Monitoring Your Landfill Chapter 08

1. Monitoring Your LandfillChapter 08 Kentucky Department of Environmental Protection Division of Compliance Assistance 300 Fair Oaks Lane • Frankfort, KY 40601 Phone: 502.564.0323 • 800.926.8111 • Fax: 502.564.9720 Email: envhelp@ky.gov • Website: dca.ky.gov

2. Would this be suspicious to you if you were the Landfill manager or operator?

3. Would this be suspicious to you if you were the Landfill manager or operator?

4. Chapter 08 General Objective Explain the monitoring procedures associated with each type of landfill (with emphasis on groundwater and surface water monitoring).

5. Chapter 08 Specific Objectives • Understand Environmental Performance Standards (EPS). • Explain the purpose and the requirements of surface water and groundwater monitoring. • Know the importance of proper sampling and the considerations that should be given to surface water and groundwater.

6. Chapter 08 Specific Objectives • Understand Data Submittal Requirements. • Understand the recordkeeping requirements • Comprehend the assessment monitoring and corrective action process. • Understand explosive gas monitoring systems and requirements. • Understand the primary ways a landfill can contaminate groundwater and surface water.

7. Environmental Monitoring • All waste sites and facilities must comply FULLY with the EPS in . . . • 401 KAR 47:030 (for solid waste sites) • 401 KAR 30:031 (for special waste sites)

8. Environmental Monitoring • Environmental Performance Standards (EPS) • Pollutantsshall NOT be discharged into surface waters of the Commonwealth • Groundwater shall NOT be contaminated beyond a point of compliance for the facility in excess of drinking water Maximum Contaminant levels (MCLs) • Concentrations of explosive gas shall not exceed 25%LEL for methane in facility structures and shall not exceed 100% LEL for methane at the facility property line.

9. Environmental Monitoring Monitoring Plans Included in Permit Applications • Surface Water Monitoring Plans • Groundwater Monitoring Plans • Methane Monitoring Plans Landfill Type • Special Waste • Residual • CDD • Contained Each facility MUST BE MONITORED in accordance with the applicable REGULATIONS, APPROVED PLANS and the PERMIT.

10. What are the surface water and groundwatermonitoringproceduresassociated with each landfill type?

11. Surface Water Monitoring • Surface water sampling • Allows for verification that leachate is NOT entering surface water • Facility operations are NOT otherwise adversely impacting surface water • Surface water monitoring points must be located to characterize the quality of water unaffected by the landfill and water that leaves the landfill in surface drainage.

12. Surface Water Monitoring • EVERY landfill should have • AT LEAST one upstream (background) monitoring point • AT LEAST one downstream (compliance) monitoring point

13. Surface Water Monitoring • UpstreamMonitoring Point • Upstream from the landfill OR • Outside of the effects of waste placement for use in background comparisons • May be a SURFACE STREAM

14. Surface Water Monitoring • DownstreamMonitoring Point • Located on the inlet side (landfill’s surface water run-off ditches) of the surface water sediment structures to monitor the landfill runoff water BEFORE it enters the sediment ponds • Can be done in the RECEIVING STREAM

15. Surface Water Monitoring • Grab Samples • Collected at previously specified points approved by the Division, on a QUARTERLY BASIS • Parameters • Chlorides • Sodium • Sulfate • Total Organic Carbon (TOC) • Iron • Specific Conductance • pH • Solids (TSS, TDS, TS) Chemical Oxygen Demand • Other parameters in the permit

16. Surface Water Monitoring • All facilities with storm water runoff structures and point-source discharges are required to have a KPDES permit from the Division of Water. • Documentation that the application has been submitted will be required during the Division of Waste Management permitting process.

17. Groundwater Monitoring • The groundwater monitoring system approved within the application is meant to allow an accurate assessment of the groundwater quality and characterize groundwater flow.

18. Groundwater Monitoring • Groundwater monitoring requirementsdiffer for each type of solid waste or special waste site or facility

19. Groundwater Monitoring • Residual, CDD, Contained Landfills • must have at least 1 background well hydraulically upgradient from the disposal area • must have at least 3 downgradient monitoring wells with the Division’s approval • Special Waste Landfills • must have at least 1background well hydraulically upgradient from the disposal area • must have at least 2downgradient monitoring wells with the Division’s approval

20. Groundwater Monitoring • The Division may approve springs in addition to, or instead of downgradient wells. • An alternate monitoring plan may be used if approved by the Division.

21. Groundwater Characterization • 401 KAR 47:180 • A groundwater characterization shall contain • Thechemical characteristics of the uppermost aquifer down to and including the lowest aquifer that may be affected by the site or facility. • Results of analysis of at least two (2) samples of groundwater collected at least 30 days apart from the site before waste placement for the parameters listed in 401 KAR 48:300, Section 10. • Special Waste Landfills must perform groundwater characterization according to 401 KAR 45:160, Section 7.

22. Groundwater Characterization • Improved background characterization • Includes two years of quarterly data, or eight samples per well, before waste disposal begins • More monitoring data collected prior to waste placement can facilitate the use of an intra-well statistical method, which may reduce false positives that occur due to geologicaland chemical variability between upgradient and downgradient wells.

23. Groundwater Monitoring Residualor Special Waste Landfill applicants should do an industrial waste analysis for the chemical parameters based on a review of raw materials feed dataor an analysis of the chemicals from one of the following: • The “Long List” of parameters for contained landfill assessment or characterization monitoring available in 48:300, Section 10(3)(b), • The Hazardous Constituent List in 40 CFR 261 Appendix IX, • The parameters included in the NPDES Priority Pollutant List

24. Groundwater Monitoring Detected chemical constituents could become the characterizationor assessment list while the top two or three concentrated metals or organicswith common indicators could make up the detectionor quarterly (or, semi-annual for special waste) monitoring.

25. Residual Landfill Groundwater Monitoring Parameter Requirements

26. CDD Landfill Groundwater Monitoring Parameter Requirements

27. Contained Landfill GroundwaterMonitoring Parameter Requirements

28. Contained Landfill GroundwaterMonitoring Parameter Requirements

29. Special Waste CCB Landfill Groundwater Monitoring Parameter Requirements

30. Sample Collection ALL landfills that are required to monitor groundwater and surfacewater must have samples collected using proper and permitted collection procedures. The landfill manager must ensure proper collection techniques are followed so that the sample is NOT contaminated.

31. Data Submittal All lab results must be submitted within 60 days of the sampling eventor 15 days after receipt of the statistical analysis–whichever is sooner.

32. Data Submittal • Statistical analysis MUST be performed SEPARATELY for EACH • Parameter • Well • Sampling Event • Used to determine if there has been a significant increase over background values for each parameter that lacks an MCL

33. Data Submittal If laboratory delays are encountered, a letterrequesting an extension must be sent to the Solid Waste Branch, Permit Review Section

34. Recordkeeping The owner or operator shall maintain records from all groundwater monitoring wells and associated groundwater surface elevations, for the active life of the facility, and for the post-closure care period as well.

35. MCL or Statistical Exceedance • Owner or Operator MUST notify Division within 48 hours of analysis receipt • Arrange to split confirmation samples within 10 days ofreceipt of analyses • Drinking Water Supply Affected • IF probable contamination source is landfill • Facility shall provide alternative drinking water supplies to all affected parties within 24 hours of the notification of the Division

36. Assessment Plan • If the confirmation sampling verifiesthat an exceedance has occurred, the landfill must prepare a groundwater assessment plan, and submit it to the Division within 30 days. • Assessment Plan must specifythe way in which the landfill intends to determine: • the existence, quality, quantity, areal extent, and depth of groundwater degradation, and • the rateand directionof migration of contaminants in the groundwater.

37. Assessment Plan • The assessment plan must be implemented within 60 days of its approval by the Division. • If the Division determines that the assessment plan is inadequate, it can either • Issue a Notice of Deficiency (NOD) or • Modify the plan and approve it as modified. • The Division may require abatement measures prior to the approval of the assessment plan.

38. Assessment Report • Within 90 days of the implementation of the assessment plan, the landfill must submit an assessment report • Summary of the data collected in the assessment investigation, • Analysis of the data, and • Recommendations on the necessity of abatement.

39. Assessment Report • Within 15 days of approval of the groundwater assessment report, the Cabinet prepares a public notice for the owner or operator to advertise in the newspaper. • The notice must summarize the findings of the report, including proposed remedies, and allow for a 30-day comment period. • 401 KAR 48:300, Section 8

40. Corrective Action Plan • Within 120 days of the approval of the assessment report, the landfill must submit a corrective action plan. • The methodsthat will be used to abate the groundwater contamination • The actionsthat will prevent further releases from the facility • The processby which affected water supplies will be restored or replaced; and • Any other measures necessary to protect human health and environment

41. Corrective Action Plan • Corrective action must be continued • until parameters with primary MCLs are lowered below MCLs, and • until parameters without primary MCLs are returned below statistical background • 401 KAR 48:300, Section 8(14)

42. Explosive Gas Monitoring • Landfill gas forms in the waste mass and migrates through subsurface pathways from areas of higher pressure to areas of lower pressure. • In the environment, landfill gas most commonly migrates through unsaturated soil, sand, or gravel, especially when the pathway is overlain by less permeable materials.

43. Explosive Gas Monitoring • Contained landfills must monitor for explosive gas in accordance with the permit to ensure that gas concentrations at the property line do not exceed 100% of the Lower Explosive Limit (LEL), and gas concentrations in facility structures do not exceed 25% of the LEL, as required by 401 KAR 47:030 Section 11.

44. Explosive Gas Monitoring • The landfill gas monitoring plan submitted in the permit application should evaluate potential subsurface migration pathways and potential receptors such as nearby residences or buildings.

45. Explosive Gas Monitoring • Facility structures must be monitored both continuously and quarterly in accordance with the approved plans. • Continuous explosive gas monitors must be installed in each onsite building and quarterly monitoring must be conducted underneath or in the low area of each structure.

46. Explosive Gas Monitoring • Landfill gas may be monitored along the perimeter of the landfill site with a handheld explosimeter using permanent gas monitoring wells and / or barhole punches. • Permanent gas monitoring wells targeting the most likely migration pathways are preferred.

47. Explosive Gas Monitoring • When monitoring shallow zones with permanent gas monitoring wells, monitoring at the wellhead is generally appropriate. • For deeper wells with thick unsaturated zones or those with multiple potential migration pathways, a drop tube may be required.

48. Leachate Contamination of Groundwater General Leachate Composition • Inorganics: Calcium, Magnesium, Iron, Copper, Manganese, Barium, Arsenic, Zinc • Ions: Chloride, Sodium, Boron, Alkalinity • Nutrients: Nitrogen (Ammonia/Ammonium, Nitrate); Phosphate • Organics: VOCs, Pesticides.

49. Leachate Contamination of Groundwater

50. Leachate Contamination of Groundwater