DRAFT

DRAFT
Sud;' Mi:ud Waste Ludrill
Grouadwater Moaitorin& WeD System
uti Procra- OnrriPt Review
12112/07
On Malcl11. 2007. Ci!i= Ac:tiou New Mcxiw (CANM) _ted that information pertaining
to ground_ mooilO!ing for the Sandia National Labor.IOI)', New Mexico (SNL) Mixed
W'ISI< Landfill (MWL) be "';'wed by the Environmental Prolec:tioo Agency (EPA). Citi=
Action asked th .. written information and CD they provided be forw8rded 10 the EPA National
Risk Managellu:nt Resean:h Lahomol)' They also _ed thaI NRMRL review the:
November, 2006, New Mexico Environment lXpartment (NMED) rq><>rt by Mr. William Moats,
el aI . entitled. "Evaluation of the Represcntativeoess and Reliability of Groundwater Monitoring
Well Data."
Citizen Aetions request stated that they believe the monitoring well network cannot provide
reliable and representative water samples for numerous reasons. and that the November. 2006.
NMED rq>Ort contradicts earlier rq><>rts by NRMRL staf[ They also pro";ded DumeroUS
additional and telephone correspondence with groundwater information relating to the
MWL.
After considering CANM's request. EPA Region 6 conducted the: review of this infonnation as
part of our OV"';ghl t;esponsibility for NMED's federally authorized RCRA program. The
NRMRL wu consulted on various tcchniw pouudwatcr issues, however.
We did not conduct a rigorous teclutical review of the November. 2006. NMED report because
the State cODduC1cd their analysis in a manner similar to the methods used by NRMRL in a
previous ofLANL data. Further. because the NMED has already directed SNL to replace
a number ofMWL monitoring wells due to factors such as well screen corrosion and dropping
water leVels. at this pow we prefer to conduc1 detailed evaluations on data from. new wells based
on groundwater monitoring objectives aod data requimneots, should that become n=ary.
We reviewed the overall MWL grouodwatcrmonitoriog system in order to detemrine its efficacy
in detecting contamination. We reviewed weU locations. depth of wells and well screens, purging
and sampling methods. downhole videos. and analytieaJ results.
The original mOnitoring wells were installed based on geology and regional and local
groundwater flow known at that time. Population growtb and changes in land usc in the:
Albuquerque area since this monitoring network was initially installed has probably altered flow
and aquifer levels due to increased pumping. Further study (more data over time) has
improved the understanding of geology and groundwater mechanisms. These factors, combined
with the age and degradation of some wel15, has led us to updates to the monitoring
methods and oetwork. which the NMED has already begun to implement.
The scope of our review encompassed fundamental aspectS ofthc: groundwater monitoring ;
system and the effectiveness of upgrades to the existing system involving the placement of new
monitoring wells. Specifically. we reviewed information pertaining to: (0 ,he MWl conceptual
hydrogeologic model and whether the eooccptuaI model is consistent with published infonnation
and field data; (ii) published information on regional groundwater flow directions (Santa Fe
aquifer) and stresses on the regioo.a.l system; (iii) site specific information on the locations of
existing MWL monitoring wells with respect to flow infonnation contai.ned in SNL reports; (iv)
well screen depths and intervals; (v) consistencY of weI! depths with the site conceptual
hydrogeologic (vi) groUndwater flow directions and gradients in the two main saturated
units (te, alluvial faD and Rio Gronde strata); and, (vii) possible improvements to the monitoriJig
well netWOrk including potential new well locations.
BackgrcuDd .
The MWL operated from 1959.to 1988. It is small. 2.6 acres., and the landfiU bottom is located
more than 400 feet above the Regional aquifer. The MWL bss "fairly wcl!-documented
inventory of contents comprised mainly of laboratory wastes. Precipitation for the area is less
than 1 Q incheslyear and there are no significant surface water reatl..ll'eS in the- site vicinity.
CANM:
NMED:
EPA:
The MWL should be a regulated unit. not a S WMU.
Solid Waste Management Unit.
No comment. in State court.
Th.decision to trest the MM' ", a SWMUwu original!y made by EPA in 1993 befure thi>
site's regWllIory responsibility passed to NMED in 1996. For EPA to revisit that decision '" this
late date would serve no useful purpose since we believe the site has received adequate attention
through the corrective action process. In addition. since Citizen Action brought this matter
before the State Court of Appeals in October, 2006. it should be allowed the opportunity for
resolution through the-State administrative and judicial processes.
CANM:
NMED:
EPA:
The is not afforded opportunity to participate in MWL decisions.

Continue discussion with NMED.
in general, EPA believes that NMED has provided adequate public notice and opportunity for
participation in regulatory activities related to the MWL. More specifically. NMED has routinely
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placed MWL documents on its, website and numerous opportunities have been provided for
forinal public comment on MWL proposals and plans. For example, the dec",ion 10 place a
cover over the MWL, wtUle maintaining long term monitoring. was made after several yeari of
public meetings. Study9 and diKussion. Participanb included. formal Citizen's Advisory Soan!
(CAB), NMED, DOE, SNL, various indcpeudcnt tccluUcal exptlts, as woU as local inletOSted
citizens. The EPA was au ex officio participant in the CAB. Several possible scenarios were
discussed before the tiDal cover and monitoring plan were selected. 11tc purpose of the cover
was 10 toduc:e t)le possibility of """Wninalion tuehing tbc groundwater through mcclumisms
such as erosion. WIlIer infiltntion, and animal intrusion.
Citizen Action bas also demanded that EPA dln:ct NMED 10 release documents such as the
"Ted! Law repotI." Citizen ActioD is a party to the lawsuit con<:eming NMED', release of that
documeni. and this matter ia abo CUI'TetI1ly being addressed through the New Mexico state court
system. lberefore, EPA considers this an issue of State law and we wil1 anow it to be resolved
through tbc State judicial proc ....
Concerns about specific issues shoukl be raised during the public comment period and addIessed
through the channels ofNMED', fedctaJly authori=! RCRA program. thus utilizing
the proper Stale administrative andjudicial processes. However. since the MWL is currently
addressed as a SWMU in the facility pennit, the nature of the permitting process does not
specific details of every indivicfual decision to be opened to public commcnt. Instead. specific
concerns should be addressed during gCoem public comment pcrlods. such as that for the Long
Term Monitoring aDd Maintenance Plan,. which is currently opcu for comment.:
CANM: Wclls should use a low flow purge and sample method.
NMED: CUlTCIlt sampling method is adequate and representative.
CurmtI sampling uses Bennett pumps, with purging tales of approximately O.S to 1.0 gpm. The
pumps abo utilize. small valve to obtain volatile samples. There is no indication that the MWL
wells have been dama&ed by this method. The facility is sampling appropriately and doing the
best they can under tbc existing conditions. The NMED has done their own sampling to see the
field C9Ildilions and obtained the same results. It is hoped that the new wolls will have be_
screcosand volum.eofwatet since thc wells don' t producc as well as in the past. The NMED
rosy look into difI'e=Il pumps but must weigh ifit', worth the expense to the facility. .
EPA: Continue further discussion with NMED.
"Low floW" is considend to be a flow rate oflC$S than 0.5 l.Jmin (0.13 gpm). The purpose for
low flow purgioa is to minimize the volatilizatioD ofVCC,. reduce turbidity wroch may give
more Rliabte results for mctab" and also to miDimizc the possibility of damage to the well screen
or sand pack. the purging and sampling methods must be appropriate for the geologic
and well conditions. Although EPA gmerally J'C1;ommeods that facilities try to imptemenllow
flow techniques. EPA Bulletin No. QAD023. Purging and Sampling of Groundwater
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Monitoring Wells," dated October 15, 1997. states that. "The lowflow pw-ging and sampling
method is not appropriate_for use in all hydrogeologic regimes, and particular groundwater
monitoring well designs may make the method unsuitable ....... 1nerefore. we ruommend that
NMED consider use of low flow pumps, if conditions warrant Additionally, intend
observe aD upcoming sampling event to observe field conditions..
A 1996 study of several monitoring wcUs at Sandia (S.S. Collins and G.A. &;Iey) found that
VOC samples in two oul of four wells wet< affec:t<d by higher pumping ra!<s compattd to du:
low-flow purging method. These tests were not conducted at the MWL. 1n a phone conversation
with du: Iletw:It Co. (Amarillo, TX) pertaining to the ability of their pumps to ounduct low,.tlow
purging and sampling. du: company said that low flow technique could be performed by adding
a specific piece of equipment to the pump to reduce the flow rate enough to meet the low flow
purging and sampling requirements.
;. "'" Wben using the low flow purging method, du: facility sbould be careful in detennining wben du:
. a groundwaIer panmeten bave stabilized, espeoiAIIy on wells with lonser screen lengths and larger
, = diameters. Historical information from past purgings should be evaluated in determining du:
i stabilization of tho groundwaler parameters.
__ Spud ofGroUlldweUr ill tit. r ... Aq"ifos
....
CANM: Groundwat., flow i$ 001 adequately understood and pumping ..... are needed.
Usc of the average value ofhydraulie conductivity measured in three wells to calculate rate of
groundwater travel is incorrect.
NMED: Flow is adequately understood.
EPA; Continue further discussion with NMEO.
Regarding the AF aquifer, the typeS of data acquired here 00 grounclwatcr velocity an: typical of
landfill sites in Region 6. In tho AF aquifer, a pumping test wu performed on MW4 in 1994 on
both du: upper and lower sc:reens. An inflatable packer wu used to bydrouIica11y isolate the
upper and lower-screened intervals. Each screened interval was pumped wbiIe the other __
intczval was isolated.. Results indicawi that there was DO drawdown observed in either
and then: was also no drawdown in adjacent observation wells. In 1994. monitoring wells MW1
4 had the waitt levels monitored using presNre transducers during purging and sampling o(the
wells; hydraulic conductivity values were calculated from the drawdovm and recovCl)' data.. In
200 I, slug tests were pcrformed 00 the AF aquifer wells. From these tests. Sandia calculated the
average tinear flow velocity for the AF faeies at 0.17 ft/year. However. actual flow velocities of
contaminated plumes an: often qujte a bit higher than calculated average velocities due to aquifer
heterogeneity and prcfened paths in the aquifer. for when reviewing the historical
nitrate contamination found in the AF aquifer wells (BWI, MW1, MW2. MW3) .... note that the
acruaJ flow velocicy must be greater than the calculated value, otherwise the elevated nitrate
would DOt be found in all the AF aquifer wells. Note that this assumes the sowce for the DWate
is to the east-northeast ofthc MWL, as claimed by Sandia.
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EPA m:ognizes that there is ample published docwnentation on gradients and vc:Jocities for the
Santa Fe aquifer for regionaJ as5C$sments and local assessments when available. However.
conceming the ARG aquifer at the MWL. the flow. velocity is less certain due to the fact that
there is only one well ~ n e d solely in that aquifer, MW6.
CANM:
NMED:
BodgrolUrd WtlIs
Two beoI<ground wells are needed, one in each aquifer.
One well in uppermosl 'aquifer,
EPA: Only one J>ackground well is needed and it should be in the M facies, which is
considered the uppmnost aquifer under RCRA This well shouJd be located on the eastern. up-
gradient, side of the MWL.
Low Level Tritium Anllipis
CANM: Low levellritium analysis should be don. at all wells. Wells should be installed
within the MWL
NMED: Not necessary, sampling is now done for tritium and levels are below the Mel.
EPA: Continue further discussion with NMED.
W_ sampl<s an: aiI<ady tested for lritium and results are below the Federal drinking water
s1an.dard (MeL) of20,OOO piCIL, This analytical m>od has. repor!ing limit 0(200250
piC/L. The Low Level with Elec!rolytic Enrichment (LLEE) method has a detection limit of
abeut 03 pCiIL. Tritium is. very mobile constituenl in groundwa .... and may be a good tllICer
fur contamination. The NMED has successfully, used the low level analytical method at LANL
for several years and recently used it for samples -at several wells at Sandia. Therefore. we:
recommend that NMEQ consider use of the low level tritiwn analytical method at the MWL. at
least periodically.
The landfill inventory indicates that ttitium-contaminated material was placed,in the MWL until
its closure in 1988. Approximately 204.000 gallons of tritium --contaminated water were reported
to have been disposed of in the Mw.L in 1967. ' However. since tritiwn has a half-life of only
12.3 years. and several dctadcs have passed since any waste was placed io the landfill. it is
unlikely thai: a signi1icaol amount of tritium contamination win rucb the deep aquifer at this
point.
Drlllilfg Wdis w.iJltin I h ~ LandJiU
CANM: Need wells within the- MWL to. define hotspots."
NMED: No.
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EPA: No.
Detection monitoring wells are normally located around the perimeter of a landfill. A weU inside
a landfill would not be part of a monitoring well pelWork to detennine if there are releases
outside the landfill. Drilling through known q>ntamination would also increa5c the chances of
,cross contamination between shallow and deeper zones and woUld pose a risk of creating a direct
conduit for contamination from the surface to the aquifer. We recognize that DOE bas placed
groundwater monitoring wells at other sites inside waste management areas (e.g.s Savannah
River); however, RCRA regulations do not require groundwater monitoring within a landfill.
Instead, the groundwater detection monitoring wells should be located at the point of
which is the hydraulically doVlngradient edge of the unit or waste management area. Further.
because of the MWl.'s smaU size (2.6 acres). we do not recommend wells within it
DriJling.Methodsfor We111nstaUanon
CANM: Drilling meth09s (mud) have compromised all wells.
NMED: Wells were adequate and representative.
EPA: Continue further discussion with NMED.
The preferable drilling method for purposes of groundwater sampling is the ODe that introduces
the (east amount of foreign matter into the aquifer. fOt' both mechanical well damage from
pore plugging) and chemical reasons. fa<:ility should evaluate and propose the best
method(s) based. on the site geology. We drilling boreholes Without using bentonite
or organic additives within screened intervals. Additives may be used in interVals above the
target monitoring zone if telescoping casing constructions are used and the bole is
before drilling the final .footage within the interval to be screened. The facility should
minimize the time between drilling and 'Well development
We expect that installation of new wells and the subsequent new data will alleviate this coocem.
In the real world. bowever, drilling and sampling wells is never "perfect" since unavoidable
difficulties are often encountered. The facility is expected to use proper methods and do the best
they can under the existing circumstances and understanding of the site geology.
Aquift, Cltaraderislics
CANM: A pwnping test must be designed to thoroughly characterize and measw-e the
speed of groundwater travel in the productive (ARG) aquifer.
NMED: It is appropriate to sample the uppermost saturated zone. the AF Facies.
EPA: Continue furthcr discussion with NMED.
There are two distinct aquifers at the Mixed Waste Landfill. the alluvial fan (AF) and the
ancestral Rio Grande (ARO). This distinction is evident in the clearly different potentiometric
6
surfaces for the two units. The AF aquifer has very low average hydraulic conductivity (1 .81
ftlday) and appears to have some beds with vertical hydRulic conductivity low enough to act as
confining beds. It appears that the ARG facies is more productive and that wells screened in
both ",nos willlikeJy be controlled" by the ARG facies. ' .
The flow directions are different for each aquifer. The AF aquifer flow di:reetion is to the wm..
southwest (based on our review of over IS ya.rs of data), while the ARG aquifer flow direction
is to the w.st-northW<Sl (based on USGS infonnatioa and the Sandia 1990 to 2001 Groundwater
Reports). We also ootod that elevatod nillalc (4-5 ppm) is foUDd in the monitoring _lis
screeued in the upJX!Imwt portion oftbe AF aquifer, but iJ not found or is in much lower
concentrations in the wells (1-2 ppm) screened in the ARG aquifer. or wells screeued in both
aquifers.
CANM:
NMED:
EPA:
Wells in the ARG q " i f ~
Wells should be installed in both the upper and lowor aquifm
Wells only needed in the uppermost aquifer.
Wells are only n ~ in the uppcnnost aquifer.
Additional monitoring wells.,., not needed in the deep ARG aquifer at this time. The AF facies
is considered the "uppennost aquifer" or satw"atcd zone under ReRA and is where contamination
from the im!dfill would be foUDd initially. We recognize that the AF facies bas very low
coocluctivity and is unlikely to be ..... lOr production purpose>. However, if contamination is
found in the AF filcies, then vertical deliDeatiou of conramination would be requirod by installing
_lis in the ARG aquifer.
N_o/Wdb
CANM: The MWL needs 25 wells.
NMED: One background and two downsradient wells needed.
EPA: Continue further discussion with NMED.
We recommend that the Mixed Waste Landfill have two or three detecti on monitoring 'W'CUs at
the urul's point of t:ompliancc along its weslem boundaty. TIIC wells should be fairJyevenly
spaced and located to intercept potc:otiaJ groundwaler releases in the uppermost aquifer. the AF
facies. Two oftbcse wells should be rtpJacemenu for wells MWI and MW3 .. If contamination
fs found in the Ai strata monitoring wells. tbeu vertit:al delineation of contamination would be
requ;,.d by installing wells in the ARG aquifer. W. also recommend that NMED consider
installation of at least oue additional well to the north or northwest sinec it appears the
groundwater flow direction may take. more IIOIthmly din:ction as the City of Albuquerque
continues pumping whid! is causing dnIwdown of the Regional Aquifer: .
7
The NMED has already directed DOElSNL to replace MWI and MW3 with MW7 and MWS,
reSpectively, along the western boundary of the MWl at the point of compliance in addition to
replac:mg aWl as the background well on the eastern side. Additional wells and exact locations
are still under negotiation. Once we would prefer to see new wells sampled
annually or quarterly, ifpractieable.
Since the MWL is considered a SWMU. there are no specific regulations to determine the
minimum number of downgradient wells. only guidance which recommends an adequate number
of hydraulically downgradient monitoring wells in the uppermost aquifer. iii contrast, RCRA
regulations require a minimum of three do\mgradient wells..
BoraoJe Wd/ VullO!
The EPA reviewed the DVDs of the borehole videos provided by SNL for monitoring wells
8WI, MWI, MW2; MW3, MWS, and MW6. The MWI video indicared the most corrosion of
its stainless steel screen. 1be MW3 video showed much less corrosion. with MW2 and aWl
displaying minimal cOrTosion. Since stainleSs steel contains nickel,. chromium., and iron., well
cOlTOsion may mask groundwater contamination by these metals. However, since the MWL
ReRA Facility Investigation (RFI) did not identify constituents in the landfill which would cause
significant chromium or nickel contamination, we believe the elevated groundwater levels of
these contaminants are probably caused by weU screen corrosion.
In addition, several of the wells had. broWlKOlored, encrustation-like material 011 the well
screens. The MW3 video also had a fOOl long hoi. In the PVC casing 11140 feet, exposing the
annular grout. Periodic maintenance of wells should be used to clear sereen and/or sandpack
obstructions.
Individual WeD Comments
BWl
CANM: Needs replacement Mud rotary drilling caused new mineralogy which masks
contaminants. Improper purging and sampling methods. Jncorrect location. Low water level.
NMED: Repiacemcnl: scheduled for early 2008.
EPA: Needs replacement.
The background 'well u located approximately 450 feet to the south southeast of the MWL This
monitoring well needs to be replaced because water Ievel$ have dropped below the screened .
interval, as indicared by the 2006 WIller level measurements and verified by the DVD log.
Although recent measurements indicate the well may have become more cross-gradienl to the t
MWL than thought at the time of installation., this does not mean the data are unreliable; it
should not have been affected by the MWL due to its distance.
8


The n:pl .. emcnt well should be located cast (hydraulically upgradient) of the MWL and screened
with. PVC saecn ""ross the watcrtable in the AP aquifer. The NMED Iw already di=ted
DOEISandia to r<pIace Ibis well aod & is scbcduled for installation hy early 2008.
MWI
CANM: A plume of nickel contamination must be invtltigated and additional wens
installed within aod surrounding the MWL. Cross gradient. Improper water samplins
methodology. Improper purgins aod sampling methods.
NMED: Needs replacement; scheduled for spring of2001. The nickel is not moving and
it's probably due to well screen corrosion.
EPA: Continue furtherdiscussioD with NMED.
This well is located near the northern boundary of the MWL. It should be n:pi1l<ed due to
corrosion of the stainless steel screen, low WIUr aod because the lower part of the screened
intcrvill is filled with sediment, which was seen in the video log.. Well wnples indicated the
presence of chromium. nickel, and iron, the same constituents found in stainless steeL Since the
w<lI's looation oil the north side of the MWL Iw become m<tly c:ross-gradient or up-gradlent to
the landfill, it's unlikely the well would detC<t cODtamination from the MWL. Although elevated
background lovcla of nickel have been do<umcnted in the 10<al...., the possibility exists for
longitudinal dispcrsioc northward from the MWL to this well.
Since corrooion problems could mask any chromium or nickel contamination from the landfil4
w< c:annot conelude wbcther the eh:voted nickel in tbe well is from the laodfill. Samplins of the
groundwater from a oew well or from: a borehole near MW 1 would provide conclusive results.
The NMED Iw ah<ady di=tcd DOEiSaodia to n:pi1l<c MW I with a well on the western side of
the MWL; it is S(:heduled for installation in earty 2008.
CANM: Mud rotary drilling caused new tnineJ1Uogy which masks confaminants. Improper
purging and sampliog methods. Low water level.
NMED:
EPA: Continue further discussion with NMEO.
The well is located on the northwestem: comer of the landfill and a.ppears to be cross-gradient SO
it is unlikely 10 observe releases &om the landfill with westerly groundwaa flow. The video log
indicates very Jittle corrosion which seems to be confinned by the lack. of chromium or nickel
exceedances in the samples. We recommend thai: this well be used to mea5UR groundwater
devation unless corrosion problems occur later or the watct level drops.
In addition. we recommend further on the north side of the landfill since we expec1
9
that the groundwater direction may tum more northward as the City of Albuquerque continues
pwnping. This well may be able to provide additional information unless it becomes
problematic.
MW3
CANM: Has never produced reliable data due to purging method and mud rotary drilling.
Mud roWy drilling caused new mineralogy which masks contaminants. Improper purging and
sampling methods. Dedining water levels.
NMED:
Replacement scheduled for spring of 2008.
EPA: Needs replacement.
This well is located on the western side of the MWL. It should be replaced due to corrosion of
the stainless steel ~ e n and because.the water level is near the bottom of the screeoed interval.
as seen in the video log. Well samples indicated. the presence of chromium, Dick.el, and iron. the
same constituents found in stainless steel. There is a foot long hole in the PVC casing at the 40
foot depth which appears to be the result of efforts to free jammed equipment.
The replacement well should be moved closer to the wlit boundary and h o ~ d have a PVC .
screen across the water table of the AF facies. The NMED has already directed DOE/Sandia to
replace this well and it is scheduled for installation in early 2008.
MW4
CANM: Needs to be immediately plugged and abandoned due to well screen across both
the AF and ARG_ Improper purging and sampling methods. Mistakes in drilling and
construction. Declining water level.
NMED: Does not need replacement. 1be well was refurbished a couple of years ago and
the old packer was removed and replaced. There is a significant vertical hydraulic gradient in
this area but no problem with ARG to AF c:omingling.
EPA: Continue further discussion with NMED.
This well is driUed at an angle under the nonb side of the MWL. It has screened intervals in both
the shallow and deeper aquifers. Although the packer has been replaced. it is unc1eax if it is
providing an adequate sea] between the two well screens. Irnot. the two. aquifers may be mixing
in the well and providing a conduit between the deeper and shallow strata with the bulk of water
apparently provided by the more productive ARG aquifer. Lower nitrate concentrations may also
be an indication of mixing oftbc aquifers.. It is also unclear whether the screen was properly
placed at the water table of the AF facies based on the lithologic: log narrative which states that
the material recovered at the 398 to 410 foot interval was "'very moist."
In addition, since this well was placed within the landfill boundary, it docs not provide indication
10
,
..
. .

At this poipt. we recommend plugging this well but
additional information is needed from NMED regarding the date the paCker was "'placed. Also,
as discussed UDder MW2, we recommend fiuthcT investigation of the north side of the landfill SO
another well may be needed as "'Placement.
MW5
CANM: Needs to be immediately plugged aDd abandoned due to well screen across txlth
the AF and AKO and CODtaminalion with grout and bentonite <lay.
NMED: Does !tOI' need "'Plaoemcnt. The grout was suc:oessfully deaned and the well
sbould remain for water level monitoring. ,
EPA: Continue further disoussion with NMED.
Thi> well is lo<:ated about 140'feet to the west of the MWL. Although the intent of tho well
appears to be monitoring allnvial fan strata. the well sc:r=n extends into the ARG. Since
the ARG appears to be confined. the hydraulic gradient, if any, appears to be upward to the' AF
strata. In adQition, i, is _lear if the grout was fully removed from the soreened interval or
formation. which could pievent representative sampling. This well m8y be useful to mr;asurc
"Water level, however.
MW6
CANM: Installed in the AKG bu, too tar from MWL,
NMED: Keep this well for monitoring water level and flow
EPA: Keep this well for monitoring water level in the ARG.
This well is located about SOO feet to the west northwest of the landfill and monitors the ARO
facies. We recommend that it be maintained to measure water level and flow direction. The
water level in this well is approximately 15-20 feet above the top of the screen. indicating the
confined nat1.Jre" oftbis aquifer.
Summary aad Coaclusioos
Based on our review, we ha .... e determined that NMEO's overall actions and decisions for
administration of the authorized program ha .... e been technically sound and consistent with
applicable ReRA requirements. We have also found no C"Yidence to indicate that the MWL
poses an imminent or substantial danger to citizens or groundwater supply.
As part of our oversight responsibility, we maintain an open and ongoing dialogue with NMED.
routinely discussing program matters and raising any concerns we may have. It is our intention
to continue to discuss these issues with the State. Although it may appear there are differences of
11
,
opinion between EPA and NMED, we share the same goal: proteCt the environment of New It
Mexico. In regard to the MWL, Ihe main priority is ensuring the effectiveness of the
groundwater monitoring network". Since NMEO is responsible for day to day administration of
the delegated RCRA program. they are allowed leeway in specific details. as long as
environmental standards and requirements are In many instances, the -best way" is a
matter ofjudgmenl and experience, and we have confidence in their ability to run this program.
The decision to cover the MWL was made to reduce the potential for erosion. water infiltration.
and animal intrusion; it is not "F(nal Closure" with a permanent ReRA Delaying the
cover may actually increase the possibility that contamination could reach the groundwater.
Long term monitoring was included to ensure prompt and apPropriate actions would be taken if
contamination was found. The potential exists for future excavation if deeined necessary.
The original weBs were properly located based on knowledge of geology and gro!ltldwater at that
time. We believe they provided reliable, representative data and. effective detection monitoring-
during their uscfullife. We have recommended ihat certain wells be plugged or I'q)laced due to
changes in groundwater. levels, weU Corrosion. aDd better tmdCrstanmng of groundwater flow.
We are confident the new wells and monitoring network will provide adequate/accurate data,
thus ensuring protection of the groundwater. It would also have been preferable for the landfill
cover to have been fully in place by now.
..
Soil vapor sampling of the MWL is also planned. This was originally scheduled for early 2007
but has been delayed due to CANM inquiries and requests for information. We would like to see f
this sampling move forward as soon as possible.


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