do’s and don’ts - compliance monitoring systems · methane monitoring regulatory requirements...
TRANSCRIPT
Dos and Don’ts for Designing and Maintaining Your Environmental Compliance Monitoring Systems
April 27, 2016
Did you know?
Detection Monitoring vs. Assessment Monitoring cost differential is ~ triple?
Groundwater and methane exceedances may require adjacent property owner notification?
Analytical results (and standards) are in parts per billion(= thimble in Olympic sized swimming pool)?
Outline
Groundwater Monitoring Networks Surface Water Monitoring Networks Methane Monitoring Networks Stormwater Monitoring Networks Leachate Monitoring Networks
Environmental Monitoring Networks
Groundwater Surface Water
Leachate Methane
Stormwater
Groundwater Monitoring Networks
Well Location Regulatory Requirements Well Maintenance Decommissioning Procedures
Well Location
Geology/Hydrogeology Topography Current and Previous Site Layout and Usage
Well Location
Geology and Hydrogeology Do Consider:
Physiographic province Bedrock geology Thickness and type of soils Depth to water Multiple aquifer systems Complicated geology (e.g., diabase)
Don’t: Use a grid system approach to well location Take same approach for each site
Well Location
Topography Drilling rig access
Complicated with distance between edge of waste and property line
Complicated for steep slopes Stake and verify locations in field
Drainage issues Do have positive drainage Don’t have standing water around well
Use topography for well placement Preferential flow paths along drainages Fracture trace/lineament analysis
Well Location
Land Usage – Past and Present Dos
Leachate storage areas Sumps/manholes/lift stations
Well Location
Land Usage – Past and Present Don’ts
Contractor laydown areas Former petroleum storage Heavily trafficked roads Customer convenience areas Unpermitted disposal areas Too close to/in waste Buried utilities Pre-landfill uses
Regulatory Requirements
Regulatory Requirements – NC Solid Waste Water Quality Monitoring Plan
Number and spacing (site-specific) –upgradient and downgradient
Distance from waste ~ 125’ Representative samples Uppermost hydrogeologic unit (complicated
hydrogeology may require deeper wells) Reports submitted by qualified PG/PE
Regulatory Requirements
Regulatory Requirements and Guidance Documents – NC Solid Waste Surveyed location and elevation surveyed by licensed surveyor
Horizontal: 0.1 ft Vertical 0.01 ft
NC certified well driller required for monitoring well and piezometer installation
Network modification through minor permit modification 4-wheel drive access to well locations
Regulatory Requirements
Regulatory Requirements – NC 2C Rules Incorporated by reference into Solid Waste Rules Constructed with proper materials that will not
adversely affect monitoring and other construction specifics
Prevention of surface water infiltration or aquifer cross-contamination
Secured with locks and protective casing with valve Well ID tags (name, date, driller, non-potable label,
well construction info) Minimum 12 inches above grade stickup Well development required Well construction record submitted within 30 days
to NC DEQ
Regulatory Requirements
Regulatory Requirements – Other Federal (RCRA Guidance)
Technical Enforcement Guidance Document (TEGD) Handbook of Suggested Practices for the Design and
Installation of Ground-Water Monitoring Wells Other Guidance
Local requirements County permits Well fees (annual)
Regulatory Requirements
Dos Observe and document all drilling and well installation activities Decontaminate drilling materials before and between drilling
locations Use factory cleaned, sealed well construction materials Use threaded joints for well segments Clean gloves donned when handling well materials Use tremie pipe/adequate time for sand, bentonite, and grout
placement and curing Tell surveyor to use care when surveying top of casing (we
measure in parts per BILLION)
Regulatory Requirements
Don’ts No glues, solvents, paints during construction Generator/truck exhaust near well heads Introduce additional water to facilitate development in poor
producing aquifers (if you must, use deionized)
Well Maintenance
Required for life of monitoring plan (i.e., 30 years post-closure)
Required under Regulations (2C Rules) and Guidance Documents
Possible violations during inspection Comprehensive Landfill Audit Team
(CLAT) inspections Pad condition Locks Accessibility Positive drainage from wellhead
Well MaintenanceRoutine well inspections are key to identify potential compliance issues before they impact your data!
Well Maintenance Access (4-wheel drive) Vegetation
Do – hand clear Don’t use pesticides or herbicdes
Surface completion Do keep protective casings in working order (keep out bugs) Avoid flush mounts if possible Do keep well pads in good condition with positive drainage
from wellhead Don’t paint near wellhead (we test in parts per BILLION)
Well Maintenance Security and protection
Do use/painted bollards Do use pre-colored protective casings Do keep locked at all times Consider fencing for additional protection in unsecured areas Do keep roads clear for 4X4 access
Well Maintenance Legible label
Do use engraved tags Dedicated equipment maintenance
Do gauge depth to bottom to check for sediment build-up Do pull dedicated pumps and clean periodically
Well Maintenance
Other repairs Damage by heavy equipment Cracked pads Vandalism Infestation (e.g., spiders, stinging insects,
ants, etc.) If significant repairs are below grade,
must have licensed well driller and PG oversight
Well Maintenance
Development and Re-development Removes sediments/drilling fluids Lowers turbidity, washes well screen/filter
pack, and connects to aquifer Required by state guidance documents Pumps vs. bailers (depends on recharge) Containerize water if necessary
Well Maintenance
Why is development important? Turbidity is cloudiness or opacity in the appearance of a
liquid caused by solids, particles and other pollutants Turbidity measurements provide an indication of the clarity
of water and water quality Measured in Nephelometric Turbidity Units (NTUs) Can bias inorganic parameters in groundwater and
surface water high (which can lead to increased monitoring costs – up to triple)
Well Decommissioning
2C Rule Requirements Do have oversight/reporting by PG Do remove casing (if possible) or grout in place Do use bentonite/grout mixture Overdrill within landfill footprint (soils) and grout to ~
base grade
Environmental Monitoring Networks
Groundwater Surface Water
Leachate Methane
Stormwater
Surface Water Monitoring
Regulatory Requirements – NC Solid Waste Number and location of monitoring points vary with each site Do sample flowing water (don’t sample stagnant) Do keep streams free of debris Do note potential offsite impacts Do sample from consistent locations (signs)
Methane Monitoring
Regulatory Requirements – NC Solid Waste Must be fitted with stopcock valve with barbed
connection and label Do use engraved tag
Locations, spacing, and depth are site-specific Do place near property line and not at edge of waste if
practical Depths typically to water table or bedrock, whichever is
more shallow and screened to just below ground surface Clustered probes may be appropriate for complicated
geology and >45’ depth to water At compliance boundary and all structures (permanent
devices for occupied structures near waste)
Methane Monitoring
Regulatory Requirements – NC Solid Waste Probes must be installed/decommissioned by licensed well
driller, located by licensed surveyor and reports sealed by PE/PG
Surface water acts as barrier to methane migration Do maintain path for access Maintain for facility life and post closure
Stormwater Monitoring
Regulatory Requirements – NPDES General Permits Stormwater Discharge Outfall (SDO) = point of departure
from a discernable, confined, or discrete conveyance (e.g., storm sewer pipes, drainage ditches, channels, spillways, channelized collection areas) to waters of the State
Do sample during representative storm events within 30 minutes of first discharge Measurable storm event = actual discharge where
previous storm event was >72 hours prior
Stormwater Monitoring
Regulatory Requirements – NPDES General Permits Do sample from consistent locations (use signs) Do maintain best management practices (BMPs) in and
around SDOs Do record wildlife activity for potentially biased high fecal
counts
Leachate Monitoring
Regulatory Requirements – NC Solid Waste Semi-annual sampling & analysis required for specified
parameters (lined facilities) Do collect composite sample if multiple storage areas Do sample pre-treatment at consistent
locationsPOTW Requirements
Sampling requirements vary with individual waste water permits
Do sample post-treatment at consistent locations
Summary
Compliance networks must be designed to provide representative samples for site-specific characteristics
Keep networks functioning as designed and protect your investment – life of facility and post closure
Failure to maintain your network can result in significant cost increases, regulatory compliance violations, and negative public perception
Rachel P. Kirkman, PGAssociate and Senior Consultant
www.golder.com
336-852-49035B Oak Branch DriveGreensboro, NC 27407
Questions?
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