RBCA Closure at DNAPL Sites

The closure of sites with identified or suspected DNAPL (dense nonaqueous phase liquids) under the requirements of the Resources Conservation and Recovery Act of 1976 (RCRA), or the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA) has not been well defined. With respect to RCRA, the U.S. Environmental Protection Agency (EPA) has required that all contamination must be removed at closure such that no residual risk to human health or the environment remains. Therefore, even though many states administering the RCRA program have adopted or are considering Risk-Based Corrective Action (RBCA) procedures (including the statistical methods described in SW-846) for RCRA closure, the treatment of DNAPL is, at best, challenging.
The methodology for closure in CERCLA is described in "Risk Assessment Guidelines for Super-fund (RAGS)," which requires that risks above the National Contingency Plan criteria must be remediated, preferably by on-site or in situ destruction. Most risk-based Brownfield or voluntary cleanup programs do not provide any explicit allowance for DNAPL. However, while the ASTM methodology for RBCA in E1739-95 (ASTM 1995) does not explicitly treat the problem of DNAPL, a basic framework for DNAPL assessment is implicitly provided.
A uniform methodology for RBCA closure of VOC (volatile organic compounds) DNAPL sites can be used to achieve the program objectives of RCRA, CERCLA, and Brownfield or voluntary cleanup programs. The regulatory acceptance of the application of RBCA methods to DNAPL sites will require education and discussion, but the use of a uniform methodology should facilitate acceptance.     

The Geochemistry of Boron in a Landfill Monitoring Program

Ground water monitoring data collected during the past eight years at a permitted municipal solid waste (MSW) disposal facility located in the midwestern United States indicated fluctuations in typical leachate indicator parameter concentrations. Apparent trends in the data inferred leachate outbreak, generating suspicion as to the integrity of the landfill liner. Eight ground water monitoring wells were installed in three distinct geologic units at the landfill facility, including glacial drift, silurian dolomite, and a post-glacial peat fen, which is downgradient from the landfill. Piezometer nests were used to define ground water gradients at the site. Using boron as an indicator, the occurrence of analytes of concern in the downgradient monitoring wells were shown to be indicative of the natural geochemistry of site ground water. This work emphasizes the importance of understanding site hydrogeology during the interpretation of ground water quality data.