appropriate for the placed in sealed plastic bags and added to
constituents to be analyzed. Cleaning the cooler. All related paperwork is sealed
procedures are provided by USEPA in a plastic bag and taped to the inside top of
(1986b). Sample containers that have been the cooler. The cooler top is then taped
cleaned according to these procedures can shut. Custody seals should be placed across
be procured commercially. the hinges and latches on the outside of the
cooler.
Most vendors will provide a certification of
cleanliness. Transportation arrangements should
maintain proper storage conditions and
Sample Preservation provide for effective sample pickup and
delivery to the laboratory. Sampling plans
During ground-water sampling, every should be coordinated with the laboratory so
attempt should be made to minimize that appropriate sample receipt, storage,
changes in the chemistry of the samples. To analysis, and custody arrangements can be
assist in maintaining the natural chemistry provided.
of the samples, it is necessary to preserve
the sample. The owner or operator should Most analyses must be performed within a
refer to SW-846 (USEPA, 1986b) for the specified period (holding time) from sample
specific preservation method and holding collection. Holding time refers to the period
times for each constituent to be analyzed. that begins when the sample is collected
Methods of sample preservation are from the well and ends with its extraction or
relatively limited and are intended to retard analysis. Data from samples not analyzed
chemical reactions, such as oxidation, within the recommended holding times
retard, biodegradation, and to reduce the should be considered suspect. Some
effects of sorption. Preservation methods holding times for Appendix I constituents
are generally limited to pH control, are as short as 7 days. To provide the
refrigeration, and protection from light. laboratory with operational flexibility in
meeting these holding times, samples
Sample Storage and Shipment usually are shipped via overnight courier.
Laboratory capacity or operating hours may
The storage and transport of ground-water influence sampling schedules. Coordination
samples must be performed in a manner that with laboratory staff during
262
planning and sampling activities is ! Internal temperature of shipping

important in maintaining sample and container when samples were sealed into
analysis quality. the container for shipping
The documentation that accompanies ! Internal temperature of container when

samples during shipment to the laboratory opened at the laboratory
usually includes chain-of-custody (including
a listing of all sample containers), requested ! Any remarks regarding potential hazards
analyses, and full identification of the origin or other information the laboratory may
of samples (including contact names, phone need.
numbers, and addresses). Copies of all
documents shipped with the samples should An adequate chain-of-custody program
be retained by the sampler. allows for tracing the possession and
handling of individual samples from the
Chain-of-Custody Record time of collection through completion of
laboratory analysis. A chain-of-custody
To document sample possession from the program should include:
time of collection, a chain-of-custody record
should be filled out to accompany every ! Sample labels to prevent
sample shipment. The record should misidentification of samples
contain the following types of information:
! Sample custody seals to preserve the
! Sample number integrity of the samples from the time
they are collected until they are opened
! Signature of collector in the laboratory
! Date and time of collection ! Field notes to record information about

each sample collected during the ground-
! Media sampled (e.g., ground water) water monitoring program
! Sample type (e.g., grab) ! Chain-of-custody record to document

sample possession from the time of
! Identification of sampling location/well collection to analysis
! Number of containers ! Laboratory storage and analysis records,

which are maintained at the laboratory
! Parameters requested for analysis and which record pertinent information
about the sample.
! Signatures of persons involved in the
chain of possession Sample Labels
! Inclusive dates of possession with time Each sample's identification should be

in 24-hour notation marked clearly in waterproof ink on the
sample container. To aid in labeling, the
263
Subpart E
information should be written on each ! Well depth

container prior to filling with a sample. The
labels should be sufficiently durable to ! Static water level depth and
remain legible even when wet and should measurement technique
contain the following information:
! Presence and thickness of immiscible
! Sample identification number layers and the detection method
! Name and signature of the sampler ! Well yield (high or low) and well
recovery after purging (slow, fast)
! Date and time of collection
! Well purging procedure and equipment
! Sample location
! Purge volume and pumping rate
! Analyses requested.
! Time well purged
Sample Custody Seal
! Collection method for immiscible
Sample custody seals should be placed on layers
the shipping container and/or individual
sample bottle in a manner that will break the ! Sample withdrawal procedure and
seal if the container or sample is tampered equipment
with.
! Date and time of sample collection
Field Logbook
! Results of field analysis
To provide an account of all activities
involved in sample collection, all sampling ! Well sampling sequence
activities, measurements, and observations
should be noted in a field log. The ! Types of sample bottles used and
information should include visual sample identification numbers
appearance (e.g., color, turbidity, degassing,
surface film), odor (type, strength), and ! Preservatives used
field measurements and calibration results.
Ambient conditions (temperature, humidity, ! Parameters requested for analysis
wind, precipitation) and well purging and
sampling activities should also be recorded ! Field observations of sampling event
as an aid in evaluating sample analysis
results. ! Name of collector
The field logbook should document the ! Weather conditions, including air
following: temperature
! Well identification
264
! Internal temperature of field and ground-water samples analyzed. The

shipping containers. laboratory logbook should include the time,
date, and name of the person who performed
Sample Analysis Request Sheet each processing step.
A sample analysis request sheet should Analytical Procedures

accompany the sample(s) to the laboratory
and clearly identify which sample The requirements of 40 CFR Part 258
containers have been designated for each include detection and assessment
requested parameter and the preservation monitoring activities. Under detection
methods used. The record should include monitoring, the constituents listed in 40
the following types of information: CFR Part 258, Appendix I are to be
analyzed for. This list includes volatile
! Name of person receiving the sample organic compounds (VOCs) and selected
inorganic constituents. No specific
! Laboratory sample number (if different analytical methods are cited in the
from field number) regulations, but there is a requirement (40
CFR §258.53(h)(5)) that any practical
! Date of sample receipt quantitation limit (PQL) used in subsequent
statistical analysis "be the lowest
! Analyses to be performed (including concentration level that can be reliably
desired analytical method) achieved within specified limits of precision
and accuracy during routine laboratory
! Information that may be useful to the operating conditions that are available to the
laboratory (e.g., type and quantity of facility." Suggested test methods are listed
preservatives added, unusual conditions). in Appendix II of Part 258 for informational
purposes only. Method 8240 (gas
Laboratory Records chromatography with packed column; mass
spectrometry) and Method 8260 (gas
chromatography with capillary column;
Once the sample has been received in the
mass spectrometry) are typical methods
laboratory, the sample custodian and/or
used for all Appendix I VOCs. The
laboratory personnel should clearly
inorganic analyses can be performed using
document the processing steps that are
inductively coupled plasma atomic emission
applied to the sample. All sample
spectroscopy (ICP) Method 6010. These
preparation (e.g., extraction) and
methods, as well as other methods
determinative steps should be identified in
appropriate to these analyses, are presented
the laboratory records. Deviations from
in Tests Methods for Evaluating Solid
established methods or standard operating
Waste, Physical/Chemical Methods,
procedures (SOPs), such as the use of
SW-846 (USEPA, 1986), and are routinely
specific reagents (e.g., solvents, acids),
performed by numerous analytical testing
temperatures, reaction times, and instrument
laboratories. These methods typically
settings, should be noted. The results of the
provide PQLs in the 1 to 50 µg/L range.
analyses of all quality control samples
The ground-water monitoring plan must
should be identified for each batch of
specify the analytical method to be used.
265
Subpart E
Evaluation and documentation of analytical laboratory of choice is exercising an

performance requires that quality control appropriate QA/QC program.
samples be collected and analyzed along
with the ground-water monitoring samples. The owner or operator should provide for
Chapter One of SW-846 (Quality the use of standards, laboratory blanks,
Assurance) describes the types of quality duplicates, and spiked samples for
control samples necessary, as well as the calibration and identification of potential
frequency at which they must be collected matrix interferences, especially for metal
and analyzed. In general, these quality determinants. Refer to Chapter One of
control samples may include trip blanks, SW-846 for guidance. The owner or
equipment rinsate samples, field duplicates, operator should use adequate statistical
method blanks, matrix spikes and procedures (e.g., QC charts) to monitor and
duplicates, and laboratory control samples. document performance and to implement an
effective program to resolve testing
Other mechanisms, including sample problems (e.g., instrument maintenance,
holding times, surrogate constituents, and operator training). Data from QC samples
standard additions, are also used to control (e.g., blanks, spiked samples) should be
and document data quality. The used as a measure of performance or as an
specification of and adherence to sample indicator of potential sources of cross-
holding times minimizes the sample contamination, but should not be used by
degradation that occurs over time. the laboratory to alter or correct analytical
Evaluating the recovery of surrogate data. All laboratory QC data should be
constituents spiked into organic samples submitted with the ground-water monitoring
allows the analyst and data user to monitor sample results.
the efficiency of sample extraction and
analysis. The method of standard additions Field Quality Assurance/Quality Control
is used to eliminate the effects of matrix
interferences in inorganic analyses. To verify the precision of field sampling
procedures, field QC samples, such as trip
Quality Assurance/Quality Control blanks, equipment blanks, and duplicates,
should be collected. Additional volumes of
One of the fundamental responsibilities of sample also should be collected for
the owner or operator is to establish a laboratory QC samples.
continuing program to ensure the reliability
and validity of field and analytical All field QC samples should be prepared
laboratory data gathered as part of the exactly as regular investigation samples
overall ground-water monitoring program. with regard to sample volume, containers,
The owner or operator must explicitly and preservation. The concentrations of any
describe the QA/QC program that will be contaminants found in blank samples should
used in the laboratory. Most owners or not be used to correct the ground-water
operators will use commercial laboratories data. The contaminant concentrations in
to conduct analyses of ground-water blanks should be documented, and if the
samples. In these cases, the owner or concentrations are more than an order of
operator is responsible for ensuring that the magnitude greater than the field sample
266
results, the owner/operator should resample Equipment rinsate samples are used to
the ground water. The owner/operator assess the efficacy of sampling equipment
should prepare the QC samples as decontamination procedures. The data
recommended in Chapter One of SW-846 validation process uses the results from all
and at the frequency recommended by of these QC samples to determine if the
Chapter One of SW-846 and should analyze reported analytical data accurately describe
them for all of the required monitoring the samples. All reported data must be
parameters. Other QA/QC practices, such evaluated -- a reported value of "non-detect"
as sampling equipment calibration, is a quantitative report just like a numerical
equipment decontamination procedures, and value and must be validated.
chain-of-custody procedures, are discussed
in other sections of this chapter and should The data validation process must also
be described in the owner/operator's QAPjP. consider the presence and quality of other
kinds of data used to ensure data quality
Validation (e.g., calibration frequency and descriptors,
matrix specific detection limits). All of the
The analytical data report provided by the criteria for data quality are described in the
laboratory will present all data measured by quality assurance project plan (QAPjP) or
the laboratory but will not adjust those data sampling and analysis plan (SAP). These
for field or laboratory quality control documents may reference criteria from some
indicators. This means that just because other source, (e.g., the USEPA Contract
data have been reported, they are not Laboratory Program). The performance
necessarily an accurate representation of the criteria must be correctly specified and must
quality of the ground water. For example, be used for data validation. It is a waste of
acetone and methylene chloride are often time and money to evaluate data against
used in laboratories as cleaning and standards other than those used to generate
extraction solvents and, consequently, are them. Several documents are available to
often laboratory contaminants, transmitted assist the reviewer in validation of data by
through the ambient air into samples. different criteria (i.e., Chapter One of Test
Method blanks are analyzed to evaluate the Methods for Evaluating Solid Waste,
extent of laboratory contamination. Physical/Chemical Methods, USEPA CLP
Constituents found as contaminants in the Functional Guidelines for Evaluating
method blanks are "flagged" in the sample Organics Analyses, USEPA CLP Functional
data. The sample data are not, however, Guidelines for Evaluating Pesticides/PCBs
adjusted for the contaminant concentration. Analyses, etc.).
Other kinds of samples are analyzed to In addition to specific data that describe
assess other data quality indicators. Trip data quality, the validator may consider
blanks are used to assess contamination by other information that may have an impact
volatile organic constituents during sample on the end-use of the data, such as
shipment and storage. Matrix spike/matrix background concentrations of the
spike duplicate sample pairs are used to constituent in the environment. In any
evaluate analytical bias and precision. event, the QAPjP or SAP also should
describe the validation procedures that will
be used. The result of
267
Subpart E
this validation should be the classification ! Statistical methods to be used to evaluate

of data as acceptable or unacceptable for the ground-water monitoring data and
purposes of the project. In some cases, data demonstrate compliance with the
may be further qualified, based either on performance standard;
insufficient data or marginal performance
(i.e., qualitative uses only, estimated ! Approved demonstration that monitoring
concentration, etc.). requirements are suspended (if
applicable);
Documentation
! Boring logs;
The ground-water monitoring program
required by §258.50 through §258.55 relies ! Piezometer and well construction logs
on documentation to demonstrate for the ground-water monitoring system.
compliance. The operating record of the
MSWLF should include a complete
description of the program as well as 5.9 STATISTICAL ANALYSIS
periodic implementation reports. 40 CFR §258.53 (g)-(i)
At a minimum, the following aspects of the 5.9.1 Statement of Regulation

ground-water monitoring program should be
described or included in the operating (g) The owner or operator must specify
record: in the operating record one of the
following statistical methods to be used in
! The Sampling and Analysis plan that evaluating ground-water monitoring data
details sample parameters, sampling for each hazardous constituent. The
frequency, sample collection, statistical test chosen shall be conducted
preservation, and analytical methods to separately for each hazardous constituent
be used, shipping procedures, and chain- in each well.
of-custody procedures;
(1) A parametric analysis of variance
! The Quality Assurance Project Plan (ANOVA) followed by multiple
(QAPjP) and Data Quality Objectives comparisons procedures to identify
(DQOs); statistically significant evidence of
contamination. The method must include
! The locations of monitoring wells; estimation and testing of the contrasts
between each compliance well's mean and
! The design, installation, development, the background mean levels for each
and decommission of monitoring wells, constituent.
piezometers, and other measurement,
sampling, and analytical devices; (2) An analysis of variance (ANOVA)
based on ranks followed by multiple
! Site hydrogeology; comparisons procedures to identify
statistically significant evidence of
contamination. The method must include
268
estimation and testing of the contrasts (2) If an individual well comparison

between each compliance well's median procedure is used to compare an
and the background median levels for individual compliance well constituent
each constituent. concentration with background
constituent concentrations or a ground-
(3) A tolerance or prediction interval water protection standard, the test shall
procedure in which an interval for each be done at a Type I error level of no less
constituent is established from the than 0.01 for each testing period. If a
distribution of the background data, and multiple comparisons procedure is used,
the level of each constituent in each the Type I experiment wise error rate for
compliance well is compared to the upper each testing period shall be no less than
tolerance or prediction limit. 0.05; however, the Type I error of no less
than 0.01 for individual well comparisons
(4) A control chart approach that gives must be maintained. This performance
control limits for each constituent. standard does not apply to tolerance
intervals, prediction intervals, or control
(5) Another statistical test method that charts.
meets the performance standards of
§258.53(h). The owner or operator must (3) If a control chart approach is used to
place a justification for this alternative in evaluate ground-water monitoring data,
the operating record and notify the State the specific type of control chart and its
Director of the use of this alternative test. associated parameter values shall be
The justification must demonstrate that protective of human health and the
the alternative method meets the environment. The parameters shall be
performance standards of §258.53(h). determined after considering the number
of samples in the background data base,
(h) Any statistical method chosen under the data distribution, and the range of the
§258.53(g) shall comply with the concentration values for each constituent
following performance standards, as of concern.
appropriate:
(4) If a tolerance interval or a
(1) The statistical method used to predictional interval is used to evaluate
evaluate ground-water monitoring data ground-water monitoring data, the levels
shall be appropriate for the distribution of confidence and, for tolerance intervals,
of chemical parameters or hazardous the percentage of the population that the
constituents. If the distribution of the interval must contain, shall be protective
chemical parameters or hazardous of human health and the environment.
constituents is shown by the owner or These parameters shall be determined
operator to be inappropriate for a normal after considering the number of samples
theory test, then the data should be in the background data base, the data
transformed or a distribution-free theory distribution, and the range of the
test should be used. If the distributions concentration values for each constituent
for the constituents differ, more than one of concern.
statistical method may be needed.
269
Subpart E
(5) The statistical method shall account significant increase over background at
for data below the limit of detection with each monitoring well.
one or more statistical procedures that
are protective of human health and the 5.9.2 Applicability
environment. Any practical quantitation
limit (PQL) that is used in the statistical The statistical analysis requirements are
method shall be the lowest concentration applicable to all existing units, new units,
level that can be reliably achieved within and lateral expansions of existing units for
specified limits of precision and accuracy which ground-water monitoring is required.
during routine laboratory operating The use of statistical procedures to evaluate
conditions that are available to the monitoring data shall be used for the
facility. duration of the monitoring program,
including the post-closure care period.
(6) If necessary, the statistical method
shall include procedures to control or The owner or operator must indicate in the
correct for seasonal and spatial operating record the statistical method that
variability as well as temporal correlation will be used in the analysis of ground-water
in the data. monitoring results. The data objectives of
the monitoring, in terms of the number of
(i) The owner or operator must samples collected and the frequency of
determine whether or not there is a collection, must be consistent with the
statistically significant increase over statistical method selected.
background values for each parameter or
constituent required in the particular Several options for analysis of ground-water
ground-water monitoring program that data are provided in the criteria. Other
applies to the MSWLF unit, as methods may be used if they can be shown
determined under §§258.54(a) or to meet the performance standards. The
258.55(a) of this part. approved methods include both parametric
and nonparametric procedures, which differ
(1) In determining whether a primarily in constraints placed by the
statistically significant increase has statistical distribution of the data. Control
occurred, the owner or operator must chart, tolerance interval, and prediction
compare the ground-water quality of interval approaches also may be applied.
each parameter or constituent at each
monitoring well designated pursuant to
The owner or operator must conduct the
§258.51(a)(2) to the background value of
statistical comparisons between upgradient
that constituent, according to the
and downgradient wells after completion of
statistical procedures and performance
each sampling event and receipt of validated
standards specified under paragraphs (g)
data. The statistical procedure must
and (h) of this section.
conform to the performance standard of a
Type I error level of no less than 0.01 for
(2) Within a reasonable period of time
inter-well comparisons. Control chart,
after completing sampling and analysis,
tolerance interval, and prediction interval
the owner or operator must determine
approaches must incorporate decision values
whether there has been a statistically
270
that are protective of human health and the useful for selecting other methods (Dixon
environment. Generally, this is meant to and Massey, 1969; Gibbons, 1976;
include a significance level of a least 0.05. Aitchison and Brown, 1969; and Gilbert,
Procedures to treat data below analytical 1987). The statistical methods that may be
method detection levels and seasonality used in evaluating ground-water monitoring
effects must be part of the statistical data include the following:
analysis.
! Parametric analysis of variance
5.9.3 Technical Considerations (ANOVA) with multiple comparisons
The MSWLF rule requires facilities to ! Rank-based (nonparametric) ANOVA

evaluate ground-water monitoring data with multiple comparisons
using a statistical method provided in
§258.53(g) that meets the performance ! Tolerance interval or prediction interval
standard of §258.53(h). Section 258.53(g)
contains a provision allowing for the use of ! Control chart
an alternative statistical method as long as
the performance standards of §258.53(h) are ! An alternative statistical method (e.g.,
met. CABF t-test or confidence intervals).
The requirements of §258.53(g) specify that If an alternative method is used, then the
one of five possible statistical methods be State Director must be notified, and a
used for evaluating ground-water justification for its use must be placed in the
monitoring data. One method should be operating record.
specified for each constituent. Although
different methods may be selected for each The statistical analysis methods chosen must
constituent at new facilities, use of a method meet performance standards specified under
must be substantiated by demonstrating that §258.53(h), which include the following:
the distribution of data obtained on that
constituent is appropriate for that method
1) The method must be appropriate for the
(§258.53(h)). Selection of a specific
observed distribution of the data
method is described in Statistical Analysis
of Ground-Water Monitoring Data at RCRA
2) Individual well comparisons to
Facilities - Interim Final Guidance"
(USEPA, 1989) and in Statistical Analysis background ground-water quality or a
of Ground-Water Monitoring Data at RCRA ground-water protection standard shall
Facilities - Addendum to Interim Final be done at a Type I error level of no less
Guidance (USEPA, 1992b). EPA also than 0.01 or, if the multiple comparisons
offers software, entitled User procedure is used, the experiment-wise
Documentation of the Ground-Water error rate for each testing period shall be
Information Tracking System (GRITS) with no less than 0.05
Statistical Analysis Capability, GRITSTAT
Version 4.2. In addition to the statistical 3) If a control chart is used, the type of
guidance provided by EPA, the following chart and associated parameter values
references may be
271
Subpart E
shall be protective of human health and Multiple Well Comparisons

the environment
If more than two wells (background and
4) The level of confidence and percentage downgradient combined) are screened in the
of the population contained in an interval same stratigraphic unit, then the appropriate
shall be protective of human health and statistical comparison method is a multiple
the environment well comparison using the ANOVA
procedure. The parametric ANOVA
5) The method must account for data below procedure assumes that the data from each
the limit of detection (less than the PQL) well group come from the same type (e.g.,
in a manner that is protective of human Normal) of distribution with possibly
health and the environment different mean concentrations. The
ANOVA tests for a difference in means. If
6) The method must account for seasonal there are multiple background wells, one
and spatial variability and temporal should consider the possibility of trying to
correlation of the data, if necessary. pool these background data into one group.
Such an increase in sample size often allows
These statistical analysis methods shall be for more accurate statistical comparisons,
used to determine whether a significant primarily because better information is
increase over background values has known about the background concentrations
occurred. Monitoring data must be as a whole. Downgradient wells should not
statistically analyzed after validated results be pooled, as stated in the regulations.
from each sampling and analysis event are Ground-water monitoring data tend to
received. follow a log normal distribution (USEPA,
1989), and usually need to be transformed
The statistical performance standards prior to applying a parametric ANOVA
provide a means to limit the possibility of procedure. By conducting a log
making false conclusions from the transformation, ground-water monitoring
monitoring data. The specified error level data will generally be converted to a normal
of 0.01 for individual well comparisons for distribution. By applying a Shapiro-Wilk
probability of Type I error (indication of test, probability plots, or other normality
contamination when it is not present or false tests on the residuals (errors) from the
positive) essentially means that the analysis ANOVA procedure, the normality of the
is predicting with 99-percent confidence transformed data can be determined. In
that no significant increase in contaminant addition, data variance for each well in the
levels is evident when in fact no increase is comparison must be approximately
present. Non-detect results must be treated equivalent; this condition can be checked
in an appropriate manner or their influence using Levene's or Bartlett's test. These tests
on the statistical method may invalidate the are provided in USEPA (1992b) and
statistical conclusion. Non-detect results USEPA (1989).
are discussed in greater detail later in this
section. If the transformed data do not conform to
the normality assumption, a nonparametric
ANOVA procedure may be used. The
272
nonparametric statistical procedures do not designed to contain a designated proportion

depend as much on the mathematical of the population (e.g., 95 percent of all
properties of a specified distribution. The possible sample measurements). Because
nonparametric equivalent to the parametric the interval is constructed from sample data,
ANOVA is the Kruskal-Wallis test, which it also is a random interval. And because of
analyzes variability of the average ranks of sampling fluctuations, a tolerance interval
the data instead of the measurements can contain the specified proportion of the
themselves. population only with a certain confidence
level.
If the data display seasonality (regular,
periodic, and time-dependent increases or Tolerance intervals are very useful for
decreases in parameter values), a two-way ground-water data analysis because in many
ANOVA procedure should be used. If the situations one wants to ensure that at most a
seasonality can be corrected, a one-way small fraction of the compliance well
ANOVA procedure may still be appropriate. sample measurements exceed a specific
Methods to treat seasonality are described in concentration level (chosen to be protective
USEPA (1989). of human health and the environment).
ANOVA procedures attempt to determine Prediction intervals are constructed to

whether different wells have significantly contain the next sample value(s) from a
different average concentrations of population or distribution with a specified
constituents. If a difference is indicated, the probability. That is, after sampling a
ANOVA test is followed by a multiple background well for some time and
comparisons procedure to investigate which measuring the concentration of an analyte,
specific wells are different among those the data can be used to construct an interval
tested. The overall experiment-wise that will contain the next analyte sample or
significance level of the ANOVA must be samples (assuming the distribution has not
kept to a minimum of 0.05, while the changed). Therefore, a prediction interval
minimum significance level of each will contain a future value or values with
individual comparison must be set at 0.01. specified probability. Prediction intervals
USEPA (1992b) provides alternative can also be constructed to contain the
methods that can be used when the number average of several future observations.
of individual contrasts to be tested is very
high. In summary, a tolerance interval contains a
proportion of the population, and a
Tolerance and Prediction Intervals prediction interval contains one or more
future observations. Each has a probability
Two types of statistical intervals are often statement or "confidence coefficient"
constructed from data: tolerance intervals associated with it. It should be noted that
and prediction intervals. A comprehensive these intervals assume that the sample data
discussion of these intervals is provided in used to construct the intervals are normally
USEPA 1992b. Though often confused, the distributed.
interpretations and uses of these intervals
are quite distinct. A tolerance interval is
273
Subpart E
Individual Well Comparisons monitoring data. Such data may be adjusted

for seasonal effects to aid in assessing the
When only two wells (e.g., a single degree of change over time. Guidance for
background and a single compliance point and limitations of intra-well comparison
well) are being compared, owners or techniques are provided in USEPA (1989)
operators should not perform the parametric and USEPA (1992b).
or nonparametric ANOVA. Instead, a
parametric t-test, such as Cochran's Treatment of Non-Detects
Approximation to the Behrens-Fisher
Students' t-test, or a nonparametric test The treatment of data below the detection
should be performed. When a single limit of the analytical method (non-detects)
compliance well group is being compared to used depends on the number or percentage
background data and a nonparametric test is of non-detects and the statistical method
needed, the Wilcoxin Rank-Sum test should employed. Guidance on how to treat non-
be performed. These tests are discussed in detects is provided in USEPA (1992b).
more detail in standard statistical references
and in USEPA (1992b). 5.10 DETECTION MONITORING
PROGRAM
Intra-Well Comparisons 40 CFR §258.54
Intra-well comparisons, where data of one 5.10.1 Statement of Regulation

well are evaluated over time, are useful in
evaluating trends in individual wells and for (a) Detection monitoring is required at
identifying seasonal effects in the data. The MSWLF units at all ground-water
intra-well comparison methods do not monitoring wells defined under
compare background data to compliance §§258.51(a)(1) and (a)(2) of this part. At
data. Where some existing facilities may a minimum, a detection monitoring
not have valid background data, however, program must include the monitoring for
intra-well comparisons may represent the the constituents listed in Appendix I of
only valid comparison available. In the this part.
absence of a true background well, several
monitoring events may be required to 1) The Director of an approved State
determine trends and seasonal fluctuations may delete any of the Appendix I
in ground-water quality. monitoring parameters for a MSWLF
unit if it can be shown that the
Control charts may be used for intra-well removed constituents are not
comparisons but are only appropriate for reasonably expected to be in or
uncontaminated wells. If a well is derived from the waste contained in
intercepting a release, then it is already in the unit.
an "out-of-control" state, which violates the
principal assumption underlying control 2) The Director of an approved State
chart procedures. Time series analysis (i.e., may establish an alternative list of
plotting concentrations over time) is inorganic indicator parameters for a
extremely useful for identifying trends in MSWLF unit, in lieu of some or all of
274
the heavy metals (constituents 1-15 in must be collected and analyzed during
Appendix I), if the alternative subsequent semiannual sampling events.
parameters provide a reliable The Director of an approved State may
indication of inorganic releases from specify an appropriate alternative
the MSWLF unit to the ground water. frequency for repeated sampling and
In determining alternative analysis for Appendix I constituents, or
parameters, the Director shall the alternative list approved in
consider the following factors: accordance with paragraph (a)(2), during
the active life (including closure) and the
(i) The types, quantities, and post-closure care period. The alternative
concentrations of constituents in frequency during the active life
wastes managed at the MSWLF unit; (including closure) shall be no less than
annual. The alternative frequency shall
(ii) The mobility, stability, and be based on consideration of the following
persistence of waste constituents or factors:
their reaction products in the
unsaturated zone beneath the 1) Lithology of the aquifer and
MSWLF unit; unsaturated zone;
(iii) The detectability of indicator 2) Hydraulic conductivity of the aquifer

parameters, waste constituents, and and unsaturated zone;
reaction products in the ground
water; and 3) Ground-water flow rates;
(iv) The concentration or values and 4) Minimum distance between

coefficients of variation of upgradient edge of the MSWLF unit
and downgradient monitoring well
monitoring parameters or
screen (minimum distance of travel);
constituents in the background
and
ground-water.
5) Resource value of the aquifer.
(b) The monitoring frequency for all
constituents listed in Appendix I, or the (c) If the owner or operator determines,
alternative list approved in accordance pursuant to §258.53(g) of this part, that
with paragraph (a)(2), shall be at least there is a statistically significant increase
semiannual during the active life of the over background for one or more of the
facility (including closure) and the post- constituents listed in Appendix I or the
closure period. A minimum of four alternative list approved in accordance
independent samples from each well with paragraph (a)(2), at any monitoring
(background and downgradient) must be well at the boundary specified under
collected and analyzed for the Appendix §258.51(a)(2), the owner or operator:
I constituents, or the alternative list
approved in accordance with paragraph (1) Must, within 14 days of this finding,
(a)(2), during the first semiannual place a notice in the operating record
sampling event. At least one sample from indicating which constituents have shown
each well(background and downgradient) statistically significant changes from
275
Subpart E
background levels, and notify the State list has been established by the Director of
Director that this notice was placed in the an approved State.
operating record; and
During the first semiannual monitoring
(2) Must establish an assessment event, the owner or operator must collect at
monitoring program meeting the least four independent ground-water
requirements of §258.55 of this part samples from each well and analyze the
within 90 days, except as provided for in samples for all constituents in the Appendix
paragraph (3) below. I or alternative list. Each subsequent
semiannual event must include, at a
(3) The owner/operator may minimum, the collection and analysis of one
demonstrate that a source other than a sample from all wells. The monitoring
MSWLF unit caused the contamination requirement continues throughout the active
or that the statistically significant life of the landfill and the post-closure care
increase resulted from error in sampling, period.
analysis, statistical evaluation, or natural
variation in ground-water quality. A If an owner or operator determines that a
report documenting this demonstration statistically significant increase over
must be certified by a qualified ground- background has occurred for one or more
water scientist or approved by the Appendix I constituents (or constituents on
Director of an approved State and be an alternative list), a notice must be placed
placed in the operating record. If a in the facility operating record (see Table 5-
successful demonstration is made and 2). The owner or operator must notify the
documented, the owner or operator may State Director within 14 days of the finding.
continue detection monitoring as Within 90 days, the owner or operator must
specified in this section. If after 90 days, establish an assessment monitoring program
a successful demonstration is not made, conforming to the requirements of §258.55.
the owner or operator must initiate an
assessment monitoring program as If evidence exists that a statistically
required in §258.55. significant increase is due to factors
unrelated to the unit, the owner or operator
5.10.2 Applicability may make a demonstration to this effect to
the Director of an approved State or place a
Except for the small landfill exemption and certified demonstration in the operating
the no migration demonstration, detection record. The potential reasons for an
monitoring is required at existing MSWLF apparent statistical increase may include:
units, lateral expansions of units, and new
MSWLF units. Monitoring must occur at ! A contaminant source other than the
least semiannually at both background wells landfill unit
and downgradient well locations. The
Director of an approved State may specify ! A natural variation in ground-water
an alternative sampling frequency. quality
Monitoring parameters must include all
Appendix I constituents unless an ! An analytical error
alternative
276
! A statistical error Independent Sampling for Background
! A sampling error. The ground-water monitoring requirements

specify that four independent samples be
The demonstration that one of these reasons collected from each well to establish
is responsible for the statistically significant background during the first semiannual
increase over background must be certified monitoring event. This is because almost all
by a qualified ground-water scientist or statistical procedures are based on the
approved by the Director of an approved assumption that samples are independent of
State. If a successful demonstration is made each other. In other words, independent
and documented, the owner or operator may samples more accurately reflect the true
continue detection monitoring. range of natural variability in the ground
water, and statistical analyses based on
If a successful demonstration is not made independent samples are more accurate.
within 90 days, the owner or operator must Replicate samples, whether field replicates
initiate an assessment monitoring program. or lab splits, are not statistically
A flow chart for a detection monitoring independent measurements.
program in a State whose program has not
been approved by EPA is provided in Figure It may be necessary to gather the
5-5. independent samples over a range of time
sufficient to account for seasonal
5.10.3 Technical Considerations differences. If seasonal differences are not
taken into account, the chance for false
If there is a statistically significant increase positives increases (monitoring results
over background during detection indicate a release, when a release has not
monitoring for one or more constituents occurred). The sampling interval chosen
listed in Appendix I of Part 258 (or an must ensure that sampling is being done on
alternative list of parameters in an approved different volumes of ground water. To
State), the owner or operator is required to determine the appropriate interval between
begin assessment monitoring. The sample collection events that will ensure
requirement to conduct assessment independence, the owner or operator can
monitoring will not change, even if the determine the site's effective porosity,
Director of an approved State allows the hydraulic conductivity, and hydraulic
monitoring of geochemical parameters in gradient and use this information to
lieu of some or all of the metals listed in calculate ground-water velocity (USEPA,
Appendix I. If an owner or operator 1989). Knowing the velocity of the ground
suspects that a statistically significant water should enable an owner/operator to
increase in a geochemical parameter is establish an interval that ensures the four
caused by natural variation in ground-water samples are being collected from four
quality or a source other than a MSWLF different volumes of water. For additional
unit, a demonstration to this effect must be information on establishing sampling
documented in a report to avoid proceeding interval, see Statistical Analysis of
to assessment monitoring. Groundwater Monitoring Data at RCRA
277
Figure 5-5. Detection Monitoring Program
278
Facilities - Interim Final Guidance, constituents from Appendix I may be

(USEPA, 1989). acceptable. Usually, a waste would have to
be homogeneous to allow for this kind of
Alternative List/Removal of Parameters determination. The owner or operator may
submit a demonstration that documents the
An alternative list of Appendix I presence or absence of certain constituents
constituents may be allowed by the Director in the waste. The owner or operator also
of an approved State. The alternative list would have to demonstrate that constituents
may use geochemical parameters, such as proposed for deletion from Appendix I are
pH and specific conductance, in place of not degradation or reaction products of
some or all of the metals (Parameters 1 constituents potentially present in the waste.
through 15) in Appendix I. These
alternative parameters must provide a Alternative Frequency
reliable indication of inorganic releases
from the MSWLF unit to ground water. The In approved States, 40 CFR §258.54(b)
option of establishing an alternative list allows the Director to specify an alternative
applies only to Parameters 1 through 15 of frequency for ground-water monitoring.
Appendix I. The list of ground-water The alternative frequency is applicable
monitoring parameters must include all of during the active life, including the closure
the volatile organic compounds (Appendix and the post-closure periods. The
I, Parameters 16 through 62). alternative frequency can be no less than
annual.
A potential problem in substituting
geochemical parameters for metals on the The need to vary monitoring frequency must
alternative list is that many of the be evaluated on a site-specific basis. For
geochemical parameters are naturally example, for MSWLF units located in areas
occurring. However, these parameters have with low ground-water flow rates, it may be
been used to indicate releases from MSWLF acceptable to monitor ground water less
units. Using alternative geochemical frequently. The sampling frequency chosen
parameters is reasonable in cases where must be sufficient to protect human health
natural background levels are not high and the environment. Depending on the
enough to mask the detection of a release ground-water flow rate and the resource
from a MSWLF unit. The decision to use value of the aquifer, less frequent
alternative parameters also should consider monitoring may be allowable or more
natural spatial and temporal variability in frequent monitoring may be necessary. An
the geochemical parameters. approved State may specify an alternative
frequency for repeated sampling and
The types, quantities, and concentrations of analysis of Appendix I constituents based on
wastes managed at the MSWLF unit play an the following factors:
important role in determining whether
removal of parameters from Appendix I is 1) Lithology of the aquifer and the
appropriate. If an owner or operator has unsaturated zone
definite knowledge of the nature of wastes
accepted at the facility, then removal of
279
Subpart E
2) Hydraulic conductivity of the aquifer 2) A comprehensive audit of sampling,

and the unsaturated zone laboratory, and data evaluation
procedures
3) Ground-water flow rates
3) Resampling and analysis to verify the
4) Minimum distance between the presence and concentration of the
upgradient edge of the MSWLF unit and constituents for which the increase was
the downgradient well screen reported.
5) The resource value of the aquifer. A demonstration that the increase in

constituent concentration is the result of a
Approved States also can set alternative source other than the MSWLF unit should
document that:
frequencies for monitoring during the post-
closure care period based on the same
! An alternative source exists.
factors.
! Hydraulic connection exists between the
Notification alternative source and the well with the
significant increase.
The notification requirement under 40 CFR
§258.54(c) requires an owner or operator to ! Constituent(s) (or precursor constituents)
1) place a notice in the operating record that are present at the alternative source or
indicates which constituents have shown along the flow path from the alternative
statistically significant increases and 2) source prior to possible release from the
notify the State Director that the notice was MSWLF unit.
placed in the operating record. The
constituents can be from either Appendix I ! The relative concentration and
or from an alternative list. distribution of constituents in the zone of
contamination are more strongly linked
Demonstrations of Other Reasons to the alternative source than to the
For Statistical Increase MSWLF unit when the fate and transport
characteristics of the constituents are
An owner or operator is allowed 90 days to considered.
demonstrate that the statistically significant
increase of a contaminant/constituent was ! The concentration observed in ground
caused by statistical, sampling, or analytical water could not have resulted from the
errors or by a source other than the landfill MSWLF unit given the waste
constituents and concentrations in the
unit. The demonstration allowed in
MSWLF unit leachate and wastes, and
§258.54(c)(3) may include:
site hydrogeologic conditions.
1) A demonstration that the increase ! The data supporting conclusions
resulted from another contaminant regarding the alternative source are
source historically consistent with
hydrogeologic
280
conditions and findings of the 5.11 ASSESSMENT MONITORING

monitoring program. PROGRAM
40 CFR §258.55(a)-(f)
The demonstration must be documented,
certified by a qualified ground-water 5.11.1 Statement of Regulation
scientist, and placed in the operating record
of the facility. (a) Assessment monitoring is required
whenever a statistically significant
Demonstrations of Other Sources of increase over background has been
Error detected for one or more of the
constituents listed in Appendix I or in the
A successful demonstration that the alternate list approved in accordance
statistically significant change is the result with § 258.54(a)(2).
of an error in sampling, analysis, or data
evaluation may include the following: (b) Within 90 days of triggering an
assessment monitoring program, and
! Clear indication of a transcription or annually thereafter, the owner or
calculation error operator must sample and analyze the
ground water for all constituents
! Clear indication of a systematic error in identified in Appendix II of this part. A
analysis or data reduction minimum of one sample from each
downgradient well must be collected and
! Resampling, analysis, and evaluation of analyzed during each sampling event.
results For any new constituent detected in the
downgradient wells as a result of the
! Corrective measures to prevent the complete Appendix II analysis, a
recurrence of the error and incorporation minimum of four independent samples
of these measures into the ground-water from each well (background and
monitoring program. downgradient) must be collected and
analyzed to establish background for the
If resampling is necessary, the sample(s) new constituents. The Director of an
taken must be independent of the previous approved State may specify an
sample. More than one sample may be appropriate subset of wells to be sampled
required to substantiate the contention that and analyzed for Appendix II
the original sample was not representative constituents during assessment
of the ground-water quality in the affected monitoring. The Director of an approved
well(s). State may delete any of the Appendix II
monitoring parameters for a MSWLF
unit if it can be shown that the removed
constituents are not reasonably expected
to be contained in or derived from the
waste contained in the unit.
281
Subpart E
(c) The Director of an approved State I to this Part or in the alternative list
may specify an appropriate alternate approved in accordance with
frequency for repeated sampling and §258.54(a)(2), and for those constituents
analysis for the full set of Appendix II in Appendix II that are detected in
constituents required by §258.55(b) of response to paragraph (b) of this section,
this part, during the active life (including and record their concentrations in the
closure) and post-closure care of the unit facility operating record. At least one
considering the following factors: sample from each well (background and
downgradient) must be collected and
(1) Lithology of the aquifer and analyzed during these sampling events.
unsaturated zone; The Director of an approved State may
specify an alternative monitoring
(2) Hydraulic conductivity of the frequency during the active life
aquifer and unsaturated zone; (including closure) and the post closure
period for the constituents referred to in
(3) Ground-water flow rates; this paragraph. The alternative
frequency for Appendix I constituents or
(4) Minimum distance between the alternate list approved in accordance
upgradient edge of the MSWLF unit and with §258.54(a)(2) during the active life
downgradient monitoring well screen (including closure) shall be no less than
(minimum distance of travel); annual. The alternative frequency shall
be based on consideration of the factors
(5) Resource value of the aquifer; and specified in paragraph (c) of this section;
(6) Nature (fate and transport) of any (3) Establish background concentrations
constituents detected in response to this for any constituents detected pursuant to
section. paragraphs (b) or (d)(2) of this section;
and
(d) After obtaining the results from the
initial or subsequent sampling events (4) Establish ground-water protection
required in paragraph (b) of this section, standards for all constituents detected
the owner or operator must: pursuant to paragraph (b) or (d)(2) of
this section. The ground-water
(1) Within 14 days, place a notice in the protection standards shall be established
operating record identifying the in accordance with paragraphs (h) or (i)
Appendix II constituents that have been of this section.
detected and notify the State Director
that this notice has been placed in the (e) If the concentrations of all Appendix
operating record; II constituents are shown to be at or
below background values, using the
(2) Within 90 days, and on at least a statistical procedures in §258.53(g), for
semiannual basis thereafter, resample all two consecutive sampling events, the
wells specified by § 258.51(a), conduct owner or operator must notify the State
analyses for all constituents in Appendix
282
Director of this finding and may return to may specify an appropriate subset of wells
detection monitoring. to be included in the assessment monitoring
program. The Director of an approved State
(f) If the concentrations of any also may specify an alternative frequency
Appendix II constituents are above for repeated sampling and analysis of
background values, but all concentrations Appendix II constituents. This frequency
are below the ground-water protection may be decreased or increased based upon
standard established under paragraphs consideration of the factors in
(h) or (i) of this section, using the §258.55(c)(1)-(6). These options for
statistical procedures in §258.53(g), the assessment monitoring programs are
owner or operator must continue available only with the approval of the
assessment monitoring in accordance Director of an approved State.
with this section.
Within 14 days of receiving the results of
5.11.2 Applicability the initial sampling for Appendix II
constituents under assessment monitoring,
Assessment monitoring is required at all the owner or operator must place the results
existing units, lateral expansions, and new in the operating record and notify the State
facilities whenever any of the constituents Director that this notice has been placed in
listed in Appendix I are detected at a the operating record.
concentration that is a statistically
significant increase over background values. Within 90 days of receiving these initial
Figure 5-6 presents a flow chart pertaining results, the owner or operator must resample
to applicability requirements. all wells for all Appendix I and detected
Appendix II constituents. This combined
Within 90 days of beginning assessment list of constituents must be sampled at least
monitoring, the owner or operator must semiannually thereafter, and the list must be
resample all downgradient wells and updated annually to include any newly
analyze the samples for all Appendix II detected Appendix II constituents.
constituents. If any new constituents are
identified in this process, four independent Within the 90-day period, the owner or
samples must be collected from all operator must establish background values
upgradient and downgradient wells and and ground-water protection standards
analyzed for those new constituents to (GWPSs) for all Appendix II constituents
establish background concentrations. The detected. The requirements for determining
complete list of Appendix II constituents GWPSs are provided in §258.55(h). If the
must be monitored in each well annually for concentrations of all Appendix II
the duration of the assessment monitoring constituents are at or below the background
program. In an approved State, the Director values after two independent, consecutive
may reduce the number of Appendix II sampling events, the owner or operator may
constituents to be analyzed if it can be return to detection monitoring after
reasonably shown that those constituents are notification has been made to the State
not present in or derived from the wastes. Director. If, after these two
The Director of an approved State
283
Figure 5-6
ASSESSMENT MONITORING
284
sampling events, any detected Appendix II the owner or operator must collect at least
constituent is statistically above background one sample from each downgradient well
but below the GWPSs, the assessment and analyze the samples for the Appendix II
monitoring program must be continued. parameters. If a downgradient well has
detectable quantities of a new Appendix II
5.11.3 Technical Considerations constituent, four independent samples must
be collected from all background and
The purpose of assessment monitoring is to downgradient wells to establish background
evaluate the nature and extent of for the new constituent(s). The date, well
contamination. The assessment monitoring locations, parameters detected, and their
program is phased. The first phase assesses concentrations must be documented in the
the presence of additional assessment operating record of the facility, and the
monitoring constituents (Appendix II or a State Director must be notified within 14
revised list designated by an approved State) days of the initial detection of Appendix II
in all downgradient wells or in a subset of parameters. On a semiannual basis
ground-water monitoring wells specified by thereafter, both background and
the Director of an approved State. If downgradient wells must be sampled for all
concentrations of all Appendix II Appendix II constituents.
constituents are at or below background
values using the statistical procedures in Alternative List
§258.53(g) for two consecutive sampling
periods, then the owner or operator can In an approved State, the Director may
return to detection monitoring. delete Appendix II parameters that the
owner or operator can demonstrate would
Following notification of a statistically not be anticipated at the facility. A
significant increase of any Appendix I demonstration would be based on a
constituent above background, the owner or characterization of the wastes contained in
operator has 90 days to develop and the unit and an assessment of the leachate
implement the assessment monitoring constituents. Additional information on the
program. Implementation of the program alternative list can be found in Section
involves sampling downgradient monitoring 5.10.3.
wells for ground water passing the relevant
point of compliance for the unit (i.e., the Alternative Frequency
waste management unit boundary or
alternative boundary specified by the The Director of an approved State may
Director of an approved State). specify an alternate sampling frequency for
Downgradient wells are identified in the entire Appendix II list for both the
§258.51(a)(2). Initiation of assessment active and post-closure periods of the
monitoring does not stop the detection facility. The decision to change the
monitoring program. Section 258.55(d)(2) monitoring frequency must consider:
specifies that analyses must continue for all
Appendix I constituents on at least a 1) Lithology of the aquifer and unsaturated
semiannual basis. Within the 90-day period, zone;
285
Subpart E
2) Hydraulic conductivity of the aquifer 5.12 ASSESSMENT MONITORING

and unsaturated zone; PROGRAM
40 CFR §258.55(g)
3) Ground-water flow rates;
4) Minimum distance of travel (between the
MSWLF unit edge to downgradient (g) If one or more Appendix II
monitoring wells); and constituents are detected at statistically
significant levels above the ground-water
5) Nature (fate and transport) of the protection standard established under
detected constituents. paragraphs (h) or (i) of this section in any
sampling event, the owner or operator
The Director of an approved State also may must, within 14 days of this finding, place
allow an alternate frequency, other than a notice in the operating record
semiannual, for the monitoring of Appendix identifying the Appendix II constituents
I and detected Appendix II constituents. that have exceeded the ground-water
protection standard and, notify the State
The monitoring frequency must be Director and all appropriate local
sufficient to allow detection of ground- government officials that the notice has
water contamination. If contamination is been placed in the operating record. The
detected early, the volume of ground water owner or operator also:
contaminated will be smaller and the
required remedial response will be less (1) (i) Must characterize the nature and
burdensome. Additional information on the extent of the release by installing
alternate frequency can be found in Section additional monitoring wells as necessary;
5.10.3.
(ii) Must install at least one additional
In an approved State, the Director may monitoring well at the facility boundary
specify a subset of wells that can be in the direction of contaminant migration
monitored for Appendix II constituents to and sample this well in accordance with
confirm a release and track the plume of §258.55(d)(2);
contamination during assessment
monitoring. The owner or operator should (iii) Must notify all persons who own
work closely with the State in developing a the land or reside on the land that
monitoring plan that targets the specific directly overlies any part of the plume of
areas of concern, if possible. This may contamination if contaminants have
represent a substantial cost savings, migrated off-site if indicated by sampling
especially at large facilities for which only of wells in accordance with §258.55(g)(i);
a very small percentage of wells showed and
exceedances above background. The use of
a subset of wells likely will be feasible only (iv) Must initiate an assessment of
in cases where the direction and rate of flow corrective measures as required by
are relatively constant. §255.56 of this part within 90 days; or
286
(2) May demonstrate that a source installing and sampling an appropriate

other than a MSWLF unit caused the number of additional monitoring wells
contamination, or that the statistically
significant increase resulted from error in 2) Install at least one additional
sampling, analysis, statistical evaluation, downgradient well at the facility
or natural variation in ground-water property boundary in the direction of
quality. A report documenting this migration of the contaminant plume and
demonstration must be certified by a sample that well for all Appendix II
qualified ground-water scientist or compounds initially and thereafter, in
approved by the Director of an approved conformance with the assessment
State and placed in the operating record. monitoring program
If a successful demonstration is made the
owner or operator must continue 3) Notify all property owners whose land
monitoring in accordance with the overlies the suspected plume, if the
assessment monitoring program pursuant sampling of any property boundary
to §258.55, and may return to detection well(s) indicates that contaminants have
monitoring if the Appendix II migrated offsite
constituents are below background as
specified in §258.55(e). Until a successful 4) Initiate an assessment of corrective
demonstration is made, the owner or measures, as required by §258.56, within
operator must comply with §258.55(g) 90 days.
including initiating an assessment of
corrective measures. In assessment monitoring, the owner or
operator may demonstrate that a source
5.12.2 Applicability other than the MSWLF unit caused the
contamination or that the statistically
This requirement applies to facilities in significant increase was the result of an
assessment monitoring and is applicable error in sampling, analysis, statistical
during the active life, closure, and post- evaluation, or natural variation in ground-
closure care periods. water quality. The demonstration must be
certified by a qualified ground-water
5.12.3 Technical Considerations scientist or approved by the Director of an
approved State. Until a successful
If an Appendix II constituent(s) exceeds a demonstration is made, the owner or
GWPS in any sampling event, the owner or operator must comply with §258.55(g) and
operator must notify the State Director initiate assessment of corrective measures.
within 14 days and place a notice of these If the demonstration is successful, the owner
findings in the operating record of the or operator must return to assessment
MSWLF facility. In addition, the owner or monitoring and may return to the detection
operator must: program provided that all Appendix II
constituents are at or below background for
1) Characterize the lateral and vertical two consecutive sampling periods.
extent of the release or plume by
287
Subpart E
Release Investigation semiannually or at an alternative frequency

determined by the Director of an approved
If the GWPS is exceeded, a series of actions State. The initial sample must be analyzed
must be taken. These actions are described for all Appendix II constituents.
in the next several paragraphs. The owner
or operator must investigate the extent of Notification of Adjoining Residents and
the release by installing additional Property Owners
monitoring wells and obtaining additional
ground-water samples. The investigation If ground-water monitoring indicates that
should identify plume geometry, both contamination has migrated offsite, the
laterally and vertically. Prior to such field owner or operator must notify property
activities, records of site operation and owners or residents whose land surface
maintenance activities should be reviewed overlies any part of the contaminant release.
to identify possible release locations within Although the requirement does not describe
the landfill and whether such releases are the contents of the notice, it is expected that
expected to be transient (e.g., one time the notice could include the following
release due to repaired liner) or long-term. items:
Due to the presence of dissolved ionic
constituents, such as iron, magnesium, ! Date of detected release
calcium, sodium, potassium, chloride,
sulfate, and carbonate, typically associated ! Chemical composition of release
with MSWLF unit leachates, geophysical
techniques, including resistivity and terrain ! Reference to the constituent(s), reported
conductivity, may be useful in defining the concentration(s), and the GWPS
plume. Characterizing the nature of the
release should include a description of the ! Representatives of the MSWLF facility
rate and direction of contaminant migration with whom to discuss the finding,
and the chemical and physical including their telephone numbers
characteristics of the contaminants.
! Plans and schedules for future activities
Property Boundary Monitoring Well
! Interim recommendations or remedies to
At least one monitoring well must be protect human health and the
installed at the facility boundary in the environment.
direction of contaminant migration.
Additional wells may be required to Demonstrations of Other Sources of
delineate the plume. Monitoring wells at Error
the facility boundary should be screened to
monitor all stratigraphic units that could be The owner or operator may demonstrate that
preferential pathways for contaminant the source of contamination was not the
migration in the uppermost aquifer. In MSWLF unit. This demonstration is
some cases, this may require installation of discussed in Section 5.10.3.
nested wells or individual wells screened at
several discrete intervals. The well installed
at the facility boundary must be sampled
288
Return to Detection Monitoring (3) For constituents for which the

background level is higher than the MCL
A facility conducting assessment monitoring identified under subparagraph (1) above
may return to detection monitoring if the or health based levels identified under
concentrations of all Appendix II §258.55(i)(1), the background
constituents are at or below background concentration.
levels for two consecutive sampling periods
using the statistical procedures in (i) The Director of an approved State
§258.53(g). The requirement that may establish an alternative ground-
background concentrations must be water protection standard for
maintained for two consecutive sampling constituents for which MCLs have not
events will reduce the possibility that the been established. These ground-water
owner or operator will fail to detect protection standards shall be appropriate
contamination or an increase in a health based levels that satisfy the
concentration of a hazardous constituent following criteria:
when one actually exists. The Director of
an approved State can establish an (1) The level is derived in a manner
alternative time period (§258.54(b). consistent with Agency guidelines for
assessing the health risks of
environmental pollutants (51 FR 33992,
5.13 ASSESSMENT MONITORING 34006, 34014, 34028);
PROGRAM
40 CFR §258.55(h)-(j) (2) The level is based on scientifically
valid studies conducted in accordance
5.13.1 Statement of Regulation with the Toxic Substances Control Act
Good Laboratory Practice Standards (40
(h) The owner or operator must CFR Part 792) or equivalent;
establish a ground-water protection
standard for each Appendix II (3) For carcinogens, the level represents
constituent detected in the ground water. a concentration associated with an excess
The ground-water protection standard lifetime cancer risk level (due to
shall be: continuous lifetime exposure) with the 1
x 10-4 to 1 x 10 -6 range; and
(1) For constituents for which a
maximum contaminant level (MCL) has (4) For systemic toxicants, the level
been promulgated under Section 1412 of represents a concentration to which the
the Safe Drinking Water Act (codified) human population (including sensitive
under 40 CFR Part 141, the MCL for that subgroups) could be exposed to on a daily
constituent; basis that is likely to be without
appreciable risk of deleterious effects
(2) For constituents for which MCLs during a lifetime. For purposes of this
have not been promulgated, the subpart, systemic toxicants include toxic
background concentration for the chemicals that cause effects other than
constituent established from wells in cancer or mutation.
accordance with §258.51(a)(1); or
289
Subpart E
(j) In establishing ground-water 5.13.3 Technical Considerations

protection standards under paragraph
(i), the Director of an approved State may For each Appendix II constituent detected,
consider the following: a GWPS must be established. The GWPS is
to be set at either the MCL or background.
(1) Multiple contaminants in the ground Where the background concentration is
water; higher than the MCL, then the GWPS is
established at background.
(2) Exposure threats to sensitive
environmental receptors; and Directors of approved States have the option
of establishing an alternative GWPS for
(3) Other site-specific exposure or constituents without MCLs. This alternative
potential exposure to ground water. GWPS must be an appropriate health-based
level, based on specific criteria. These
5.13.2 Applicability levels must:
The criteria for establishing GWPSs are ! Be consistent with EPA health risk
applicable to all facilities conducting assessment guidelines
assessment monitoring where any Appendix
II constituents have been detected. The ! Be based on scientifically valid studies
owner or operator must establish a GWPS
for each Appendix II constituent detected. ! Be within a risk range of 1x10-4 to 1x10 -6
for carcinogens
If the constituent has a promulgated
maximum contaminant level (MCL), then ! For systemic toxicants (causing effects
the GWPS is the MCL. If no MCL has been other than cancer or mutations), be a
published for a given Appendix II concentration to which the human
constituent, the background concentration of population could be exposed on a daily
the constituent becomes the GWPS. In basis without appreciable risk of
cases where the background concentration is deleterious effects during a lifetime.
higher than a promulgated MCL, the GWPS
is set at the background level. The health-based GWPS may be established
considering the presence of more than one
In approved States, the Director may constituent, exposure to sensitive
establish an alternative GWPS for environmental receptors, and other site-
constituents for which MCLs have not been specific exposure to ground water. Risk
established. Any alternative GWPS must be assessments to establish the GWPS must
health-based levels that satisfy the criteria in consider cumulative effects of multiple
§258.55(i). The Director may also consider pathways to receptors and cumulative
any of the criteria identified in §258.55(j). effects on exposure risk of multiple
In cases where the background contaminants. Guidance and procedures for
concentration is higher than the health- establishing a health-based risk assessment
based levels, the GWPS is set at the may be found in Guidance on Remedial
background level. Actions for
290
Contaminated Groundwater at Superfund (3) The costs of remedy implementation;

Sites, (USEPA, 1988). and
(4) The institutional requirements such

5.14 ASSESSMENT OF as State or local permit requirements or
CORRECTIVE MEASURES other environmental or public health
40 CFR §258.56 requirements that may substantially
affect implementation of the remedy(s).
(d) The owner or operator must discuss
(a) Within 90 days of finding that any of the results of the corrective measures
the constituents listed in Appendix II assessment, prior to the selection of
have been detected at a statistically remedy, in a public meeting with
significant level exceeding the ground- interested and affected parties.
water protection standards defined under
§258.55(h) and (i) of this part, the owner 5.14.2 Applicability
or operator must initiate an assessment of
corrective measures. Such an assessment An assessment of corrective measures must
must be completed within a reasonable be conducted whenever any Appendix II
period of time. constituents are detected at statistically
significant levels exceeding the GWPS. The
(b) The owner or operator must assessment of corrective measures must be
continue to monitor in accordance with initiated within 90 days of the finding.
the assessment monitoring program as During the initiation of an assessment of
specified in §258.55. corrective measures, assessment monitoring
must be continued. The assessment of
(c) The assessment shall include an corrective measures must consider
analysis of the effectiveness of potential performance (including potential impacts),
corrective measures in meeting all of the time, and cost aspects of the remedies. If
requirements and objectives of the implementation requires additional State or
remedy as described under §258.57, local permits, such requirements should be
addressing at least the following: identified. Finally, the results of the
corrective measures assessment must be
(1) The performance, reliability, ease of discussed in a public meeting with
implementation, and potential impacts of interested and affected parties.
appropriate potential remedies, including
safety impacts, cross-media impacts, and 5.14.3 Technical Considerations
control of exposure to any residual
contamination; An assessment of corrective measures is
site-specific and will vary significantly
(2) The time required to begin and depending on the design and age of the
complete the remedy; facility, the completeness of the facility's
historical records, the nature and
concentration of the contaminants found in
291
Subpart E
the ground water, the complexity of the site (e.g., unlined leachate storage ponds, failed
hydrogeology, and the facility's proximity cover system, leaky leachate transport pipes,
to sensitive receptors. Corrective measures past conditions of contaminated storm
are generally approached from two overflow), such information should be
directions: 1) identify and remediate the considered as part of the assessment of
source of contamination and 2) identify and corrective measures.
remediate the known contamination.
Because each case will be site-specific, the Existing site geology and hydrogeology
owner or operator should be prepared to information, ground-water monitoring
document that, to the best of his or her results, and topographic and cultural
technical and financial abilities, a diligent information must be documented clearly and
effort has been made to complete the accurately. This information may include
assessment in the shortest time practicable. soil boring logs, test pit and monitoring well
logs, geophysical data, water level elevation
The factors listed in §258.56(c)(1) must be data, and other information collected during
considered in assessing corrective measures. facility design or operation. The
These general factors are discussed below in information should be expressed in a
terms of source evaluation, plume manner that will aid interpretation of data.
delineation, ground-water assessment, and Such data may include isopach maps of the
corrective measures assessment. thickness of the upper aquifer and important
strata, isoconcentration maps of
Source Evaluation contaminants, flow nets, cross-sections, and
contour maps. Additional guidance on data
As part of the assessment of corrective interpretation that may be useful in a source
measures, the owner or operator will need to evaluation is presented in RCRA Facility
identify the nature of the source of the Investigation Guidance: Volume I -
release. The first step in this identification Development of an RFI Work Plan and
is a review of all available site information General Considerations for RCRA Facility
regarding facility design, wastes received, Investigations, (USEPA 1989a), RCRA
and onsite management practices. For Facility Investigation Guidance: Volume IV
newer facilities, this may be a relatively - Case Study Examples, (USEPA 1989d),
simple task. However, at some older and Practical Guide For Assessing and
facilities, detailed records of the facility's Remediating Contaminated Sites (USEPA
history may not be as well documented, 1989e).
making source definition more difficult.
Design, climatological, and waste-type Plume Delineation
information should be used to evaluate the
duration of the release, potential seasonal To effectively assess corrective measures,
effects due to precipitation (increased the lateral and vertical extent of
infiltration and leachate generation), and contamination must be known. When it is
possible constituent concentrations. If determined that a GWPS is exceeded during
source evaluation is able to identify a the assessment monitoring program, it may
repairable engineering condition that likely be necessary to install additional wells to
contributed to the cause of contamination characterize the contaminant plume(s). At
292
least one additional well must be added at and effective porosity) should be developed
the property boundary in the direction of for modeling contaminant transport if
contaminant migration to allow timely sufficient data are not available. Anisotropy
notification to potentially affected parties if and heterogeneity of the aquifer must be
contamination migrates offsite. evaluated, as well as magnitude and
duration of source inputs, to help explain
The following circumstances may require present and predicted plume configuration.
additional monitoring wells:
Currently, most treatment options for
! Facilities that have not determined the ground-water contamination at MSWLF
horizontal and vertical extent of the units involve pump and treat or in-situ
contaminant plume biological technologies (bio-remediation).
The cost and duration of treatment depends
! Locations where the subsurface is on the size of the plume, the pumping
heterogeneous or where ground-water characteristics of the aquifer, and the
flow patterns are difficult to establish chemical transport phenomena. Source
control and ground-water flow control
! Mounding associated with MSWLF measures to reduce the rate of contaminant
units. migration should be included in the costs of
any remedial activity undertaken. Ground-
Because the requirements for additional water modeling of the plume may be
monitoring are site-specific, the regulation initiated to establish the following:
does not specifically establish cases where
additional wells are necessary or establish ! The locations and pumping rates of
the number of additional wells that must be withdrawal and/or injection wells
installed.
! Predictions of contaminant
During the plume delineation process, the concentrations at exposure points
owner or operator is not relieved from
continuing the assessment monitoring ! Locations of additional monitoring wells
program.
! The effect that source control options
The rate of plume migration and the change may have on ground-water remediation
in contaminant concentrations with time
must be monitored to allow prediction of the ! The effects of advection and dispersion,
extent and timing of impact to sensitive retardation, adsorption, and other
receptors. The receptors may include users attenuation processes on the plume
of both ground-water and surface water dimensions and contaminant
bodies where contaminated ground water concentrations.
may be discharged. In some cases, transfer
of volatile compounds from ground water to Any modeling effort must consider that
the soil and to the air may provide an simulations of remedial response measures
additional migration pathway. Information and contaminant transport are based on
regarding the aquifer characteristics (e.g., many necessary simplifying assumptions,
hydraulic conductivity, storage coefficients,
293
Subpart E
which affect the accuracy of the model. ! Stratigraphy and hydraulic properties of
These assumptions include boundary the aquifer
conditions, the degree and spatial variability
of anisotropy, dispersivity, effective ! Treatment concentration goals and
porosity, stratigraphy, and the algorithms objectives.
used to solve contaminant transport
equations. Model selection should be The owner or operator should consider
appropriate for the amount of data available, whether immediate measures to limit further
and the technical uncertainty of the model plume migration (e.g., containment options)
results must be documented by a sensitivity or measures to minimize further
analysis on the input parameters. A introduction of contaminants to ground
sensitivity analysis is generally done after water are necessary.
model calibration by varying one input
parameter at a time over a realistic range The process by which a remedial action is
and then evaluating changes in model undertaken will generally include the
output. For additional information on following activities:
modeling, refer to the Further Information
Section of Chapter 5.0 and the RCRA ! Hydrogeologic investigation, which may
Facility Investigation Guidance: Volume II include additional well installations,
- Soil, Groundwater and Subsurface Gas detailed vertical and lateral sampling to
Releases (USEPA, 1989b). characterize the plume, and core
sampling to determine the degree of
Ground-Water Assessment sorption of constituents on the geologic
matrix
To assess the potential effectiveness of
corrective measures for ground-water ! Risk assessment, to determine the impact
contamination, the following information is on sensitive receptors, which may
needed: include identification of the need to
develop treatment goals other than
! Plume definition (includes the types, GWPSs
concentration, and spatial distribution of
the contaminants) ! Literature and technical review of
treatment technologies considered for
! The amenability of the contaminants to further study or implementation
specific treatment and potential for
contaminants to interfere with ! Evaluation of costs of different treatment
treatability options
! Fate of the contaminants (whether ! Estimation of the time required for

chemical transformations have, are, or completion of remediation under the
may be occurring, and the degree to different treatment options
which the species are sorbed to the
geologic matrix)
294
! Bench-scale treatability studies ! The anticipated cost of the remediation,

conducted to assess potential including capital expenditures, design,
effectiveness of options ongoing engineering, and monitoring of
results
! Selection of technology(ies) and
proposal preparation for regulatory and ! Technical and financial capability of the
public review and comment owner or operator to successfully
complete the remediation
! Full-scale pilot study for verification of
treatability and optimization of the ! Disposal requirements for treatment
selected technology residuals
! Initiation of full-scale treatment ! Other regulatory or institutional

technology with adjustments, as requirements, including State and local
necessary permits, prohibitions, or environmental
restrictions that may affect the
! Continuation of remedial action until implementation of the proposed remedial
treatment goals are achieved. activity.
Corrective Measures Assessment The performance objectives of the

corrective measures should be considered in
terms of source reduction, cleanup goals,
To compare different treatment options,
and cleanup time frame. Source reduction
substantial amounts of technical information
would include measures to reduce or stop
must be assembled and assessed. The
further releases and may include the repair
objective of this information-gathering task
of existing facility components (liner
is to identify the following items for each systems, leachate storage pond liners, piping
treatment technology: systems, cover systems), upgrading of
components (liners and cover systems), or
! The expected performance of individual premature closure in extreme cases. The
approaches technology proposed as a cleanup measure
should be the best available technology,
! The time frame when individual given the practicable capability of the owner
approaches can realistically be or operator.
implemented
The technologies identified should be
! The technical feasibility of the reliable, based on their previous
remediation, including new and performance; however, new innovative
innovative technologies, performance, technologies are not discouraged if they can
reliability and ease of implementation, be shown, with a reasonable degree of
safety and cross media impacts confidence, to be reliable.
! The anticipated time frame when Because most treatment processes, including
remediation should be complete biorestoration, potentially produce
byproducts or release contaminants to
295
Subpart E
different media (e.g., air stripping of of a qualified professional and will

volatile compounds), the impacts of such necessitate a literature review of the best
potential releases must be evaluated. available treatment technologies.
Releases to air may constitute a worker
health and safety concern and must be Numerous case studies and published papers
addressed as part of the alternatives from scientific and engineering technical
assessment process. Other cross media journals exist on treatability of specific
impacts, including transfer of contaminants compounds and groups of related
from soils to ground water, surface water, or compounds. Development of new
air, should be assessed and addressed in the technologies and refinements of
assessment of corrective actions. Guidance technologies have been rapid. A
for addressing air and soil transport and compendium of available literature that
contamination is provided in USEPA
includes treatment technologies for organic
(1989b) and USEPA (1989c).
and inorganic contaminants, technology
Analyses should be conducted on treatment selection, and other sources of information
options to determine whether or not they are (e.g., literature search data bases pertinent
protective of human health and the to ground-water extraction, treatment, and
environment. Environmental monitoring of responses) is included in Practical Guide
exposure routes (air and water) may for Assessing and Remediating
necessitate health monitoring for personnel Contaminated Sites (USEPA, 1989e).
involved in treatment activities if
unacceptable levels of exposure are The general approach to remediation
possible. On a case-by-case basis, typically includes active restoration, plume
implementation plans may require both containment, and source control as
forms of monitoring. discussed below. The selection of a
particular approach or combination of
The development and screening of approaches must be based on the corrective
individual corrective measures requires an action objectives. These general approaches
understanding of the physio-chemical are outlined in Table 5-3. It should be
relationships and interferences between the emphasized that the objective of a treatment
constituents and the sequence of treatment program should be to restore ground water
measures that must be implemented. Proper to pre-existing conditions or to levels below
sequencing of treatment methods to produce applicable ground-water protection
a feasible remedial program must be standards while simultaneously restricting
evaluated to avoid interference between the further releases of contaminants to ground
presence of some constituents and the water. Once treatment objectives are met,
effective removal of the targeted compound.
the chance of further contamination should
In addition, screening and design parameters
be mitigated to the extent practicable.
of potential treatment options should be
evaluated in the early stages of conceptual
development and planning to eliminate Active Restoration
technically unsuitable treatment methods.
In general, selection of an appropriate Active restoration generally includes
treatment method will require the ground-water extraction, followed by onsite
experience or offsite wastewater treatment. Offsite
296
wastewater treatment may include sending pilot field studies to determine the
the contaminated water to a local publicly feasibility and the reliability of full-scale
owned treatment works (POTW) or to a treatment. It must be demonstrated that the
facility designed to treat the contaminants of treatment techniques will not cause
concern. Treated ground water may be re- degradation of a target chemical to another
injected, sent to a local POTW, or compound that has unacceptable health risks
discharged to a local body of surface water, and that is subject to further degradation.
depending on local, State, and Federal Alternative in-situ methods may also be
requirements. Typical treatment practices designed to increase the effectiveness of
that may be implemented include desorption or removal of contaminants from
coagulation and precipitation of metals, the aquifer matrix. Such methodologies
chemical oxidation of a number of organic may include steam stripping, soil flushing,
compounds, air stripping to remove volatile vapor extraction, thermal desorption, and
organic compounds, and biological solvent washing, and extraction for removal
degradation of other organics. of strongly sorbed organic compounds.
These methods also may be used in
The rate of contaminant removal from unsaturated zones where residual
ground water will depend on the rate of contaminants may be sorbed to the geologic
ground-water removal, the cation exchange matrix during periodic fluctuations of the
capacity of the soil, and partition water table. Details of in-situ methods may
coefficients of the constituents sorbed to the be found in several sources: USEPA (1988);
soil (USEPA, 1988). As the concentration USEPA (1985); and Eckenfelder (1989).
of contaminants in the ground water is
reduced, the rate at which constituents Plume Containment
become partitioned from the soil to the
aqueous phase may also be reduced. The The purpose of plume containment is to
amount of flushing of the aquifer material limit the spread of the contaminants.
required to remove the contaminants to an Methods to contain plume movement
acceptable level will generally determine include passive hydraulic barriers, such as
the time frame required for restoration. This grout curtains and slurry walls, and active
time frame is site-specific and may last gradient control systems involving pumping
indefinitely. wells and french drains. The types of
aquifer characteristics that favor plume
In-situ methods may be appropriate for containment include:
some sites, particularly where pump and
treat technologies create serious adverse ! Water naturally unsuited for human
effects or where it may be financially consumption
prohibitive. In-situ methods may include
biological restoration requiring pH control, ! Contaminants present in low
addition of specific micro-organisms, and/or concentration with low mobility
addition of nutrients and substrate to
augment and encourage degradation by ! Low potential for exposure to
indigenous microbial populations. contaminants and low risk associated
Bioremediation requires laboratory with exposure
treatability studies and
297
Subpart E
! Low transmissivity and low future user ! Preventing additional leachate

demand. generation that may reach a liner failure
(e.g., using a portable or temporary rain
Often, it may be advantageous for the owner shelter during operations or capping
or operator to consider implementing landfill areas that contribute to leachate
ground-water controls to inhibit further migrating from identified failure areas).
contamination or the spread of
contamination. If ground-water pumping is In extreme cases, excavation of deposited
considered for capturing the leading edge of wastes for treatment and/or offsite disposal
the contaminant plume, the contaminated may be considered.
water must be managed in conformance
with all applicable Federal and State Public Participation
requirements. Under most conditions, it is
necessary to consult with the regulatory The owner or operator is required to hold a
agencies prior to initiating an interim public meeting to discuss the results of the
remedial action. corrective action assessment and to identify
proposed remedies. Notifications, such as
Source Control contacting local public agencies, town
governments, and State/Tribal governments,
Source control measures should be posting a notice in prominent local
evaluated to limit the migration of the newspapers, and making radio
plume. The regulation does not limit the announcements are effective. The public
definition of source control to exclude any meeting should provide a detailed
specific type of remediation. Remedies discussion of how the owner or operator has
must control the source to reduce or addressed the factors at §258.56(c)(1)-(4).
eliminate further releases by identifying and
locating the cause of the release (e.g., torn
geomembrane, excessive head due to 5.15 SELECTION OF REMEDY
blocked leachate collection system, leaking 40 CFR §258.57 (a)-(b)
leachate collection well or pipe). Source
control measures may include the following: 5.15.1 Statement of Regulation
! Modifying the operational procedures (a) Based on the results of the corrective
(e.g., banning specific wastes or measure assessment conducted under
lowering the head over the leachate §258.56, the owner or operator must
collection system through more frequent select a remedy that, at a minimum,
leachate removal) meets the standards listed in paragraph
(b) below. The owner or operator must
! Undertaking more extensive and notify the State Director, within 14 days
effective maintenance activities (e.g., of selecting a remedy, that a report
excavate waste to repair a liner failure or describing the selected remedy has been
a clogged leachate collection system) placed in the operating record and how it
meets the standards in paragraph (b) of
this section.
298
(b) Remedies must: and comply with waste management

standards.
(1) Be protective of human health and
the environment; 5.15.3 Technical Considerations
(2) Attain the ground-water protection The final method selected for
standard as specified pursuant to implementation must satisfy the criteria in
§§258.55(h) or (i); §258.57(b)(1)-(4). The report documenting
the capability of the selected method to
(3) Control the source(s) of releases so as meet these four criteria should include such
to reduce or eliminate, to the maximum information as:
extent practicable, further releases of
Appendix II constituents into the ! Theoretical calculations
environment that may pose a threat to
human health or the environment; and ! Comparison to existing studies and
results of similar treatment case
(4) Comply with standards for histories
management of wastes as specified in
§258.58(d). ! Bench-scale or pilot-scale treatability
test results
5.15.2 Applicability
! Waste management practices.
These provisions apply to facilities that
have been required to perform corrective The demonstration presented in the report
measures. The selection of a remedy is must document the alternative option
closely related to the assessment process and selection process.
cannot be accomplished unless a sufficiently
thorough evaluation of alternatives has been
completed. The process of documenting the 5.16 SELECTION OF REMEDY
rationale for selecting a remedy requires 40 CFR §258.57 (c)
that a report be placed in the facility
operating record that clearly defines the 5.16.1 Statement of Regulation
corrective action objectives and
demonstrates why the selected remedy is (c) In selecting a remedy that meets the
anticipated to meet those objectives. The standards of §258.57(b), the owner or
State Director must be notified within 14 operator shall consider the following
days of the placement of the report in the evaluation factors:
operating records of the facility. The study
must identify how the remedy will be (1) The long- and short-term
protective of human health and the effectiveness and protectiveness of the
environment, attain the GWPS (either potential remedy(s), along with the
background, MCLs, or, in approved States, degree of certainty that the remedy will
health-based standards, if applicable), attain prove successful based on consideration
source control objectives, of the following:
299
Subpart E
(i) Magnitude of reduction of existing (ii) The extent to which treatment

risks; technologies may be used.
(ii) Magnitude of residual risks in (3) The ease or difficulty of

terms of likelihood of further releases due implementing a potential remedy(s) based
to waste remaining following on consideration of the following types of
implementation of a remedy; factors:
(iii) The type and degree of long-term (i) Degree of difficulty associated with
management required, including constructing the technology;
monitoring, operation, and maintenance;
(ii) Expected operational reliability of
(iv) Short-term risks that might be the technologies;
posed to the community, workers, or the
environment during implementation of (iii) Need to coordinate with and obtain
such a remedy, including potential necessary approvals and permits from
threats to human health and the other agencies;
environment associated with excavation,
transportation, and redisposal or (iv) Availability of necessary
containment; equipment and specialists; and
(v) Time until full protection is (v) Available capacity and location of
achieved; needed treatment, storage, and disposal
services.
(vi) Potential for exposure of humans
and environmental receptors to (4) Practicable capability of the owner
remaining wastes, considering the or operator, including a consideration of
potential threat to human health and the the technical and economic capability.
environment associated with excavation,
transportation, redisposal, or (5) The degree to which community
containment; concerns are addressed by a potential
remedy(s).
(vii) Long-term reliability of the
engineering and institutional controls; 5.16.2 Applicability
and
These provisions apply to facilities that are
(viii) Potential need for replacement of selecting a remedy for corrective action.
the remedy. The rule presents the considerations and
factors that the owner or operator must
(2) The effectiveness of the remedy in evaluate when selecting the appropriate
controlling the source to reduce further corrective measure.
releases based on consideration of the
following factors:
(i) The extent to which containment

practices will reduce further releases;
300
5.16.3 Technical Considerations releases of contaminants to the environment,

as well as on the feasibility of the proposed
The owner or operator must consider remedy to meet or exceed the GWPSs. The
specific topics to satisfy the performance owner or operator must make a reasonable
criteria under selection of the final effort to estimate and quantify risks, based
corrective measure. These topics must be on exposure pathways and estimates of
addressed in the report documenting the exposure levels and durations. These
selection of a particular corrective action. estimates include risks for both ground-
The general topic areas that must be water and cross-media contamination.
considered include the following:
The source control measures that will be
! The anticipated long- and short-term implemented, including excavation,
effectiveness of the corrective action transportation, re-disposal, and
containment, should be evaluated with
! The anticipated effectiveness of source respect to potential exposure and risk to
reduction efforts human health and the environment. The
source control measures should be viewed
! The ease or difficulty of implementing as an integral component of the overall
the corrective measure corrective action. Health considerations
must address monitoring risks to workers
! The technical and economic practicable and the general public and provide
capability of the owner or operator contingency plans should an unanticipated
exposure occur. Potential exposure should
! The degree to which the selected remedy consider both long- and short-term cases
will address concerns raised by the before, during, and after implementation of
community. corrective actions.
Effectiveness of Corrective Action The time to complete the remedial activity

must be estimated, because it will have
In selecting the remedial action, the direct financial impacts on the project
anticipated long-term and short-term management needs and financial capability
effectiveness should be evaluated. Long- of the owner or operator to meet the
term effectiveness focuses on the risks remedial objectives. The long-term costs of
remaining after corrective measures have the remedial alternatives and the long-term
been taken. Short-term effectiveness financial condition of the owner or operator
addresses the risks during construction and should be reviewed carefully. The
implementation of the corrective measure. implementation schedule should indicate
Review of case studies where similar quality control measures to assess the
technologies have been applied provide the progress of the corrective measure.
best measures to judge technical
uncertainty, especially when relatively new The operational reliability of the corrective
technologies are applied. The long-term, measures should be considered. In addition,
post-cleanup effectiveness may be judged the institutional controls and management
on the ability of the proposed remedy to practices developed to assess the reliability
mitigate further should be identified.
301
Subpart E
Effectiveness of Source Reduction Technical considerations, including pH

control, ground-water extraction feasibility,
Source control measures identified in or the ability to inject nutrients, may need to
previous sections should be discussed in be considered, depending on the proposed
terms of their expected effectiveness. If treatment method. Potential impacts, such
source control consists of the removal and as potential cross-media contamination,
re-disposal of wastes, the residual materials, need to be reviewed as part of the overall
such as contaminated soils above the water feasibility of the project.
table, should be quantified and their
potential to cause further contamination The schedule of remedial activities should
evaluated. Engineering controls intended to identify the start and end points of the
upgrade or repair deficient conditions in following periods:
landfill component systems, including cover
systems, should be quantified in terms of ! Permitting phase
anticipated effectiveness according to
current and future conditions. This ! Construction and startup period, during
assessment may indicate to what extent it is which initial implementation success
technically and financially practicable to will be evaluated, including time to
make use of existing technologies. The correct any unexpected problems
decision against using a certain technology
may be based on health considerations and ! Time when full-scale treatment will be
the potential for unacceptable exposure(s) to initiated and duration of treatment period
both workers and the public.
! Implementation and completion of
Implementation of Remedial Action source control measures, including the
timeframe for solving problems
The ease of implementing the proposed associated
remedial action will affect the schedule and with interim management and disposal of
startup success of the remedial action. The waste materials or treatment residuals.
following key factors need to be assessed:
Items that require long lead times should be
! The availability of technical expertise identified early in the process and those
tasks should be initiated early to ensure that
! Construction of equipment or implementation occurs in the shortest
technology practicable period.
! The ability to properly manage and Practical Capability

dispose of wastes generated by
treatment The owner or operator must be technically
and financially capable of implementing the
! The likelihood of obtaining local chosen remedial alternative and ensuring
permits and public support for the project completion, including provisions for
proposed project. future changes to the remedial plan after
progress is reviewed. If either technical or
financial capability is inadequate for a
302
particular alternative, then other alternatives (3) Availability of treatment or disposal

with similar levels of protectiveness should capacity for wastes managed during
be considered for implementation. implementation of the remedy;
Community Concerns (4) Desirability of utilizing technologies

that are not currently available, but
The public meetings held during assessment which may offer significant advantages
of alternative measures are intended to elicit over already available technologies in
public comment and response. The owner terms of effectiveness, reliability, safety,
or operator must, by means of meeting or ability to achieve remedial objectives;
minutes and a record of written comments,
identify which public concerns have been (5) Potential risks to human health and
expressed and addressed by corrective the environment from exposure to
measure options. In reality, the final contamination prior to completion of the
remedy selected and implemented will be remedy;
one that the State regulatory agency, the
public, and the owner or operator agree to. (6) Resource value of the aquifer
including:
5.17 SELECTION OF REMEDY (i) Current and future uses;

40 CFR §258.57 (d)
(ii) Proximity and withdrawal rate of
5.17.1 Statement of Regulation users;
(d) The owner or operator shall specify (iii) Ground-water quantity and
as part of the selected remedy a quality;
schedule(s) for initiating and completing
remedial activities. Such a schedule must (iv) The potential damage to wildlife,
require the initiation of remedial crops, vegetation, and physical structures
activities within a reasonable period of caused by exposure to waste constituent;
time taking into consideration the factors
set forth in paragraphs (d) (1-8). The (v) The hydrogeologic characteristic of
owner or operator must consider the the facility and surrounding land;
following factors in determining the
schedule of remedial activities: (vi) Ground-water removal and
treatment costs; and
(1) Extent and nature of contamination;
(vii) The cost and availability of
(2) Practical capabilities of remedial alternative water supplies.
technologies in achieving compliance with
ground-water protection standards (7) Practicable capability of the owner
established under §§258.55(g) or (h) and or operator.
other objectives of the remedy;
(8) Other relevant factors.
303
Subpart E
5.17.2 Applicability affects the ultimate treatment rate. The size

of the treatment facility and the ground-
The requirements of §258.57(d) apply to water extraction and injection rates must be
owners or operators of all new units, balanced for system optimization, capital
existing units, and laterally expanded units resources, and remedial timeframe
at all facilities required to implement objectives. The nature of the contamination
corrective actions. The requirements must will influence the degree to which the
be complied with prior to implementing aquifer must be flushed to remove adsorbed
corrective measures. The owner or operator species. These factors, which in part define
must specify the schedule for remedial the practicable capability of the alternative
activities based on the following (treatment efficiency, treatment rate, and
considerations: replenishment of contaminants by natural
processes), should be considered when
! The size and nature of the contaminated selecting the remedy.
area at the time the corrective measure is
to be implemented In addition, the rate at which treatment may
occur may be restricted by the availability
! The practicable capabilities of the or capacity to handle treatment residues and
remedial technology selected the normal flow of wastes during
remediation. Alternative residue treatment
! Available treatment and disposal
or disposal capacity must be identified as
capacity
part of the implementation plan schedule.
! Potential use of alternative innovative
If contaminant migration is slow due to low
technologies not currently available
transport properties of the aquifer,
! Potential risks to human health and the additional time may be available to evaluate
environment existing prior to completion the value of emerging and promising
of the remedy innovative technologies. The use of such
technologies is not excluded as part of the
! Resource value of the aquifer requirement to implement a remedial action
as soon as practicable. Delaying
! The practicable capability of the implementation to increase the availability
owner/operator of new technologies must be evaluated in
terms of achievable cleanup levels, ultimate
! Other relevant factors. cost, additional environmental impact, and
potential for increased risk to sensitive
5.17.3 Technical Considerations receptors. If a new technology clearly is
superior to existing options in attaining
The time schedule for implementing and remediation objectives, it may be
completing the remedial activity is appropriate to delay implementation. This
influenced by many factors that should be may require that existing risks be controlled
considered by the owner or operator. The through interim measures.
most critical factor is the nature and extent
of the contamination, which significantly
304
In setting the implementation schedule, the 5.18 SELECTION OF REMEDY

owner or operator should assess the risk to 40 CFR §258.57 (e)-(f)
human health and the environment within
the timeframe of reaching treatment 5.18.1 Statement of Regulation
objectives. If the risk is unacceptable,
considering health-based assessments of (e) The Director of an approved State
exposure paths and exposure limits, the may determine that remediation of a
implementation time schedule must be release of an Appendix II constituent
accelerated or the selected remedy altered to from a MSWLF unit is not necessary if
provide an acceptable risk level in a timely the owner or operator demonstrates to
manner. the satisfaction of the Director of an
approved State that:
Establishment of the schedule also may
include consideration of the resource value (1) The ground water is additionally
of the aquifer, as it pertains to current and contaminated by substances that have
future use, proximity to users, quality and originated from a source other than a
quantity of ground water, agricultural value MSWLF unit and those substances are
and uses (irrigation water source or impact present in concentrations such that
on adjacent agricultural lands), and the cleanup of the release from the MSWLF
availability of alternative supplies of water unit would provide no significant
of similar quantity and quality. Based on reduction in risk to actual or potential
these factors, a relative assessment of the receptors; or
aquifer's resource value to the local
community can be established. Impacts to (2) The constituent(s) is present in
the resource and the degree of financial or ground water that:
health-related distress by users should be
considered. The implementation timeframe (i) Is not currently or reasonably
should attempt to minimize the loss of value expected to be a potential source of
of the resource to users. The possibility that drinking water; and
alternative water supplies will have to be
developed as part of the remedial activities (ii) Is not hydraulically connected with
may need to be considered. waters to which the hazardous
constituents are migrating or are likely to
Because owners or operators may not be migrate in a concentration(s) that would
knowledgeable in remediation activities, exceed the ground-water protection
reliance on the owner or operator to devise standards established under §258.55(h)
the schedule for remediation may be or (i); or
impracticable. In these instances, use of an
outside firm to coordinate remediation (3) Remediation of the release(s) is
scheduling may be necessary. Similarly, technically impracticable; or
development of a schedule for which the
owner or operator cannot finance, when (4) Remediation results in unacceptable
other options exist that do allow for owner cross-media impacts.
or operator financing, should be prevented.
305
Subpart E
(f) A determination by the Director of from implementing some or all of the

an approved State pursuant to paragraph corrective measure requirements. The
(e) above shall not affect the authority of owner or operator must demonstrate that
the State to require the owner or operator cleanup of a release from its MSWLF unit
to undertake source control measures or would provide no significant reduction in
other measures that may be necessary to risk to receptors due to concentrations of
eliminate or minimize further releases to constituents from the other source.
the ground water, to prevent exposure to
the ground water, or to remediate the A waiver from corrective measures also may
ground water to concentrations that are be granted if the contaminated ground water
technically practicable and significantly is not a current or reasonably expected
reduce threats to human health or the potential future drinking water source, and
environment. it is unlikely that the hazardous constituents
would migrate to waters causing an
5.18.2 Applicability exceedance of GWPS. The owner or
operator must demonstrate that the
The criteria under §258.57(e) and (f) apply uppermost aquifer is not hydraulically
in approved States only. Remediation of the connected with a lower aquifer. The owner
release of an Appendix II constituent may or operator may seek an exemption if it can
not be necessary if 1) a source other than the be demonstrated that attenuation,
MSWLF unit is partly responsible for the advection/dispersion or other natural
ground-water contamination, 2) the resource processes can remove the threat to
value of the aquifer is extremely limited, 3) interconnected aquifers. The owner or
remediation is not technically feasible, or 4) operator may seek the latter exemption if
remediation will result in unacceptable the contaminated zone is not a drinking
cross-media impacts. The Director may water resource.
determine that while total remediation is not
required, source control measures or partial The Director of an approved State may
remediation of ground water to waive cleanup requirements if remediation
concentrations that are technically is not technically feasible. In addition, the
practicable and significantly reduce risks is Director may wave requirements if
required. remediation results in unacceptable cross-
media impacts. A successful demonstration
5.18.3 Technical Considerations that remediation is not technically feasible
must document specific facts that attribute
There are four situations where an approved to this demonstration. Technical
State may not require cleanup of hazardous impracticabilities may be related to the
constituents released to ground water from accessibility of the ground water to
a MSWLF unit. If sufficient evidence exists treatment, as well as the treatability of the
to document that the ground water is ground water using practicable treatment
contaminated by a source other than the technologies. If the owner or operator can
MSWLF unit, the Director of an approved demonstrate that unacceptable cross-media
State may grant a waiver impacts are uncontrollable under a given
remedial option
306
(e.g., movement in response to ground- (iii) Demonstrates compliance with

water pumping or release of volatile ground-water protection standard
organics to the atmosphere) and that the no pursuant to paragraph (e) of this section.
action option is a less risky alternative, then
the Director of an approved State may (2) Implement the corrective action
determine that remediation is not necessary. remedy selected under §258.57; and
A waiver of remedial obligation does not (3) Take any interim measures necessary
necessarily release the owner or operator to ensure the protection of human health
from the responsibility of conducting source and the environment. Interim measures
control measures or minimal ground-water should, to the greatest extent practicable,
remediation. The State may require that be consistent with the objectives of and
source control be implemented to the contribute to the performance of any
maximum extent practicable to minimize remedy that may be required pursuant to
future risk of releases of contaminants to §258.57. The following factors must be
ground water or that ground water be treated considered by an owner or operator in
to the extent technically feasible. determining whether interim measures
are necessary:
5.19 IMPLEMENTATION OF THE (i) Time required to develop and

CORRECTIVE ACTION implement a final remedy;
PROGRAM
40 CFR §258.58 (a) (ii) Actual or potential exposure of
nearby populations or environmental
5.19.1 Statement of Regulation receptors to hazardous constituents;
(a) Based on the schedule established (iii) Actual or potential contamination

under §258.57(d) for initiation and of drinking water supplies or sensitive
completion of remedial activities the ecosystems;
owner/operator must:
(iv) Further degradation of the ground
(1) Establish and implement a corrective water that may occur if remedial action is
action ground-water monitoring program not initiated expeditiously;
that:
(v) Weather conditions that may cause
(i) At a minimum, meets the hazardous constituents to migrate or be
requirements of an assessment released;
monitoring program under §258.55;
(vi) Risks of fire or explosion, or
(ii) Indicates the effectiveness of the potential for exposure to hazardous
corrective action remedy; and constituents as a result of an accident or
failure of a container or handling system;
and
307
Subpart E
(vii) Other situations that may pose ground water degradation or the spread of
threats to human health and the the contaminant plume, replacement of the
environment. system with an alternative measure may be
warranted. The improvement rate of the
5.19.2 Applicability condition of the aquifer must be monitored
and compared to the cleanup objectives. It
These provisions apply to facilities that are may be necessary to install additional
required to initiate and complete corrective monitoring wells to more clearly evaluate
actions. remediation progress. Also, if it becomes
apparent that the GWPS will not be
The owner or operator is required to achievable technically, in a realistic time-
continue to implement its ground water frame, the performance objectives of the
assessment monitoring program to evaluate corrective measure must be reviewed and
the effectiveness of remedial actions and to amended as necessary.
demonstrate that the remedial objectives
have been attained at the completion of Interim Measures
remedial activities.
If unacceptable potential risks to human
Additionally, the owner or operator must health and the environment exist prior to or
take any interim actions to protect human during implementation of the corrective
health and the environment. The interim action, the owner or operator is required to
measures must serve to mitigate actual take interim measures to protect receptors.
threats and prevent potential threats from These interim measures are typically short-
being realized while a long-term term solutions to address immediate
comprehensive response is being developed. concerns and do not necessarily address
long-term remediation objectives. Interim
5.19.3 Technical Considerations measures may include activities such as
control of ground-water migration through
Implementation of the corrective measures high-volume withdrawal of ground water or
encompass all activities necessary to initiate response to equipment failures that occur
and continue remediation. The owner or during remediation (e.g., leaking drums). If
operator must continue assessment contamination migrates offsite, interim
monitoring to anticipate whether interim measures may include providing an
measures are necessary, and to determine alternative water supply for human,
whether the corrective action is meeting livestock, or irrigation needs. Interim
stated objectives. measures also pertain to source control
activities that may be implemented as part
Monitoring Activities of the overall corrective action. This may
include activities such as excavation of the
During the implementation period, ground- source material or in-situ treatment of the
water monitoring must be conducted to contaminated source. Interim measures
demonstrate the effectiveness of the should be developed with consideration
corrective action remedy. If the remedial given to maintaining conformity with the
action is not effectively curtailing further objectives of the final corrective action.
308
5.20 IMPLEMENTATION OF THE equipment, units, devices, or structures

CORRECTIVE ACTION that are:
PROGRAM
40 CFR §258.58 (b)-(d) (i) Technically practicable; and
5.20.1 Statement of Regulation (ii) Consistent with the overall

objective of the remedy.
(b) An owner or operator may
determine, based on information (4) Notify the State Director within 14
developed after implementation of the days that a report justifying the
remedy has begun or other information, alternative measures prior to
that compliance with requirements of implementing the alternative measures
§258.57(b) are not being achieved has been placed in the operating record.
through the remedy selected. In such
cases, the owner or operator must (d) All solid wastes that are managed
implement other methods or techniques pursuant to a remedy required under
that could practicably achieve compliance §258.57, or an interim measure required
with the requirements, unless the owner under §258.58(a)(3), shall be managed in
or operator makes the determination a manner:
under §258.58(c).
(1) That is protective of human health
(c) If the owner or operator determines and the environment; and
that compliance with requirements under
§258.57(b) cannot be practically achieved (2) That complies with applicable RCRA
with any currently available methods, the requirements.
owner or operator must:
(1) Obtain certification of a qualified
ground-water specialist or approval by The requirements of the alternative
the Director of an approved State that measures are applicable when it becomes
compliance with requirements under apparent that the remedy selected will not
§258.57(b) cannot be practically achieved achieve the GWPSs or other significant
with any currently available methods; objectives of the remedial program (e.g.,
protection of sensitive receptors). In
(2) Implement alternate measures to determining that the selected corrective
control exposure of humans or the action approach will not achieve desired
environment to residual contamination, results, the owner or operator must
as necessary to protect human health and implement alternate corrective measures to
the environment; and achieve the GWPSs. If it becomes evident
that the cleanup goals are not technically
(3) Implement alternate measures for obtainable by existing practicable
control of the sources of contamination, technology, the owner or operator must
or for removal or decontamination of implement actions to control exposure of
humans or the environment from residual
309
Subpart E
contamination and to control the sources of ! Inappropriately applied technology

contamination. Prior to implementing
alternative measures, the owner or operator ! Failure of source control measures to
must notify the Director of an approved achieve desired results
State within 14 days that a report justifying
the alternative measures has been placed in ! Failure of ground-water control systems
the operating record. to achieve adequate containment or
removal of contaminated ground water
All wastes that are managed by the MSWLF
unit during corrective action, including ! Residual concentrations above GWPSs
interim and alternative measures, must be that cannot be effectively reduced further
managed according to applicable RCRA because treatment efficiencies are too
requirements in a manner that is protective low
of human health and the environment.
! Transformation or degradation of target
5.20.3 Technical Considerations compounds to different forms that are
not amenable to further treatment by
An owner or operator is required to continue present or alternative technologies.
the assessment monitoring program during
the remedial action. Through monitoring, The owner or operator should compare
the short and long term success of the treatment assumptions with existing
remedial action can be gauged against conditions to determine if assumptions
expected progress. During the remedial adequately depict site conditions. If
action, it may be necessary to install implementation occurred as designed, the
additional ground-water monitoring wells or owner or operator should attempt to modify
pumping or injection wells to adjust to or upgrade existing remedial technology to
conditions that vary from initial assessments optimize performance and to improve
of the ground-water flow system. As treatment effectiveness. If the existing
remediation progresses and data are technology is found to be unable to meet
compiled, it may become evident that the remediation objectives, alternative
remediation activities will not protect approaches must be evaluated that could
human health and the environment, meet meet these objectives while the present
GWPSs, control sources of contamination, remediation is continued. During this re-
or comply with waste management evaluation period, the owner or operator
standards. The reasons for unsatisfactory may suspend treatment only if continuation
results may include: of remedial activities clearly increases the
threat to human health and the environment.
! Refractory compounds that are not
amenable to removal or destruction
(detoxification)
! The presence of compounds that

interfere with treatment methods
identified for target compounds
310
5.21 IMPLEMENTATION OF THE (iii) Accuracy of monitoring or

CORRECTIVE ACTION modeling techniques, including any
PROGRAM seasonal, meteorological, or other
40 CFR §258.58 (e)-(g) environmental variabilities that may
affect the accuracy; and
(iv) Characteristics of the ground
(e) Remedies selected pursuant to water.
§258.57 shall be considered complete
when: (3) All actions required to complete the
remedy have been satisfied.
(1) The owner or operator complies with
the ground-water protection standards (f) Upon completion of the remedy, the
established under §§258.55(h) or (i) at all owner or operator must notify the State
points within the plume of contamination Director within 14 days that a
that lie beyond the ground-water certification that the remedy has been
monitoring well system established under completed in compliance with the
§258.51(a). requirements of §258.58(e) has been
placed in the operating record. The
(2) Compliance with the ground-water certification must be signed by the owner
protection standards established under or operator and by a qualified ground-
§§258.55(h) or (i) has been achieved by water specialist or approved by the
demonstrating that concentrations of Director of an approved State.
Appendix II constituents have not
exceeded the ground-water protection (g) When, upon completion of the
standard(s) for a period of three certification, the owner or operator
consecutive years using the statistical determines that the corrective action
procedures and performance standards in remedy has been completed in accordance
§258.53(g) and (h). The Director of an with the requirements under paragraph
approved State may specify an (e) of this section, the owner or operator
alternative length of time during which shall be released from the requirements
the owner or operator must demonstrate for financial assurance for corrective
that concentrations of Appendix II action under §258.73.
constituents have not exceeded the
ground-water protection standard(s) §258.59 [Reserved].
taking into consideration:
(i) Extent and concentration of the
release(s); These criteria apply to facilities conducting
corrective action. Remedies are considered
(ii) Behavior characteristics of the complete when, after 3 consecutive years of
hazardous constituents in the ground monitoring (or an alternative length of time
water; as identified by the Director), the results
show significant statistical evidence that
311
Subpart E
Appendix II constituent concentrations are State. Upon completion of the remedial

below the GWPSs. Upon completion of all action, in accordance with §258.58(e), the
remedial actions, the owner or operator owner or operator is released from the
must certify to such, at which point the financial assurance requirements pertaining
owner or operator is released from financial to corrective actions.
assurance requirements.
The Director of an approved State may
5.21.3 Technical Considerations require an alternate time period (other than
3 years) to demonstrate compliance. In
The regulatory period of compliance is 3 determining an alternate period the Director
consecutive years at all points within the must consider the following:
contaminant plume that lie beyond the
ground-water monitoring system unless the ! The extent and concentration of the
Director of an approved State specifies an release(s)
alternative length of time. Compliance is
achieved when the concentrations of ! The behavior characteristics (fate and
Appendix II constituents do not exceed the transport) of the hazardous constituents
GWPSs for a predetermined length of time. in the ground water (e.g., mobility,
Statistical procedures in §258.53 must be persistence, toxicity, etc.)
used to demonstrate compliance with the
GWPSs. ! Accuracy of monitoring or modeling
techniques, including any seasonal,
The preferred statistical method for meteorological or other environmental
comparison is to construct a 99 percent variabilities that may affect accuracy
confidence interval around the mean of the
last 3 years of data and compare the upper ! The characteristics of the ground water
limit of the confidence interval to the (e.g., flow rate, pH, etc.).
GWPS. An upper limit less than the GWPS
is considered significant evidence that the Consideration of these factors may result in
standard is no longer being exceeded. The an extension or shortening of the time
confidence interval must be based on the required to show compliance with
appropriate model describing the remediation objectives.
distribution of the data.
Upon completion of the remedy, including

meeting the GWPS at all points within the
contaminant plume, the owner or operator
must notify the State Director within
fourteen days that a certification that the
remedy has been completed has been placed
in the operating record. The certification
must be signed by the owner or operator and
a qualified ground-water scientist or
approved by the Director of an approved
312
5.22 FURTHER INFORMATION
5.22.1 References
Aitchison, J., and J.A.C. Brown (1969). "The Lognormal Distribution"; Cambridge University
Press; Cambridge.
American Water Works Association (1984). "Abandonment of Test Holes, Partially Completed
Wells and Completed Wells." Appendix I. American Water Works Association Standard for
Water Wells, American Water Works Association, Denver, CO, pp 45-47.
Barari, A., and L.S. Hedges (1985). "Movement of Water in Glacial Till." Proceedings of the
17th International Congress of International Association of Hydrogeologists.
Barcelona, M.J., J.A. Helfrich and E.E. Garske, (1985). "Sampling Tube Effects on
Groundwater Samples"; Analytical Chemistry 47(2): 460-464.
Barcelona, M.J., J.P. Gibb, J.A. Helfrich, and E.E. Garske, (1985b). "Practical Guide for
Ground-Water Sampling," USEPA, Cooperative Agreement #CR-809966-01, EPA/600/2-
85/104, 169 pp.
Barcelona, M.J., et al. 1990. Contamination of Ground Water: Prevention, Assessment,

Restoration. Pollution Technology Review No. 184, Noyes Data Corporation, Park Ridge, NJ,
213 pp.
Cantor, L.W., R.C. Knox, and D.M. Fairchild (1987). Ground-Water Quality Protection. Lewis
Publishers, Inc., Chelsea, MI.
Cooper, H.H., Jr., and C.E. Jacob (1946). "A Generalized Graphical Method for Evaluating
Formation Constants and Summarizing Well-Field History." American Geophys. Union Trans.,
V. 27, No. 4.
Daniel, D.E., H.M. Liljestrand, G.P. Broderick, and J.J. Bounders, Jr. (1988). "Interaction of
Earthen Linear Materials with Industrial Waste Leachate in Hazardous Waste and Hazardous
Materials," Vol. 5, No. 2.
Dixon, W.J. and F.J. Massey, Jr. (1969). "Introduction to Statistical Analysis"; 3rd Edition;
McGraw-Hill Book Co.; New York, New York.
Driscoll, F.G., (1986). "Groundwater and Wells"; Johnson and Johnson; St. Paul, Minnesota.
Eckenfelder, W.W., Jr., (1989). Industrial Water Pollution Control. McGraw-Hill, Inc., Second
Edition.
313
Subpart E
Fetter, C.W., Jr. (1980). Applied Hydrogeology. Charles E. Merrill Publishing Co., Columbus,
OH.
Freeze, R.A. and J.A. Cherry, (1979). Groundwater; Prentice-Hall, Inc.; Englewood Cliffs,
New Jersey.
Gibbons, J.D., (1976). "Nonparametric Methods for Quantitative Analysis"; Holt, Rinehart, and
Winston Publishing Co.; New York, New York.
Gilbert, R.O., (1987). Statistical Methods for Environmental Pollution Monitoring; Van
Nostrand Reinhold Co.; New York, New York.
Heath, R.C. (1982). Basic Ground-Water Hydrology. U.S. Geological Survey Water Supply
Paper 2220, 84 pp.
Hsieh, P.A., and S.P. Neuman (1985). "Field Determination of the Three - Dimensional
Hydraulic Conductivity Teasor of Anisotropic Media." Water Resources Research, V. 21, No.
11.
Kearl, P.M., N.E. Korte, and T.A. Cronk. 1992. "Suggested Modifications to Ground Water
Sampling Procedures Based on Observations from the Colloidal Borescope." Ground-Water
Monitoring Review, Spring, pp. 155-160.
Kruseman, G.P., and N.A. de Ridder (1989). "Analysis and Evaluation of Pumping Test Data,"
International Institute for Land Reclamation and Improvement/ILRI, Bulletin II, 4th Edition.
Lamb, B. and T. Kinney (1989). "Decommissioning Wells - Techniques and Pitfalls."

Proceedings of the Third National Outdoor Action Conference on Aquifer Restoration, Ground-
Water Monitoring and Geophysical Methods, NWWA, May 22-25, 1989, pp 217-228.
McGlew, P.J. and J.E. Thomas (1984). "Determining Contaminant Migration Pathways in
Fractured Bedrock." Proceedings of the Fifth National Conference on Management of
Uncontrolled Hazardous Waste Sites.
McWhorter, D.B., and D.K. Sunada (1977). Ground-Water Hydrology and Hydraulics. Water
Resources Publications, Fort Collins, CO.
Miller, J.C. and J.N. Miller, (1986). Statistics for Analytical Chemistry; John Wiley and Sons;
New York, New York.
Molz, F.J., O. Guven and J.G. Melville (1990). "A New Approach and Methodologies for
Characterizing the Hydrogeologic Properties of Aquifers." EPA Project Summary. EPA
600/52-90/002.
314
Molz, F.J., R.H. Norin, A.E. Hess, J.G. Melville, and O. Guven (1989) "The Impeller Meter for
Measuring Aquifer Permeability Variations: Evaluation and Comparison with Other Tests."
Water Resources Research, V 25, No. 7, pp 1677-1683.
Puls, R.W. and R.M. Powell. 1992. "Acquisition of Representative Ground Water Quality
Samples for Metals." Ground-Water Monitoring Review, Summer, pp. 167-176.
Puls, R.W., R.M. Powell, D.A. Clark, and C.J. Paul. 1991. "Facilitated Transport of Inorganic
Contaminants in Ground Water: Part II." Colloidal Transport, EPA/600/M-91/040, 12 pp.
Puls, R.W., and M.J. Barcelona. 1989a. "Filtration of Ground Water Samples for Metals
Analysis." Hazardous Waste and Hazardous Materials, v. 6, No. 4.
Puls, R.W., and M.J. Barcelona. 1989b. "Ground Water Sampling for Metals Analysis."
USEPA Superfund Ground Water Issue, EPA/504/4-89/001, 6 pp.
Sevee, J. (1991). "Methods and Procedures for Defining Aquifer Parameters," in D.M. Nielsen,
ed., Practical Handbook of Ground-Water Monitoring. Lewis Publishers, Chelsea, MI.
USEPA (1975). Manual of Water Well Construction Practices. USEPA Office of Water Supply,
Report No. EPA-570/9-75-001, 156 pp.
USEPA, (1985). "Handbook: Remedial Action at Waste Disposal Sites"; EPA/540/G-88/003;

U.S. EPA; Office of Emergency and Remedial Response; Washington, D.C.
USEPA, (1986a). "RCRA Groundwater Monitoring Technical Enforcement Guidance

Document"; Office of Solid Waste and Emergency Response - 9950.1.
USEPA, (1986b). "Test Methods for Evaluating Solid Waste - Physical/Chemical Methods";
EPA SW-846, 3rd edition; PB88-239-233; U.S. EPA; Office of Solid Waste and Emergency
Response; Washington, D.C.
USEPA, (1986c). "Superfund Public Health Evaluation Manual"; PB87-183-125; U.S. EPA;
Office of Emergency and Remedial Response; Washington, D.C. 20460.
USEPA, (1986d). "Superfund Risk Assessment Information Directory"; PB87-188-918; U.S.

EPA; Office of Emergency and Remedial Response; Washington, D.C. 20460.
USEPA, (1988). "Guidance on Remedial Actions for Contaminated Groundwater at Superfund

Sites"; PB89-184-618; U.S. EPA; Office of Emergency and Remedial Response; Washington,
D.C. 20460.
315
Subpart E
USEPA, (1989). "Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities-

Interim Final Guidance"; EPA/530-SW-89-026; U.S. EPA; Office of Solid Waste; Washington,
D.C.
USEPA, (1989a). "RCRA Facility Investigation (RFI) Guidance; Interim Final; Vol. I
Development of an RFI Work Plan and General Considerations for RCRA Facility
Investigations"; PB89-200-299; U.S. EPA; Office of Solid Waste; Washington, D.C.
USEPA, (1989b). "RCRA Facility Investigation (RFI) Guidance; Interim Final; Vol. II - Soil,
Ground Water and Subsurface Gas Releases"; PB89-200-299; U.S. EPA; Office of Solid Waste;
Washington, D.C.
USEPA, (1989c). "Criteria for Identifying Areas of Vulnerable Hydrogeology Under the
Resource Conservation and Recovery Act, Interim Final. Appendix B -Ground-Water Flow
Net/Flow Line Construction and Analysis."
USEPA, (1989d). "RCRA Facility Investigation (RFI) Guidance; Vol IV: Case Study
Examples;" PB89-200-299; U.S. EPA; Office of Solid Waste; Washington, D.C.
USEPA, (1989e). "Practical Guide for Assessing and Remediating Contaminated Sites - Draft";
U.S. EPA; Waste Management Division, Office of Solid Waste, 401 M Street, S.W.;
Washington, D.C. May 1989.
USEPA, (1989f). "Handbook of Suggested Practices for the Design and Installation of Ground-
Water Monitoring Wells"; PB90-159-807; U.S EPA; Office of Research and Development;
Washington, D.C.
USEPA, (1990). "Handbook: Groundwater Vol I;" EPA/625/6-90/016a; U.S. EPA; Office of
Research and Development; Cincinnati, Ohio.
USEPA, (1991). "Handbook: Groundwater Vol II"; EPA/625/6-90/016b; U.S. EPA; Office of
Research and Development; Cincinnati, Ohio.
USEPA, (1992a). "RCRA Ground-Water Monitoring: Draft Technical Guidance"; EPA/530-R-

93-001; U.S. EPA; Office of Solid Waste; Washington, D.C. PB93-139-350.
USEPA, (1992b). "Statistical Training Course for Ground-Water Monitoring Data Analysis",
EPA/530-R-93-003; U.S. EPA; Office of Solid Waste; Washington, D.C.
USEPA, (1992c). "User Documentation of the Ground-Water Information Tracking System

(GRITS) with Statistical Analysis Capability, GRITSTAT Version 4.2;" EPA/625/11-91/002;
USEPA Office of Research and Development, Center for Environmental Research, ORD
Publications.
316
USGS, (1989). "Chapter C2, Computer Model of Two-Dimensional Solute Transport and
Dispersion in Groundwater"; L.F. Konikow and J.D. Bredehoeft; Book 7; U.S. Geological
Survey; U.S. Department of Interior.
Way, S.C., and C.R. McKee (1982). "In-Situ Determination of Three-Dimensional Aquifer
Permeabilities." Ground Water, V. 20, No. 5.
317
Subpart E
318

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CHAPTER 5

5.1 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 211

5.2 APPLICABILITY 40 CFR §258.50 (a) & (b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 211

5.3 COMPLIANCE SCHEDULE 40 CFR § 258.50 (c) . . . . . . . . . . . . . . . . . . . . . . . . . . 214

5.5 QUALIFICATIONS 40 CFR 258.50 (f) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 217

5.6 GROUND-WATER MONITORING SYSTEMS 40 CFR §258.51 (a)(b)(d) . . . . . . . 219

5.8 GROUND-WATER SAMPLING AND ANALYSIS REQUIREMENTS

5.10 DETECTION MONITORING PROGRAM 40 CFR §258.54 . . . . . . . . . . . . . . . . . . 274

5.11 ASSESSMENT MONITORING PROGRAM 40 CFR §258.55(a)-(f) . . . . . . . . . . . . 281

5.12 ASSESSMENT MONITORING PROGRAM 40 CFR §258.55(g) . . . . . . . . . . . . . . 286

5.13 ASSESSMENT MONITORING PROGRAM 40 CFR §258.55(h)-(j) . . . . . . . . . . . . 289

5.15 SELECTION OF REMEDY 40 CFR §258.57 (a)-(b) . . . . . . . . . . . . . . . . . . . . . . . . 298

5.16 SELECTION OF REMEDY 40 CFR §258.57 (c) . . . . . . . . . . . . . . . . . . . . . . . . . . . 299

5.17 SELECTION OF REMEDY 40 CFR §258.57 (d) . . . . . . . . . . . . . . . . . . . . . . . . . . . 303

5.18 SELECTION OF REMEDY 40 CFR §258.57 (e)-(f) . . . . . . . . . . . . . . . . . . . . . . . . . 305

5.20 IMPLEMENTATION OF THE CORRECTIVE ACTION PROGRAM

5.21 IMPLEMENTATION OF THE CORRECTIVE ACTION PROGRAM

5.22 FURTHER INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 313

5.2 APPLICABILITY active life of the unit and the post-closure

5.2.2 Applicability §258.51 through §258.55 if the owner or

! Climatic Conditions, including annual transport should be biased toward over-

5.3 COMPLIANCE SCHEDULE (4) New MSWLF units must be in

One mile or less 3 Years

(e) Once established at a MSWLF 5.4.2 Applicability

sampling and analysis requirements of at existing MSWLF units, the Director of an

The rule allows approved States flexibility

Table 5-2. Summary of Notification Requirements

14 day notification period after well installation

the natural sciences or engineering and 5.5.3 Technical Considerations

Many State environmental regulatory (2) Represent the quality of ground

(2) Hydrogeologic setting; 5.6.2 Applicability

(3) Site history; The requirements for establishing a ground-

! Hydrogeologic setting ! The geology at the owner's/operator's

! Engineering design of the MSWLF units ! The chemical properties of the

! Information on the waste management Characterizing Site Geology

- Journal articles The subsurface boring program should be

include electric, sonic, and nuclear logging. ! Seasonal/temporal, natural, and

design of a piezometer/well nest should be Further information can be obtained from

determining flow rates in heterogeneous preliminary investigation to verify the

! Drilling and/or well construction logs Point of compliance monitoring wells

Point of compliance monitoring wells In some settings, the ground-water flow

contaminants may occur as light non ! "Down-the-dip" of lower hydraulic

Even in hydrologically simple formations, would represent a fairly discrete interval in

5.7 GROUND-WATER decommissioning of any monitoring well

Selection of Drilling Method ! Drilling should be performed in a

! Availability of drilling equipment ! The drilling method should allow the

space for placement of the filter pack Monitoring Well Design

due to suspension in the borehole, background wells and downgradient

and contaminant-related monitoring selecting monitoring well materials.

components should not be used unless an threaded joints should be used on

A locking protective casing should be unavoidable, such as in active roadways, a

unless changes in ground-water flow When development is initiated, a wide range

Decommissioning Ground-Water In some States, similar regulations may

Should an owner or operator have a (a) The ground-water monitoring

(3) Analytical procedures; §258.55(a) of this Part. Background

(c) The sampling procedures and 5.8.2 Applicability

incorrect determination of ground-water ! Chain of custody control

! Total depth of well from the top of the Well Purging

application and limitations of various Bladder pumps are generally recognized as