New Leachate Sampling and Analysis Rules for C&DD Facilities Barry Chapman and Schuyler Schmidt OAC Effective January 1, 2013 Ohio’s Solid Waste and C&DD Program Annual Meeting May 9, 2013

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

Applicability OAC 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 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

Applicability OAC (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 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

Applicability OAC (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 , in addition to the parameters in OAC (This includes facilities initially licensed in 1997 that have a ground water monitoring system but not required to construct a leachate monitoring system) 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 , in addition to the parameters in OAC (This includes facilities initially licensed in 1997 that have a ground water monitoring system but not required to construct a leachate monitoring system)

Applicability OAC Rule (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 Does the facility have a leachate monitoring system? Yes The facility is required to monitor leachate, sampling for the 77 parameters in OAC

How do these rules apply? Existing monitoring system Applicability 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 and Unconstructed facilityCommence 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 Plan OAC (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 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 (A) Leachate sampling and analysis must occur in 2013 and each following year throughout operations, closure, and post-closure.

Submit sampling and analysis results OAC (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 – Identification of leachate parameters to be monitored in ground water (if applicable) – Quality control data – Methods used and required forms 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 – 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 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 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

What happens if parameter listed in 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 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 is detected? Cont’d OAC (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 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 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. 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 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” 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 mg/L and a reporting limit of mg/L, thus making it a detection. 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 mg/L and a reporting limit of mg/L, thus making it a detection.

Detection Accuracy Continued In contrast, for Beryllium, the sample result is < and the reporting limit is 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 (<) Different labs may have different ways of showing this same concept. Let’s look at another lab report. 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 (<) Different labs may have different ways of showing this same concept. Let’s look at another lab report.

On this 2 nd 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 which is less than the Reporting Limit (RL) of 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 is clearly higher than the Reporting Limit (RL) 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 is listed, which is less than the RL of 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 while still lower than the RL of 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 thing If the lab reports the PQL (or Practical Quantitation Limit) instead of the RL (Reporting Limit), the same logic 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. If the lab reports the PQL (or Practical Quantitation Limit) instead of the RL (Reporting Limit), the same logic 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. 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) 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)

QUESTIONS?

District Offices Central District Office Northeast District Office Northwest District Office Southeast District Office Southwest District Office (800) (800) (800) (800) (800)

Questions? Call (614) or Compliance and Inspection Support – Central Office: Barry Chapman Ohio EPA Division of Materials and Waste Management P.O. Box 1049 Columbus, OH Compliance and Inspection Support – Central Office: Barry Chapman Ohio EPA Division of Materials and Waste Management P.O. Box 1049 Columbus, OH