Document ymj3mn8L5zD41MJrNnQZvwe73

. I i r hw ft J f Ki )! I for Hazardous Waste Management Facilities CCR 00004058< Dames & Moore ^ Protecting the Earth's Water Cycle from Hazardous Waste Contaminants Controlling contaminants at hazardous waste disposal facilities is a critical issue facing industry. The ultimate goal is to protect public health and the environment by containing the wastes at their source and thus, prevent harmful elements in the wastes from infiltrating surface and ground water resources. Dames & Moore, a leading earth sciences and environmental engineering consultant, is experienced in developing effective ground water monitoring networks and closure and post-closure plans for all types of hazardous waste management facilities. The firm's professional staff has extensive experience in providing consultation on how to meet the Resource Conservation and Recovery Act regulations and other federal, state and local requirements. With offices in key cities throughout the U.S., Dames & Moore provides personal, custom ized service at the lowest possible cost. Ground Water Monitoring Networks Tracing the course of ground water is the first step in preventing the transport and dispersion of contaminants. Dames & Moore's approach is to establish a ground water monitoring network designed to accomplish three key goals: Detect the presence or absence of contaminants in ground water Determine the extent of contamination Develop remedial programs Highly skilled in working with the hydro geologic environment, the firm uses sophis ticated field exploration techniques to optimize placement of ground water mon itoring wells and thus, ensure accurate, representative water quality data is ob tained. The firm also provides on-site technical supervision of well installation and extraction procedures to ensure that the construction materials used do not contribute to contamination. In developing remedial programs, Dames & Moore uses advanced waste management techniques to achieve regulatory compliance at a reason able cost. Closure and Post-Closure Plans For inoperative hazardous waste man agement facilities, Dames & Moore provides comprehensive consulting services for the development of closure and post-closure plans to prevent the migration of harmful elements in the wastes into surface or ground water. The firm also develops detailed design specifications of impound ments, which will meet the regulatory criteria, and construction drawings for appropriate closures of inactive sites. In accordance with Resource Conserva tion and Recovery Act regulations, Dames & Moore develops closure plans to provide for the diversion of run-on, collection of run-off and the prevention of wind erosion. Post-closure plans incorporate a ground water monitoring network for the required 30-year period of maintenance. Dames & Moore specialists in the area of regulatory compliance investigate alter native options to achieve compliance. Sometimes the objectives of federal regula tions can be met by using a less-stringent closure and post-closure plan. Dames & Moore provides consultation to help deter mine if an amended plan is appropriate. CCR 000040589 V- tor'' ' S" ( ' .<* 7', " .V f* * - r Surface Impoundment Closure Decision to evaporate L. j Decision to i remove by pumping ; Is liquid hazardous waste? 1 * Cost L Begin ground water monitoring activities r ; Subpart 265.278 Facility Post Cl sure Site geohydrology not characterized Site geohydrology characterized Subatantial depth to water table or Subatantial thlckneaa of Impermeable strata (-10-1 cm/sec) above water table, and Subatantial dletance to eurface water bodlea, exlatlng or potential walla Significant thlckneaa of Impermeable strata above water table Other the or waste specific information [ Site geohydrology i not characterized I Site geohydrology characterized Water table aquifer, | Shallow confined aquifer or Uncomplex fracture or solution poroefty ayatem Evidence of exlatlng contamination or I > Complex geohydrologic | ayatem or I * Other site or waste pacific information CCR 000040591 Disposition of waste and waste residue Examine economic aspects and > requirements I for landfill Implement alternate ground water monitoring plan Decision to remove from facility Examine cost, etc. ; in treating or not Yes Transport to off site treatment facility Examine nature of waste end expected leechate composition No treatment .( Treat in place S I ct d Cli nts-- Gr und Wat r Studi s Alyeska Pipeline Service Company Atlantic Richfield Company BASF Wyandotte Corporation Battelle Pacific Northwest Laboratories Bethlehem Steel Corp. Boise Cascade Corp. Chevron Chemical Company Chevron U.S.A. Collier Carbon and Chemical Corporation Consolidated Edison Co. of New York, Inc. Delmarva Power & Light Co. Department of Natural Resources, Commonwealth of Kentucky Dow Chemical Co. Eastman Kodak Co. Exxon Company, U.S.A. General Electric Co. General Motors Corp. Getty Refining & Marketing Co. International Business Machines Corp. Johnson & Johnson Kaiser Aluminum & Chemical Corp. Monroe Township, New Jersey Monsanto Company Spencer Kellogg Union Carbide Corp. Union Oil Co. U.S. Department of Energy U.S. Environmental Protection Agency U.S. Nuclear Regulatory Commission United States Steel Corp. Velsical Chemical Corp. Westvaco Corporation CCR 0000A0592 Resource Conservation and Recovery Act Highlights from Ground Water Monitoring Part 265, Subpart F Introduction Owners or operators of surface impound ments, landfills or land treatment facilities used to manage hazardous waste must implement by November 19,1981, a ground water monitoring system capable of deter mining ground water quality in the upper most aquifer underlying the hazardous waste facility (Section 1 265.90). This monitoring program must be carried out during the active life of the facility, and for disposal facilities, during the post-closure period as well. All or part of these requirements can be waived if it can be demonstrated there is little potential for waste migration from the facility to water supply wells or to surface water. This documentation must be kept at the facility and requires certification by a qualified geologist or geotechnical engineer. Ground Water Monitoring System The ground water monitoring system must consist of at least one monitoring well upgradient from the facility site for the purpose of obtaining background data, and at least three monitoring wells down-gradient from the facility site for the purpose of detecting significant amounts of waste migrating to the uppermost aquifer (Section 265.91). Sampling and Assessment Procedures A ground water sampling and analysis plan must be developed, which includes procedures and techniques for sample collection, preservation, and shipment, along with analytical procedures and chain of custody control. Testing for the various parameters indicating ground water quality and possible contamination must be carried out on a prescribed schedule. In addition, the eleva tion of the ground water surface at each monitoring well must be determined at each sampling (Section 265.92). Within one year after the effective date of the regulations (by November 19,1981), an outline for a ground water quality assess ment program must be prepared to describe methods to determine if hazardous waste constituents have entered the ground water, and if so, the rate and extent of migration and their concentration in the ground water (Section 265.93). For each of the parameters in Section 265.92 (b) (3) (pH, specific conductance, total organic carbon, total organic halogen), the variance from initial background condi tion at each of the monitoring wells must be analyzed. If the results of this analysis indicate statistically significant changes in ground water quality from the background condition, the owner or operator must notify EPA within seven days. Within 15 days after the notification, a specific plan must be submitted to the Regional Administrator. The plan must include: The number, location, and depth of wells Sampling and analytical methods for those hazardous wastes in the facility Evaluation procedures Concentration of the hazardous waste in the ground water A schedule of implementation The owner or operator must then imple ment this plan to determine the rate and extent of hazardous waste migration and its concentration in the ground water. This determination should be made as soon as possible, and a written report should be submitted to the Regional Administrator containing an assessment of the ground water quality. If the assessment plan testing indicates no hazardous wastes have entered the ground water, then the owner or operator can reinstate the evaluation program cited in Section 265.92. If the assessment plan testing indicates that hazardous wastes from the facility have entered the ground water, the owner or operator must continue CCk 0000A0593 etei'miRations in Section 265.93 on a f:erly basis until final closure of the facility. Documentation Records of the analysis required in Section 265.92 should be Kept for the life of the facility and for disposal facilities, throughout the post-closure care period as well. Concentrations or values for each of the parameters listed in Section 265.92 as well as the evaluations of these para meters should be reported to the Regional Administrator on an annual basis as part of the annual report required under Section 265.75. If ground water is monitored to satisfy the requirements of Section 265.93, the owner or operator must keep records of the analysis throughout the active life of the facility, and for disposal facilities, throughout the post-closure care period as well. In addi tion, a report must be submitted annually to the Regional Administrator containing results of the ground water quality assess- program and calculated rates of i^ration of hazardous waste in the ground water during the reporting period (Section 265.94). New Developments In October 1980, EPA proposed addi tional rules on ground water protection which are applicable to all hazardous waste management facilities. The notice gives an outline of EPA's intended approach for preventing ground water contamination in order to protect human health and the environment. The approach EPA has chosen combines various aspects of several alternatives, including specific technical design require ments, non-degradation of ground water below established health and environmental performance standards, and non-numerical health and environmental standards. EPA intends to refine these standards over time as more information becomes available. The agency believes that this flexible approach will provide maximum protection to human health and the environment. Hf ` Dames & Moore provides a broad range of consulting services designed to help clients achieve compliance with Resource Conservation and Recovery Act (RCRA) regulations. RCRA requirements for ground water monitoring and closure and post-closure plans for hazardous waste management facilities are described in the attached brochure. If you would like more detailed information on RCRA regulations or Dames & Moore's consulting services, we would be happy to assist you. Dames & Moore 6 Commerce Drive Cranford, NJ 07016 (201) 272-8300 James V Toto Manager of Waste Management Services CCR 000040594 The Firm Dames & Moore provides a broad range of planning and economic, environmental, engineering and geotechnical services. Since its founding in 1938, the firm has grown to include some 1,400 employees and partners with offices in principal cities throughout the world. The firm has com pleted more than 44,000 projects for over 12,000 clients in over 100 countries. The Staff The firm's staff includes professionals trained in geohydrology, hydrology, geology and other areas of the applied earth and environmental sciences; civil and chemical engineering; and planning and economics. Services Site and route selection studies Environ mental baseline studies Feasibility studies Environmental reports Safety analysis reports - Advanced engineering analyses Geotechnical and seismic risk investiga tions Water quality analyses * Hazardous waste management services Mineral resource evaluations Slope stability analyses Revegetation studies Flood control studies Construction management Environmental and ecological monitoring programs Meteorology and air quality analyses * Wind and wave analyses Marine weather forecasting Dredging plans Undersea hazards surveys Land use and economic planning Fish and wildlife management programs Acoustical surveys and impact analyses Remote sensing and photogrammetry Materials testing Mathematical and physical model ing Quality assurance/quality control Licensing and permitting assistance Expert testimony r more information about Dames & Moore's RCRA-related consulting rvices contact: ortheast mes V. Toto anager of Waste Management rvices and rnaj)1 Archer "ames & Moore Commerce Drive anford, NJ 07016 01) 272-8300 ational Capitol Area/Atlantic ank Vernese ames & Moore 7101 Wisconsin Avenue Washington, D.C. 20014 (301) 652-2215 South Central H. Darryl Miller Dames & Moore 4321 Director's Row, Suite 200 Houston, TX 77092 (713) 688-4541 Jack McClure Dames & Moore 3399 Tates Creek Road Lexington, KY 40502 (606) 269-3693 Rocky Mountain Wayne Smith Dames & Moore 1626 Cole Boulevard Golden, CO 80401 (303) 232-6262 Southeast Michael Hess Dames & Moore 455 East Paces Ferry Road, Suite 200 Atlanta, GA 30305 (404) 262-2915 Midwest Ron Kibler Dames & Moore 1150 West Eighth Street Cincinnati, OH 45203 (513) 651-3440 Jerry Wang Dames & Moore 1550 Northwest Highway Park Ridge, IL 60068 (312) 297-6120 Pacific Northwest Robert H. Winn Dames & Moore 155 N.E. 100th Street, Suite 500 Seattle, WA 98125 (206) 523-0560 West Coast Henry Klehn Dames & Moore 1100 Glendon Avenue, Suite 1000 Los Angeles, CA 90024 (213) 879-9700 Joseph Jeno Dames & Moore 500 Sansome Street San Francisco, CA 94111 (415) 433-0700 s & Moor CC0000405: