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Individual Individual APP Applications APP Applications Hydrogeologic Study Hydrogeologic Study Mason R. Bolitho, R.G. Mason R. Bolitho, R.G. July 15, 2010 July 15, 2010 SWVP-013320 APPLICABLE RULES Arizona Administrative Code Title 18,

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Individual Individual APP Applications APP Applications Hydrogeologic Study Hydrogeologic Study

Mason R. Bolitho, R.G. Mason R. Bolitho, R.G. July 15, 2010 July 15, 2010

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APPLICABLE RULES Arizona Administrative Code Title 18, Chapter 9, Article 2, Part A R18-9-A202

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R18-9-A202(A)(1)

Topographic map of the facility location and contiguous land area showing the known use of adjacent properties, all known water well locations within ½ mile and a description of well construction details and well uses

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A.R.S. §49-244(1)

“The pollutant management area is the limit projected in the horizontal plane of the area on which pollutants are or will be placed. The pollutant management area includes horizontal space taken up by any liner, dike or other barrier designed to contain pollutants in the

facility. If the facility contains more than one

discharging activity, the pollutant management area is described by an imaginary line circumscribing the several discharging activities.”

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R18-9-A202(A)(4)

A summary of past and proposed facility discharges, indicating: Chemical, physical and biological characteristics

Rate, volume, and frequency of discharges Location of the discharge and a map

utlining the PMA described in A.R.S. §49-

244(1)

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A.R.S. §49-244

“The point of compliance is the point at which compliance with aquifer water quality standards shall be determined. The point of compliance shall be a vertical plane downgradient of the facility that extends through the uppermost aquifers underlying that facility.”

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DISCHARGE IMPACT AREA A.R.S. §49-201

“‘Discharge impact area’ means the potential areal extent of pollutant migration, as projected on the land surface, as the result of a discharge from a facility.”

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R18-9-A202(A)(8)

A hydrogeologic study that defines the facility’s Discharge Impact Area (DIA) for the expected life of the facility . An abbreviated study or no study may be allowable. The study shall demonstrate: Discharge will not cause or contribute to an AWQS exceedance If an AWQS exceedance already exists, no additional degradation will occur

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R18-9-A202(A)(8)(b)

In the hydrogeologic study, ADEQ may require: A description of surface and subsurface geology, including all borings (i) The location of any surface water bodies (ii) Characteristics of the aquifer and units with limited permeability (iii)

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R18-9-A202(A)(8)(b)

The rate, volume, and direction of surface and groundwater flow including hydrographs & maps (iv) The precise location or estimate of the 100-year flood plain (v) Documentation of existing water quality in aquifers underlying the facility (vi) Any known soil contamination (vii)

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R18-9-A202(A)(8)(b)

Assessment of the potential to cause leaching of pollutants (viii) For a USF, assessment of leaching or migration of contaminated groundwater (ix) Any expected changes in water quality (x) Any expected changes in groundwater elevation or flow direction (xi)

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R18-9-A202(A)(8)(b)

A map of the DIA (xii) The criteria and methodologies used to determine the DIA (xiii)

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R18-9-A202(A)(9) and R18-9-A202(A)(10)

A detailed proposal for ALs, AQLs, DLs, monitoring, compliance schedules Closure or post-closure strategies

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R18-9-A202(A)(11)

Any other relevant information required by the Department to determine whether to issue a permit

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R18-9-A202(B)

An applicant shall demonstrate the ability to maintain technical capability and shall submit the following: Pertinent licenses or certifications Relevant professional training Relevant work experience

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POTENTIAL HYDROLOGY DEFICIENCIES

Hydrology that doesn’t make sense “We already submitted that!” Unsealed documents No/insufficient supporting data No AL/AQL/DL or monitoring proposal Inappropriate well construction Non-response responses No PMA or DIA maps No information on existing water quality

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POTENTIAL HYDROLOGY DEFICIENCIES

Insufficient hydrogeologic study No method of DIA determination Inappropriate POC locations No information on downgradient drinking water sources No evaluation of leaching potential No identification of uses of nearby wells No identification of local aquifer(s) No verification of disposal capacity or mounding analysis

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POTENTIAL HYDROLOGY DEFICIENCIES

No/insufficient discharge characterization Incomplete or no well inventory (e.g., only WELLS-55 database reviewed) No description of geology No information on nearby property ownership

r land uses

No groundwater flow direction or rate provided No information on construction of nearby wells

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POC LOCATIONS A.R.S. §49-244

The Director shall designate point or points of compliance for each facility receiving an individual permit. Point of compliance is in a vertical plane downgradient that extends through the uppermost aquifers. For a hazardous POC, the point of compliance is the downgradient limit of the PMA.

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POC LOCATIONS A.R.S. §49-244

For a hazardous POC well, an alternate POC location may be proposed by the applicant. The alternate location may NOT: Be located as to result in increased threat to a drinking water source Be located further downgradient than:

The property boundary An existing or potential drinking water source 750 feet from the edge of the PMA

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POC LOCATIONS A.R.S. §49-244

For a non-hazardous POC well, ADEQ shall take into account: Volume and characteristics of pollutants Practical difficulties Existing vs. new facilities Water conservation & augmentation Site-specific facility characteristics (e.g., hydrology, geology, soil chemistry, pollutant concentrations in the aquifer, climate)

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POC LOCATIONS IMPORTANT POINTS

Don’t confuse discharge compliance sampling points with POC wells POC wells must by statute be downgradient; in areas exhibiting mounding, POCs may be required radially Hazardous POC wells must be located at the edge of the PMA unless otherwise located using strict statutory limitations Non-hazardous POC wells shall be located using site specific characteristics

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POC LOCATIONS IMPORTANT POINTS

A POC does not necessarily have to be a physical monitor well, but may instead be a POC location only; this determination depends on site-specific characteristics If a POC location (rather than a well) is

riginally required, a POC well may be

required in the future if necessary (e.g., after exceedances of Alert Levels in facility discharges)

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POC LOCATIONS IMPORTANT POINTS

A POC well will typically be required to monitor an AZPDES discharge ADEQ may require additional POCs as needed in the future, depending on site characteristics and discharges

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Typical POC location

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TYPICAL GROUNDWATER MONITORING SCHEDULE

General chemistry parameters (major cations & anions, pH, TDS, EC)—quarterly Nitrate species—monthly Coliform bacteria—monthly VOCs—biannually Metals—quarterly Water levels—quarterly Data reported quarterly or semi-annually

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MONITOR WELL CONSTRUCTION

There is no one standard well construction, however: Screens should not be submerged in most cases Screens should not be too long Pump position is not very significant Filter packs should not be too long Modification of existing wells may be allowable

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Generic Construction

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Subm erged Screen

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Long Screen

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Long Filter Pack

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Monitoring I njection W ells

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Perched Groundw ater

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Open Hole Com pletion

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Sand in W ell Bottom

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Sand in W ell Bottom w ith Bentonite/ Grout

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DISCHARGE IMPACT AREA R18-9-A202(A)(8)(b)

The rule requires a DIA map and the methodology by which the DIA was identified. Models are generally used to establish the DIA Provide assumptions on which the DIA was based, e.g., hydraulic conductivity, gradient, effective porosity, discharge, etc. Provide map of DIA

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DISCHARGE IMPACT AREA POLLUTANT MANAGEMENT AREA

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DISCHARGE IMPACT AREA POLLUTANT MANAGEMENT AREA

Groundwater Flow Direction PMA Impoundment DIA POC

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HELPFUL HINTS

Use http://www.sahra.arizona.edu/wells/ for well locations and use data Use local aquifer test data when available Use ADWR modeling data when appropriate Recent GWSI water-level data may be available Use FEMA maps for floodplain analysis Pay close attention to monitor well construction Use ADWR imaged records for well completion reports and driller’s logs Read the rules!

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Questions?

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