From: | Marsden and June Chen <doobage@localnet.com> |
Date: | Wed, 29 Sep 1999 10:07:15 -0700 (PDT) |
Reply: | cpeo-military |
Subject: | Re: Monitoring wells |
I'll attempt answers to your questions, but please realize that they will be bare-boned and will be DANGEROUSLY GENERAL. The answer to your questions depends on a couple/few realities. 1) Under Superfund or RCRA there usually are regulatory agencies as the USEPA and a State involved. So while the USDOD is a federal agency - government - the situation in the vernacular is: two cops watching another cop(?). There are established protocols for constructing ground water monitoring wells and there is general agreement on the boring methods, well casing/screen material (PVC, stainless steel, teflon, fiber glass) and other materials for the actual constructing a well. EPA and the States have descriptions available, although many States merely opt for EPA's; also, you are correct about the text book - there is an excellent reference, Johnson's Ground Water (?) which contains great "stuff" on well construction. 2) the regulatory agencies have the right to field oversight during well construction and many times send their engineers, geologists, technicians (EPA also uses contractors) to ensure that the construction protocols are observed. Many times the drilling sub-contractor will do a half-baked job if the cops are not looking over their shoulder. 3) There are also protocols for developing (jargon for discharging water from the well by mechanical means until an acceptable turbidity of the water is attained - includes shocking the water column for clearing out the fines from the sand pack placed around the screen) the wells and also for sampling them. Typically, the USDOD would be responsible for "actually monitoring wells" (your Q), but this must be done in accordance with the established protocols. Lately the USEPA and some States have toyed with and have been accepting water samples obtained by "low flow" techniques, i.e., a small tube is inserted down the well and a low volume pump started for the low flow. The expectation (as shown by some studies) is that the low flow will set up a near laminar condition, thereby creating no turbulence or eddies, etc., and eventually a representative sample will be obtained from the aquifer. 4) Because they are the cops, it is incumbent upon the USEPA the State to "insure that the monitoring in in fact done" (your Q) - USDOD would be responsible for the physical moontoring. 5) "who determines how long the wells need to be monitored?" (your Q) - it depends (mucho "it depends" in the environmental programs, you'll discover). For RCRA which covers active facilities, the wells may be used for long term monitoring and sampling could be done once each quarter or some other period - depends on what the cops want to measure ( USEPA has released the responsibilities of the RCRA program to some States - the so called "AUTHORIZATION"). There are some steps under Superfund - SI - site investigation, RI - remedial investigation, construction of remedy with long term monitoring. Usually under SI, one round of sampling is done to determine if contamination or no contamination is found. If no contamination is found, we close shop and go home; if contamination is significant, the program proceeds to the RI under which more wells are constructed "to determine the areal and vertical extent of contamination" (many times not enough wells are placed to meet this requirement under the National Contingency Plan, 40 CFR part 300). One round of sampling is done under the RI and if significant contamination is found, the program proceeds to selecting a remedy and long term monitoring. If the single round of samples under the RI produces questionable data or for some other reason the regulators and USDOD agree that further rounds are warranted then additional rounds are done. Long term sampling can extend for years primarily to ensure that the remedy remains effective - USEPA and the States like the five-year review, (an EPA invention I think - formerly we used to talk about a 30-year monitoring, but reality has set in and it is now five), so several rounds of samples could be accomplished in that time, and if the first five years indicate a continued need, then monitoring is done for another five and another five and another ... 6) will find reference and send later - Alzheimers has set in. | |
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