New Leachate Sampling and Analysis Rules for C&DD FacilitiesBarry Chapman and Schuyler Schmidt

OAC 3745-400Effective January 1, 2013

Ohio’s Solid Waste and C&DD Program

Annual MeetingMay 9, 2013

ObjectivesProvide an overview of leachate sampling

regulations for existing facilities

Discuss how new requirements apply to existing facilities

Discuss how to review sampling results

OVERVIEW OF REGULATIONS

OAC RULE 3745-400-20

Leachate sampling and analysis and additional requirements to monitor ground water for leachate parameters

ApplicabilityOAC 3745-400-20

• All existing facilities subject to new rules

• Sampling and frequency based on –– Presence of leachate monitoring system– Presence of ground water monitoring system– Leachate recirculation activities

ApplicabilityOAC 3745-400-20(B)(3)

Does the facility have a leachate monitoring system? No

(Defined as any leachate collection system that includes sump risers or other access that can be used for collecting samples of leachate)

If a leachate monitoring system and a ground water monitoring system do not exist, then the facility is not subject to the new rules until such time that these systems are constructed. Includes:

– Constructed facilities not subject to ground water and leachate monitoring requirements (pre-1997)

– Unconstructed facilities subject to ground water and leachate monitoring requirements

ApplicabilityOAC 3745-400-20(B)(3)

Does the facility have a leachate monitoring system? No

• If a leachate monitoring system does not exist but a ground water monitoring system does exist, then the facility is required to monitor ground water for all parameters in OAC 3745-400-21, in addition to the parameters in OAC 3745-400-10.

(This includes facilities initially licensed in 1997 that have a ground water monitoring system but not required to construct a leachate monitoring system)

ApplicabilityOAC Rule 3745-400-20(A)(1)

Does the facility have a leachate monitoring system? Yes

The facility is required to monitor leachate, sampling for the 77 parameters in OAC 3745-400-21

How do these rules apply?Existing

monitoring systemApplicability

Leachate monitoring system (LMS) exists

Perform leachate sampling and analysis

Ground water monitoring system only (no LMS)

Monitor ground water for all parameters in OAC 3745-400-21 and 3745-400-10

Unconstructed facility Commence leachate sampling if/when facility and associated systems constructed

Pre-1997 facility – no monitoring systems required

Not subject to rule unless monitoring systems are constructed (e.g. expansion)

Summary of How New Requirements Affect Your Facility

Leachate Sampling and Analysis PlanOAC 3745-400-20(A)(2)

Key points– This plan not required to be submitted or approved by licensing authority

– Plan should be maintained on-site and available to Ohio EPA or licensing authority

– Plan needs to be completed before sampling leachate

– Follow the plan when sampling leachate

Conducting leachate sampling and analysis

OAC 3745-400-20(A)

• Leachate sampling and analysis must occur in 2013 and each following year throughout operations, closure, and post-closure.

Submit sampling and analysis resultsOAC 3745-400-20(A)(1)(e)

• Sample results shall be submitted to director and approved board of health no later than seventy-five (75) days after leachate sampling event

• Information to be submitted:– Field analysis results– Lab analysis of parameters listed in OAC Rule 3745-400-21– Identification of leachate parameters to be monitored in ground water (if

applicable)– Quality control data– Methods used and required forms

Review of sampling and analysis reports

• Ohio EPA and licensing authority are responsible for the review of these reports

What happens if parameter listed in 3745-400-21 is detected?

• For any parameter detected in leachate, the facility must expand ground water monitoring to include that parameter

• Detected parameters would be sampled at all ground water monitoring wells at the facility and analyzed at the next scheduled ground water monitoring event in accordance with OAC Rule 3745-400-10

What happens if parameter listed in 3745-400-21 is detected? Cont’d

• Continue to sample and analyze detected parameter in all future ground water sampling events

• Continue to conduct required leachate sampling and analysis for all parameters – even if detected parameter is also being monitored at all ground water monitoring wells

What happens if parameter listed in 3745-400-21 is detected? Cont’d

OAC 3745-400-20(B)(2)

• If Ohio EPA or the licensing authority conducts leachate sampling and detects a parameter, the owner/operator may be required to add that parameter to the facility’s ground water monitoring parameter list

OAC RULE 3745-400-21

Construction and demolition debris facility – leachate parameter list

Leachate parameters• Seventy-seven parameters:– Total metals, cyanide - unfiltered samples– Inorganic water quality parameters– Other inorganic parameters– Volatile organic compounds

Identification of Leachate Parameters to be Monitored in Ground Water

• The facility should provide a list which clearly states which leachate parameters must be monitored in ground water in the next ground water sampling event.

• To check this list for accuracy, it is necessary to compare the leachate parameters the facility has stated with the results from the lab report.

Identification of Leachate Parameters to be Monitored in Ground Water

• We will look at sample lab reports to illustrate how to check for accuracy

Lab Report 1 Here leachate parameters are shown • The Sample Result is the value found for that parameter • Reporting Limit (known as “Rpt Limit” here, sometimes

abbreviated “RL”, or also, more technically known as PQL)• Barium and Beryllium have actual sample results• However, only one is a “detection”

Detection Accuracy• The important this to remember is that a

“detection” is a Sample Result is that is equal or higher than the reporting limit.

• For example, on this example, Barium has a sample result of 0.167 mg/L and a reporting limit of 0.002 mg/L, thus making it a detection.

Detection Accuracy Continued• In contrast, for Beryllium, the sample result is

< 0.000400 and the reporting limit is 0.000400. If the sample result is less than the reporting limit, this would not be a “detection” for the purposes of C&DD sampling.

Detection Accuracy Continued• This means that the lab was not able to detect

the leachate for Barium at this reported level, and that the value of the leachate is at some undetermined level below (<) 0.000400.

• Different labs may have different ways of showing this same concept. Let’s look at another lab report.

On this 2nd lab report from a different lab, compare Arsenic, Barium, and Beryllium:

Arsenic and Barium have values listed in the “Result” column, while Beryllium does not. However, Arsenic is still below the Reporting Limit (RL)

For Arsenic, the result is 0.00598 which is less than the Reporting Limit (RL) of 0.0100. This is not a “detection” for the purposes of the CDD rules. To demonstrate this, the Letter J is listed in “Qual” (Qualifiers).

Compare Arsenic now to Barium. For Barium, the Result 0.225 is clearly higher than the Reporting Limit (RL) 0.0100. There is no qualifier listed Thus, Barium is a detection for the purposes of CDD leachate. As for Beryllium, no result is listed, which means that it is not a detection.

Here, again, the same concept with Antimony and Thallium: With Antimony, no Result is listed. This is not a detection. With Thallium, a Result of 0.000400 is listed, which is less than the RL of .00100. The “J” qualifier is listed again. Thallium is also not a detection for the purposes of CDD leachate.

The technical reason for this situation is that the value for Thallium has been found to be higher than the “MDL” (Method Detection Level) of .000250 while still lower than the RL of .00100. However, this is not a level quantified with statistical significance, and thus the value must be equal or higher than the RL to be a detection for the CDD rules.

If the facility uses “PQL” instead of Reporting Limit, do the exact same

thingIf the lab reports the PQL (or Practical Quantitation Limit) instead of the RL (Reporting Limit), the samelogic and procedures apply. PQL and RL are interchangeable for the purposes of the CDD leachate rules. For example, if the Result is higher or equal to the PQL, then it is a detection for CDD leachate rules purposes.

Detection Accuracy Summary• In sum, check the list submitted by the facility to

make sure that they have accurately identified which parameters should be monitored in ground water. To do this, compare the Result to the Reporting Limit (RL, or PQL if given instead). All parameters with one or more Results equal or higher to the RL should be on the ground water monitoring list.

Detection Accuracy Summary• Also, check the parameters not listed for Ground

Water monitoring to make sure that the facility has not missed any parameters that should be placed on this list. Again, all parameters with one or more Results equal or higher to the RL should be on the ground water monitoring list.

What to do if the facility has missed a parameter

• If the facility has failed to include parameters which should be placed on ground water monitoring, send a letter to the facility stating that it has made a mistake, and give them the parameter, Result, and RL. Then, tell the facility that they must place the parameter on ground water monitoring for the next ground water sampling event. A sample letter template is available.

Cross-Checking the Ground Water Monitoring List with the Ground Water sampling report

• It is imperative to cross check the list of leachate parameters to be monitored at the next ground water sampling event with the actual ground water monitoring results at the next ground water sampling event.

• This is to ensure that the facility has complied. • If they have not complied, then steps must be taken. Now,

back to Barry to explain what should be done in those circumstances.

Contact Info for Detection Accuracy and Lab Reports Interpretation

• Please feel free to contact me if there are any questions when reviewing the lab reports or the list of parameters to be placed on ground water monitoring, or any other relevant questions.

• Schuyler Schmidt – (614)728-5371 Schuyler.Schmidt@epa.state.oh.us

QUESTIONS?

Dist

rict O

ffice

s Central District Office

Northeast District Office

Northwest District Office

Southeast District Office

Southwest District Office

(800)686-2330

(800)686-6330

(800)686-6930

(800)686-7330

(800)686-8930

Questions? Call Barry @ (614)728-5344 or email barry.chapman@epa.ohio.gov

Compliance and Inspection Support – Central Office:Barry Chapman

Ohio EPADivision of Materials and Waste Management

P.O. Box 1049Columbus, OH 43216-1049