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\\Data1\Projects\2018\0945.18\03_DSGN\03_REPT\00_CLERICAL\PERMIT\NOD 2\Admin NOD Cover Letter.docm
April 20, 2020 Terance Virtue, Geoscientist IV MC 124, Municipal Solid Waste Permits Section Texas Commission on Environmental Quality Building A, Room 122 12100 Park 35 Circle Austin, Texas 78753-1808 Re: Technical Notice of Deficiency #1 Response City of Dumas MSW Management Facility Dumas, Moore County, Texas Municipal Solid Waste Permit Number: 211B RN101667053/CN600649370 Tracking No. 25063819 Type I Landfill Limited Scope Major Permit Amendment Application Mr. Virtue: The revisions made to the City of Dumas Landfill Limited Scope Major Permit Amendment Application TCEQ MSW Permit No. 211B Technical NOD #1 submittal are enclosed with this letter. In response to the TCEQ letter dated April 17, 2020, we have included our responses to each of your comments in the deficiency table following this letter. We believe the deficiency table addresses all comments. Please call 806.473.3656 for any questions.
Sincerely, PARKHILL, SMITH & COOPER, INC. By
Tyler S. Krueger, P.E. Project Engineer
TSK/SS
cc: Mr. Arbie Taylor, City Manager Mr. Brad Jones, TCEQ Region 1 Office
NOD
ID
MRI
IDApp. Part Citation Location 1st NOD Type NOD Description NOD Response
T1 517 Part III 330.63(f)(5)(B)Attachment 11
Section 3.2.Incomplete
Provide procedures to calculate background values for
each constituent listed in §330.419.
procedures to calculate background values for each
constituent listed in §330.419 has been added to Attachment
11 Section 3.2.
T2 518 Part III 330.407(a)Attachment 11
Section 3.1.Inconsistent
Provide that all six monitor wells will be sampled
semiannually to account for changes in groundwater
gradient.
It was assumed that the location is Attachment 5 Section 3.1
that needed to be updated. That section has been updated.
T3 523 Part III 330.407(b)(2)Attachment 11
Section 3.3.Ambiguous
Revise "initial Statistical Significant Increase" and "initial
SSI" to "initial exceedance” in the first two paragraphs
and revise "SSI" in the first paragraph, last sentence to
"initial exceedance”. The term “initial exceedance” refers
to a monitoring result that exceeds a statistical limit but
has not yet been verified by resampling.Attachment 11 Section 3.3 has been updated based on
comment.
T4 539 Part III 330.63(f)(6)(A)Attachment 11
Section 3.6.Omitted
Provide a statement that assessment monitoring
information and a description of any special waste
previously handled at the facility will be provided.
Attachment 11 Section 3.6 has been updated based on the
comment.
T5 Part III 330.409(b)Attachment 11
Section 3.6.Incomplete
Remove “point of compliance” from the sentence “…If a
statistically significant increase (SSI) over background
occurs in a well, the well exhibiting the SSI and the two
immediately adjacent point of compliance wells will be
sampled…”
Attachment 11 Section 3.6 has been updated to remove
point of compliance from the sentence referenced.
T6 558 Part III 330.403(a)(2)Attachment 5
Section 3.1.Incomplete
Indicate that point of compliance well spacing will not
exceed 600 feet.
Point of compliance well spacing has been added to
Attachment 5 Section 3.1
NT7 575 Part III 330.405(b)(1)Attachment 11
Section 1.6Incomplete
Provide that equipment blanks should be collected once
per day or sampling event and that field duplicates
should be collected once every sampling event. Indicate
that groundwater samples should be sent to the
laboratory within 48 hours of collection.Comment has been addressed in Attachment 11 Section 1.6
NT8 577 Part III 330.405(b)(3)Attachment 11
Section 1.5.1.Incorrect
Revise sentence from "Sample collection should be
initiated within 48 hours…" to "Sample collection
should be initiated within 24 hours…"
Attachment 11 Section 1.5.1 has been updated based on
the comment
T9 579 Part III 330.405(c)Attachment 11
Section 1.5.1Omitted
Include a statement that groundwater samples will not
be filtered in the field. Statement has been added to Attachment 11 Section 1.5.1.
T10 588 Part III 330.405(f)(2)Attachment 11
Section 3.3Incomplete
Provide, if individual sampling point comparison to
background or groundwater protection standard is
used, for the statistical test to be done at Type I level
not <0.01.
Attachment 11 Section 3.3 has been updated based on
comment.
T11 589 Part III 330.405(f)(3)Attachment 11
Section 3.3Incomplete
Provide that, if a control chart is used, the specific type
of chart & its parameters must be protective.
Attachment 11 Section 3.3 has been updated based on
comment.
T12 634 Part III 330.421(a)Attachment 5
Section 3.2.Omitted
Indicate that the construction of monitoring wells will
provide integrity, representative samples, prevent
migration of water in the bore hole and that well
construction follow prescribed specifications.Section 3.2 of Attachment 5 has been updated to address
comment.
T13 635 Part III 330.421(a)(1)(A)Attachment 5,
Section 3.2Omitted
Provide that wells are drilled by a qualified Texas
licensed driller & supervised by a Texas licensed PG or
PE.
Section 3.2 of Attachment 5 has been updated to address
comment.
T14 636 Part III 330.421(a)(1)(B)Attachment 5,
Section 3.2Omitted
Provide a drilling method that will not introduce
contaminants. If fluid is used in drilling, then use clean
city water unless approved by the ED. If city water is
used provide an analysis.
Section 3.2 of Attachment 5 has been updated to address
comment.
T15 637 Part III 330.421(a)(1)(C)Attachment 5,
Section 3.2Omitted
Provide that the boring diameter is at least 4 inches
larger than the casing diameter.
Section 3.2 of Attachment 5 has been updated to address
comment.
NT16 638 Part III 330.421(a)(1)(D)Attachment 5,
Section 3.2Omitted
Provide that boring logs are signed, sealed & dated by a
Texas licensed PG or PE.
Section 3.2 of Attachment 5 has been updated to address
comment.
T17 639 Part III 330.421(a)(2)Attachment 5,
Section 3.2Omitted Provide designs for casing, screen, filter pack, & seal.
Section 3.2 of Attachment 5 has been updated to address
comment.
T18 640 Part III 330.421(a)(2)(A)Attachment 5,
Section 3.2Omitted
Provide that casing specifications are 2 to 4 inch
schedule 40 or 80 PVC, and must meet other
requirements of 30 TAC §330.421(a)(2)(A).
Section 3.2 of Attachment 5 has been updated to address
comment.
T19 641 Part III 330.421(a)(2)(B)Attachment 5,
Section 3.2Omitted
Provide screen specifications that are compatible with
the casing and do not include glue, solvents, field-cut
slots or filter cloths.
Section 3.2 of Attachment 5 has been updated to address
comment.
T20 642 Part III 330.421(a)(2)(C )Attachment 5,
Section 3.2Omitted
Provide that filter pack consists of clean silica sand or
glass that extends 1 to 4 ft. above the screen.Section 3.2 of Attachment 5 has been updated to address
comment.
T21 643 Part III 330.421(a)(2)(D)Attachment 5,
Section 3.2Omitted
Provide that annular seal is at least 2 ft. thick and is
placed in the zone of saturation.
Section 3.2 of Attachment 5 has been updated to address
comment.
T22 644 Part III 330.421(a)(2)(E)Attachment 5,
Section 3.2Omitted
Provide that the casing seal is placed on top of annular
seal with bentonite grout or a cement-bentonite mix.Section 3.2 of Attachment 5 has been updated to address
comment.
T23 645 Part III 330.421(a)(3)Attachment 5,
Section 3.2Omitted
Provide specifications for the concrete pad to be placed
on top of the casing seal, including the type of
structural concrete used from casing seal to surface.Section 3.2 of Attachment 5 has been updated to address
comment.
T24 646 Part III 330.421(a)(4)Attachment 5,
Section 3.2Omitted Provide that collar specifications are protective.
Section 3.2 of Attachment 5 has been updated to address
comment.
T25 647 Part III 330.421(a)(5)Attachment 5,
Section 3.2Omitted
Provide protective barrier specifications such as three to
four 6-12 inch diameter pipes set in concrete. Other
types of barriers may be approved by ED.
Section 3.2 of Attachment 5 has been updated to address
comment.
NT26 648 Part III 330.421(b)Attachment 5,
Section 3.2Omitted
Acknowledge that when wells are installed in unusual
conditions, all aspects must be approved in writing by
the ED.
Section 3.2 of Attachment 5 has been updated to address
comment.
T27 649 Part III 330.421(c)Attachment 5,
Section 3.2Omitted
Provide for the removal of artifacts once the monitoring
well is installed.
Section 3.2 of Attachment 5 has been updated to address
comment.
T28 650 Part III 330.421(d)Attachment 5,
Section 3.2Omitted
Provide that well locations are surveyed and
permanently marked with the elevation.
Section 3.2 of Attachment 5 has been updated to address
comment.
GC1 651 Part III NAAttachment 5
Section 1.1Inconsistent
Revise spelling of “Ogalla” to “Ogallala” in the second
paragraph. Revision has been made
GC2 652 Part III NAAttachment 11
Section 1.6Inconsistent Revise “downwind well” to “downgradient well”. Revision has been made
GC3 653 Part III NAAttachment 11
Section 3.3Inconsistent
In the third paragraph, revise “SSI” to “Statistically
Significant Increase (SSI)”. Revision has been made
GC4 654 Part III NAAttachment 11
Section 3.5Inconsistent
Revise rule reference 30 TAC §330.409(b)(2) and (3) to
30 TAC §330.407(b)(2) and (3). Revision has been made
GC5 655 Part III NAAttachment 11
Section 3.7Inconsistent
Revise sentence from “remedy described under §330
addressing at least the following...” to “remedy
described under §330.413 addressing at least the
following...”. Revision has been made
GC6 656 Part III NAAttachment 11
Section 3.9Inconsistent Revise rule reference from §330.405I to §330.405(e). Revision has been made
GC7 657 Part III NAAttachment 11
Section 3.9Inconsistent
Revise rule reference from §330.509 to §330.509(b) in
the last paragraph. Revision has been made
TCEQ-0650, Part I Application (rev. 09-01-2019) Form - Page 1 of 11
Facility Name: City of Dumas Landfill
Permittee/Registrant Name: City of Dumas
MSW Authorization #:211B
Initial Submittal Date: 11/18/2019
Revision Date: 4/20/2020
Texas Commission on Environmental Quality
Part I Application Form for New Permit, Permit Amendment, or Registration for a
Municipal Solid Waste Facility
1. Reason for Submittal
Initial Submittal Notice of Deficiency (NOD) Response
2. Authorization Type
Permit Registration
3. Application Type
New Permit Permit Major Amendment Permit Major Amendment (Limited Scope)
New Registration
4. Application Fees
Amount
$2,050 for Permits and Permit Amendments $150 for Registrations
Payment Method
Check Online through ePay portal <https://www3.tceq.texas.gov/epay/>
If paid online, enter ePay Trace Number:
5. Application URL
Is the application submitted for a Type I Arid Exempt (AE) or Type IV AE facility?
Yes No
If the answer is “No”, provide the URL address of a publicly accessible internet web site
where the application and all revisions to that application will be posted.
http://
TCEQ-0650, Part I Application (rev. 09-01-2019) Form - Page 2 of 11
6. Application Publishing
Party Responsible for Publishing Notice:
Applicant Agent in Service Consultant
Contact Name: Tyler Krueger Title: Project Engineer
7. Alternative Language Notice
Is an alternative language notice required for this application? (For determination refer to
Alternative Language Checklist on the Public Notice Verification Form TCEQ-20244-Waste)
Yes No
8. Public Place Location of Application
Name of the Public Place: City of Dumas City Hall
Physical Address: 124 W. 6th Street
City: Dumas County: Moore State: TX Zip Code: 79029
(Area code) Telephone Number: (806) 935-4101
9. Consolidated Permit Processing
Is this submittal part of a consolidated permit processing request, in accordance with 30
TAC Chapter 33?
Yes No Not Applicable
If “Yes”, state the other TCEQ program authorizations requested:
10. Confidential Documents
Does the application contain confidential documents?
Yes No
If “Yes”, cross-reference the confidential documents throughout the application and submit
as a separate attachment in a binder clearly marked “CONFIDENTIAL.”
TCEQ-0650, Part I Application (rev. 09-01-2019) Form - Page 3 of 11
11. Permits and Construction Approvals
Permit or Approval Received Pending Not
Applicable
Hazardous Waste Management Program under the
Texas Solid Waste Disposal Act
Underground Injection Control Program under the
Texas Injection Well Act
National Pollutant Discharge Elimination System
Program under the Clean Water Act and Waste
Discharge Program under Texas Water Code,
Chapter 26
Prevention of Significant Deterioration Program under
the Federal Clean Air Act (FCAA).
Nonattainment Program under the FCAA
National Emission Standards for Hazardous Air
Pollutants Preconstruction Approval under the FCAA
Ocean Dumping Permits under the Marine Protection
Research and Sanctuaries Act
Dredge or Fill Permits under the CWA
Licenses under the Texas Radiation Control Act
Other (describe)
Other (describe)
Other (describe)
Other (describe)
12. General Facility Information
Facility Name: City of Dumas Landfill
Contact Name: Arbie Taylor Title: City Manager
MSW Authorization No. (if available): 211B
Regulated Entity Reference No. (if issued)*: RN101667053
Physical or Street Address (if available): 1900 S Maddox
City: Dumas County: Moore State: TX Zip Code: 79029
(Area Code) Telephone Number: (806) 935-4101
Latitude (Degrees, Minutes Seconds): 35°50'36.00"N
Longitude (Degrees, Minutes Seconds): 101°57'45.00"W
Benchmark Elevation (above mean sea level): 3597.24ft.
Provide a description of the location of the facility with respect to known or easily
identifiable landmarks: APPROXIMATELY THREE FOURTH MILE SOUTHEAST OF THE
CITY OF DUMAS.
Detail access routes from the nearest United States or state highway to the facility:
ABOUT ONE HALF MILE SOUTHEAST OF THE INTERSECTION OF US HIGHWAY
87/287 AND 19TH STREET.
TCEQ-0650, Part I Application (rev. 09-01-2019) Form - Page 4 of 11
*If this number has not been issued for the facility, complete a TCEQ Core Data Form (TCEQ-10400) and submit it with this application. List the Facility as the Regulated Entity.
13. Facility Type(s)
Type I Type IV Type V
Type I AE Type IV AE Type VI
14. Activities Conducted at the Facility
Storage Processing Disposal
15. Facility Waste Management Unit(s)
Landfill Unit(s) Incinerator(s)
Class 1 Landfill Unit(s) Autoclave(s)
Process Tank(s) Refrigeration Unit(s)
Storage Tank(s) Mobile Processing Unit(s)
Tipping Floor Type VI Demonstration Unit
Storage Area Compost Pile(s) and/or Vessel(s)
Container(s) Other (specify):
Roll-off Boxes Other (specify):
Surface Impoundment Other (specify)
16. Description of Proposed Facility or Changes to Existing Facility
Provide a brief description of the proposed activities if application is for a new facility, or
the proposed changes to an existing facility or permit conditions if the application is for an
amendment.
To reflect the changes in groundwater gradient on-site. The new groundwater
gradient necessitates installation of two new groundwater monitoring wells to
the north and east of the active landfill. Groundwater Characterization Report
and Groundwater Sampling and Analysis Plan (GWSAP) are updated to reflect the
groundwater monitoring plan.
17. Facility Contact Information
Site Operator (Permittee/Registrant) Name: City of Dumas
Customer Reference No. (if issued)*: CN600649370
Contact Name: Arbie Taylor Title: City Manager
TCEQ-0650, Part I Application (rev. 09-01-2019) Form - Page 5 of 11
Mailing Address: PO Box 438
City: Dumas County: Moore State: TX Zip Code: 79029-0438
(Area Code) Telephone Number: (806) 935-4101
Email Address:
TX Secretary of State (SOS) Filing Number:
*If the Site Operator (Permittee/Registrant) does not have this number, complete a TCEQ Core Data Form (TCEQ-10400) and submit it with this application. List the Site Operator (Permittee/Registrant) as the Customer.
TCEQ-0650, Part I Application (rev. 09-01-2019) Form - Page 6 of 11
Operator Name1: City of Dumas
Customer Reference No. (if issued)*: 600649370
Contact Name: Arbie Taylor Title: City Manager
Mailing Address: PO Box 438
City: Dumas County: Moore State: TX Zip Code: 79029-0438
(Area Code) Telephone Number: (806) 935-4101
Email Address:
TX SOS Filing Number:
1If the Operator is the same as Site Operator/Permittee type “Same as “Site Operator (Permittee/Registrant)”. *If the Operator does not have this number, complete a TCEQ Core Data Form (TCEQ-10400) and submit it with this application. List the Operator as the customer.
Consultant Name (if applicable): Parkhill, Smith & Cooper, Inc
Texas Board of Professional Engineers Firm Registration Number: F-560
Contact Name: Tyler Krueger Title: Project Engineer
Mailing Address: 4222 85th Street
City: Lubbock County: Lubbock State: TX Zip Code: 79424
(Area Code) Telephone Number: (806) 473-2200
E-Mail Address: [email protected]
Agent in Service Name (required only for out-of-state):
Mailing Address:
City: County: State: Zip Code:
(Area Code) Telephone Number:
E-Mail Address:
18. Facility Supervisor’s License
Select the Type of License that the Solid Waste Facility Supervisor, as defined in 30 TAC
Chapter 30, Occupational Licenses and Registrations, will obtain prior to commencing
facility operations.
Class A Class B
19. Ownership Status of the Facility
Corporation Limited Partnership Federal Government
Individual City Government Other Government
Sole Proprietorship County Government Military
General Partnership State Government Other (specify):
TCEQ-0650, Part I Application (rev. 09-01-2019) Form - Page 7 of 11
Does the Site Operator (Permittee/Registrant) own all the facility units and all the facility
property?
Yes No
If “No”, provide the information requested below for any additional ownership.
Owner Name:
Street or P.O. Box:
City: County: State: Zip Code:
(Area Code) Telephone Number:
Email Address (optional):
20. Other Governmental Entities Information
Texas Department of Transportation District: Amarillo
District Engineer’s Name: Brian Crawford
Street Address or P.O. Box: 5715 Canyon Dr
City: Amarillo County: Randall State: TX Zip Code: 79110
(Area Code) Telephone Number: (806) 356-3200
E-Mail Address (optional):
The Local Governmental Authority Responsible for Road Maintenance (if
applicable): Moore County Road & Bridge Department
Contact Person’s Name: Wes McDougal
Street Address or P.O. Box: PO Box 100
City: Dumas County: Moore State: TX Zip Code: 79029
(Area Code) Telephone Number: (806) 935-2416
E-Mail Address (optional):
City Mayor Information
City Mayor’s Name: Bob Brinkman
Office Address: 124 W 6th St
City: Dumas County: Moore State: TX Zip Code: 79029
(Area Code) Telephone Number: (806) 935-4101
E-Mail Address (optional):
City Health Authority:Department of State Health Services, PHR 1
Contact Person’s Name:
Street Address or P.O. Box: 501 Success Blvd
City: Dumas County: Moore State: TX Zip Code: 79029
(Area Code) Telephone Number: (806) 655-7151
E-Mail Address (optional):
TCEQ-0650, Part I Application (rev. 09-01-2019) Form - Page 8 of 11
County Judge Information
County Judge’s Name: Johnnie "Rowdy" Rhoades
Street Address or P.O. Box: 715 S Dumas Ave, Room 202
City: Dumas County: Moore State: TX Zip Code: 79029
(Area Code) Telephone Number: (806) 935-5588
E-Mail Address (optional):
County Health Authority: Department of State Health Services, PHR 1
Contact Person’s Name: Kelly Northcott
Street Address or P.O. Box: 3407 Pony Express Way
City: Amarillo County: Randall State: TX Zip Code: 79118
(Area Code) Telephone Number: (806) 421-0316
E-Mail Address (optional):
State Representative Information
District Number: 87
State Representative’s Name: Four Price
District Office Address: Amarillo National Bank; Plaza Two, Suite 506
City: Amarillo County: Potter State: TX Zip Code: 79101
(Area Code) Telephone Number: (806) 374-8787
E-Mail Address (optional):
State Senator Information
District Number: 31
State Senator’s Name: Kel Seliger
District Office Address: 410 S Taylor, Suite 1600
City: Amarillo County: Potter State: TX Zip Code: 79101
(Area Code) Telephone Number: (806) 374-8994
E-Mail Address (optional):
Council of Government (COG) Name: Panhandle Regional Planning Comission
COG Representative’s Name: Kyle Ingham
COG Representative’s Title: Executive Director
Street Address or P.O. Box: 9257
City: Amarillo County: Potter State: TX Zip Code: 79105-9257
(Area Code) Telephone Number: (806) 372-3381
E-Mail Address (optional):
TCEQ-0650, Part I Application (rev. 09-01-2019) Form - Page 9 of 11
River Basin Authority Name: Region A Panhandle, Texas Water Development Team
Contact Person’s Name: Lee Huntoon
Watershed Sub-Basin Name: Canadian river basin
Street Address or P.O. Box:
City: County: State: Zip Code:
(Area Code) Telephone Number: (512) 463-6021
E-Mail Address (optional): [email protected]
Coastal Management Program
Is the facility within the Coastal Management Program boundary?
Yes No
U.S. Army Corps of Engineers
The facility is located in the following District of the U.S. Army Corps of Engineers:
Albuquerque, NM Galveston, TX
Ft. Worth, TX Tulsa, OK
Local Government Jurisdiction
Within City Limits of: City of Dumas
Within Extraterritorial Jurisdiction of:
Is the facility located in an area in which the governing body of the municipality or county
has prohibited the storage, processing or disposal of municipal or industrial solid waste?
Yes No
If “Yes”, provide a copy of the ordinance or order as an attachment.
TCEQ-0650, Part I Application (rev. 09-01-2019) Form - Page 11 of 11
Part I Attachments
(See Instructions for P.E. seal requirements.)
Required Attachments Attachment No.
Supplementary Technical Report
Property Legal Description
Property Metes and Bounds Description
Facility Legal Description
Facility Metes and Bounds Description
Metes and Bounds Drawings
On-Site Easements Drawing
Land Ownership Map
Land Ownership List
Electronic List or Mailing Labels
Texas Department of Transportation (TxDOT) County Map
General Location Map
General Topographic Map
Verification of Legal Status
Property Owner Affidavit
Evidence of Competency
Additional Attachments as Applicable- Select all those apply and add as necessary
TCEQ Core Data Form(s)
Signatory Authority Delegation
Fee Payment Receipt
Confidential Documents
Waste Storage, Processing and Disposal Ordinances
Final Plat Record of Property
Certificate of Fact (Certificate of Incorporation)
Assumed Name Certificate
Revised November 2019Revision 02 April 2020
04/20/2020For November 2019and April 2020For revision only
Revised November 2019Revision 02 April 2020
04/20/2020For November 2019and April 2020 Revision only
SITE DEVELOPMENT PLAN
Revised November 2019
04/2020 For November2019 and April 2020Revision only
Revision 02 April 2020
Attachment 5 - Groundwater Characterization Report
Request for Limited Scope Major Permit Amendment
City of Dumas Municipal Solid Waste Landfill
MSW Permit No. 211B
City of Dumas
Moore County, Texas
Revision 02 April 2020
Revision 00 November 2019
PSC Project # 01094518
Revised November 2019Revision 02 April 2020
Revised By:Parkhill, Smith & Cooper, Inc.
4222 85th St, Lubbock, TX 79423
TBPE F-560 04/20/2020For November 2019and April 2020Revision only
City of Dumas, Moore County, MSW Permit No. 211B
Part III, Attachment 5 - Groundwater Characterization Report
April 2020
PARKHILL, SMITH & COOPER INC. GMP-i 01094518 Revision 00 November 2019
Revision 02 April 2020
TABLE OF CONTENTS
1.0 GROUNDWATER MONITORING PROGRAM ............................................................. 1
1.1 Site Hydrogeology .............................................................................................................. 1
1.2 Groundwater Flow Direction and Rate ............................................................................... 1
2.0 OPERATIONAL CONSIDERATIONS FOR GROUNDWATER SYSTEM
DESIGN ................................................................................................................................................... 2
2.1 Critical Receptors................................................................................................................ 2
2.2 Relationship of Excavation Bottom-to-Uppermost Aquifer ............................................... 2
2.3 Contaminant Pathway Analysis .......................................................................................... 2
3.0 SUBTITLE D GROUNDWATER MONITORING SYSTEM ....................................... 3
3.1 Monitoring Well Locations ................................................................................................. 3
3.2 Monitor Well Design and Construction .............................................................................. 3
APPENDICES
APPENDIX A – GROUNDWATER MONITORING WELL LOCATIONS
APPENDIX B – GROUNDWATER GRADIENT MAPS
APPENDIX C – HISTORICAL GROUNDWATER LEVELS
04/20/2020 For November 2019 And April 2020 Revision Only
City of Dumas, Moore County, MSW Permit No. 211B
Part III, Attachment 5 - Groundwater Characterization Report
April 2020
PARKHILL, SMITH & COOPER INC. GCR-1 01094518
11.18.19
1.0 GROUNDWATER MONITORING PROGRAM
Originally permitted Groundwater Monitoring Plan was based on the groundwater gradient map from
February 1997. It was noted groundwater flow was radially away from lagoon area, probably
influenced by adjacent unlined wastewater lagoon. Unlined lagoon was possibly a source of recharge
to groundwater and created a localized shift in gradient. The groundwater gradient map, as shown in
Figure 5-1, indicated a groundwater gradient predominantly west for the landfill. Existing
groundwater monitoring system was installed down-gradient from the landfill, as determined by
groundwater gradient plats from the late 1990s. Groundwater gradient gradually returned to regional
gradient of northeast once wastewater lagoon was lined, as shown in Figure 5-2.
1.1 SITE HYDROGEOLOGY
Moore County Soil Survey shows two streams cut through and dissect the High Plains, North
Palo Duro Creek and South Palo Duro Creek. South Palo Duro Creek begins in the western
part of the county, flows eastward, and eventually empties into the Red River Drainage
System. North Palo Duro Creek flows eastward along the north county line, mainly Sherman
County, but swings South into Moore County in several places.
Underground water used in Moore County comes predominately from saturated sand and
gravel in the lower part of the Ogallala Formation. Underlying red beds act as an aquiclude
which kept water from percolating to a greater depth. The Ogallala Formation was cut off
from the Rocky Mountains by Pecos River and Canadian River to the south, with little
recharge of the Ogallala Aquifer from the local rainfall. Minimal recharge results from an
accumulation of rainfall that collects in Playa lakes. In the immediate area of the landfill, the
wastewater lagoon was noted a significant source of recharge when the lagoon was unlined.
Since the lagoon has been lined, groundwater flow in the adjacent area of the landfill has
returned to the natural gradient of northeast.
Amount of water available for use varies according to thickness of sands and gravel in the
Ogallala Formation and depth to red beds. Ogallala Aquifer is generally unconfined in the
region of the site of interest. Depth of groundwater in the general area of the site is
approximately 180-200 feet.
1.2 GROUNDWATER FLOW DIRECTION AND RATE
Groundwater flow direction is northeast based on recent groundwater gradient map from
March 2019 as shown in Figure 5-2. Hydraulic conductivity is approximately 250 gallons per
day per square foot according to the Bureau of Economic Geology’s Report of Investigation
No. 177, “Hydrogeology and Hydrochemistry of the Ogallala Aquifer, Southern High Plains,
Texas Panhandle and Eastern New Mexico”.
City of Dumas, Moore County, MSW Permit No. 211B
Part III, Attachment 5 - Groundwater Characterization Report
April 2020
PARKHILL, SMITH & COOPER INC. GCR-3 01094518
11.18.19
size or other sample data from well, and a site map showing location of all monitoring wells and point
of compliance will be submitted at the same time.
3.1 MONITORING WELL LOCATIONS
Uppermost aquifer beneath the City of Dumas MSW Landfill for Groundwater monitoring
purposes is identified as the Ogallala Aquifer. Four groundwater monitoring wells (MW-1
through MW-4) are already installed around the site perimeter. Locations of these wells were
identified based on groundwater gradient depicted in Figure 5-1, when adjacent wastewater
lagoon was unlined. These four wells are currently being sampled in accordance with
approved Groundwater Sampling and Analysis Plan (GWSAP).
Groundwater flow gradient in the adjacent area of the landfill gradually changed once the
wastewater lagoon was lined. Over time, groundwater gradient returned to regional gradient
of northeast. Change in groundwater gradient necessitates installation of additional
down-gradient monitoring wells north and east of the landfill. Immediately north and east of
the active landfill cell is the wastewater lagoon. Feasible locations for additional monitoring
wells are immediately adjacent to the active landfill cell. Proposed locations for two, new
groundwater monitoring wells are depicted in Figure 5-2.
The two, new monitoring wells will be designated as MW-5 and MW-6, respectively. These
new wells will be sampled semi-annually as down-gradient wells. The existing four
monitoring wells will be up-gradient wells as of March 2019 gradient map. All Wells will be
sampled semiannually. All wells will be sampled semiannually.
3.2 MONITOR WELL DESIGN AND CONSTRUCTION
Five soil borings were conducted at the City of Dumas MSW Landfill, Moore County, Texas
on April 1997. Attachment 4 – Geology Report, includes detailed discussion on locations and
subsurface investigations of borings. Geologic logs of all borings with standard sample
methods are included in Attachment 4, Appendix 7.
In accordance with 30 TAC §330.421 – Monitor Well Construction Specifications, a Texas-
licensed driller will install monitoring wells according to applicable regulations. Construction
of monitoring wells will provide integrity, representative samples, prevent migration of water
in the bore hole. Well construction shall follow prescribed specifications below. A licensed
professional geoscientist or engineer familiar with area geology will supervise monitoring
well installation, development, and provide a boring log. Equivalent alternatives to
construction specifications in TCEQ rules may be used if prior written approval is obtained
from the executive director.
Monitoring well construction will be completed in accordance with 30 TAC §330.63,
§330.403, and §330.421. Boring diameter will be at least 4 inches larger than the casing
diameter. When boring is in hard rock, executive director may approve the smaller annulus.
City of Dumas, Moore County, MSW Permit No. 211B
Part III, Attachment 5 - Groundwater Characterization Report
April 2020
PARKHILL, SMITH & COOPER INC. GCR-4 01094518
11.18.19
Monitoring well construction will be completed in accordance with 30 TAC §330.63,
§330.403, and §330.421. Boring diameter will be at least 4 inches larger than the casing
diameter. When boring is in hard rock, executive director may approve the smaller annulus.
A boring log will be made by or under the supervision of a licensed professional geoscientist
or engineer familiar with area geology, and will be sealed, signed, and dated by the licensed
professional.
The well shall be drilled by a method that will allow installation of the casing, screen, etc.,
and that will not introduce contaminants into the borehole or casing. Drilling techniques used
for boring shall take into account the materials to be drilled, depth to groundwater, total depth
of the hole, adequate soil sampling, and other such factors that affect the selection of the
drilling method. If any fluids are necessary in drilling or installation, then clean, treated city
water shall be used; other fluids must be approved in writing by the executive director before
use. If city water is used, a current chemical analysis of the city water shall be provided with
the monitor-well report.
The well casing will be 2 to 4 inches in diameter, National Science Foundation-certified
polyvinyl chloride (PVC) Schedule 40 or 80 pipe, flush-thread, screw joint (no glue or
solvents), polytetrafluorethylene (PTFE, such as Teflon) tape or O-rings in joints, and no
collar couplings. Top of casing will be at least 2 feet above ground level. Where high levels
of volatile organic compounds (VOCs) or corrosive compounds are anticipated, stainless steel
or PTFE casing and screen may be used, subject to executive director approval. 4-inch
diameter casing is recommended because it allows larger volume samples to be obtained and
provides easier access for development, pumps, and repairs. Casing will be cleaned and
packaged at the manufacturer and packaging include a PVC wrapping on each section of
casing to protect from contamination before installation. Casing will be free of ink, labels, or
other markings. Casing (and screen) will be centered in the hole to allow installation of a good
filter pack and annular seal. Centralizers are recommended on wells over 20 feet in length, but
may not be needed if wells are installed through hollow-stem augers. Top of casing will be
protected by a threaded/slip-on top cap or sealing cap or screw-plug seal inserted into top of
casing. Cap will be vented to prevent buildup of methane or other gases and designed to
prevent moisture from entering well.
Screen will be compatible with casing and should generally be same material. Screen will not
involve use of any glues or solvents for construction. A wire-wound screen is recommended
to provide maximum inflow area. Field-cut slots are not permitted for well screen. Filter cloth
will not be used. A blank-pipe sediment trap, typically 1 to 2 feet, should be installed below
screen. A bottom cap will be placed on the bottom of sediment trap. Sediment trap will not
extend through the lower confining layer of water-bearing zone tested. Screen sterilization
methods are same as casing. Selection of screen size opening should be by a person
experienced with such work and include consideration of distribution of particle sizes in
water-bearing zone and filter pack surrounding screen. Screen opening will not be larger than
the smallest fraction of filter pack.
City of Dumas, Moore County, MSW Permit No. 211B
Part III, Attachment 5 - Groundwater Characterization Report
April 2020
PARKHILL, SMITH & COOPER INC. GCR-5 01094518
11.18.19
Filter pack, placed between screen and well bore, will consist of prepackaged, inert, clean
silica sand or glass beads, extending 1 to 4 feet above top of screen. Open stockpile sources
of sand or gravel will not be used. Filter pack usually has a 30-percent finer grain size four-
to-10 times larger than the 30-percent finer grain size of water-bearing zone. Filter pack should
have a uniformity coefficient less than 2.5 and placed with a tremie pipe to ensure material
completely surrounds screen and casing without bridging. Tremie pipe will be steam cleaned
before first well and each subsequent well.
Annular seal will be placed on top of filter pack and be at least 2 feet thick, placed in zone of
saturation to maintain hydration. Seal will be composed of coarse-grain sodium bentonite,
coarse-grit sodium bentonite, or bentonite grout. Special care will be taken to ensure fine
material or grout does not plug underlying filter pack. Placement of a few inches of
prepackaged clean fine sand on top of filter pack will help prevent migration of annular seal
material into filter pack. Seal will be placed on top of filter pack with a tremie pipe to ensure
good distribution and should be tamped with a rod to determine seal is thick enough. Bentonite
will be hydrated with clean water before any further activities on well and left to stand until
hydration is complete (eight to 12 hours, depending on grain size of bentonite). If bentonite-
grout (without cement) casing seal is used in well bore, it may replace annular seal described
herein.
A casing seal will be placed on top of annular seal to prevent fluids and contaminants from
entering borehole from the surface. Casing seal will consist of a commercial bentonite grout
or cement-bentonite mixture. Drilling spoil, cuttings, or other native materials are not
permitted for use as casing seal. Quick-setting cements are not permitted for use because
contaminants may leach into groundwater. Top of casing seal will be 2 - 5 feet from surface.
High-quality structural-type concrete will be placed from top of casing seal (2 - 5 feet below
surface) continuously to top of ground to form a pad at the surface. This formed surface pad
will be at least 6 inches thick but not less than 4 (preferably 6) feet square or 5 (preferably 6)
feet in diameter. Pad will contain sufficient reinforcing steel to ensure structural integrity in
the event soil support is lost. Top of pad will slope away from well bore to edges to prevent
ponding of water around casing or collar.
A steel protective pipe collar will be placed around casing "stickup" to protect from damage
and unwanted entry. Collar will be set at least 1 foot into surface pad during construction and
should extend at least 3 inches above top of well casing (and top cap, if present). Top of collar
will have a lockable, hinged-top flap or cover. A sturdy lock will be installed, maintained, and
kept locked when well is not bailed/purged or sampled. Well number or other designation will
be marked permanently on protective steel collar (it is useful to mark total depth of well and
elevation on collar).
Where monitoring wells are likely to be damaged by moving equipment or located in heavily
traveled areas, a protective barrier will be installed. Barrier will consist of three or four 6- to
12-inch diameter pipes set in concrete just off concrete pad. Pipes may be joined by pipes
welded between them.
City of Dumas, Moore County, MSW Permit No. 211B
Part III, Attachment 5 - Groundwater Characterization Report
April 2020
PARKHILL, SMITH & COOPER INC. GCR-6 01094518
11.18.19
Upon completion of a monitoring well, location of well and all appropriate elevations
associated with top-well equipment will be surveyed by a registered professional surveyor.
Elevation will be surveyed to nearest 0.01 foot above mean sea level (with year of sea-level
datum shown). Point on well casing for elevation determined will be permanently marked on
casing. Location will be given in terms of latitude and longitude at least to nearest tenth of a
second or accurately located with respect to landfill grid system described in 30 TAC
§330.143(b)(5).
If wells are installed in ususual conditions, all aspects must be approved by the TCEQ
Executive Director. If any fluid is required in drilling monitoring wells, clean, treated water
shall be used and a chemical analysis provided to executive director. No glue or solvents will
be used in monitoring well construction.
After installation, monitoring wells will be developed to remove drilling artifacts and open
water-bearing zone for maximum flow until all water used/affected during drilling activities
is removed and field measurements of pH, specific conductance, and temperature are
stabilized. A registered professional land surveyor will survey well location and elevation.
Within 30 days of completion of a monitoring well or other part of monitoring system, an
installation report will be submitted to TCEQ. Report will include construction and installation
details for each well on forms available from commission, site map drawn to scale showing
location of all monitoring wells, and relevant point(s) of compliance, well elevations to nearest
0.01 foot above msl (with year of datum shown), latitude and longitude, or landfill grid
location of each well, copies of detailed geologic logs including soil sample data, and copies
of driller reports required by other agencies.
Damaged monitoring wells no longer usable will be reported to executive director to
determine whether to replace or repair well. In accordance with 30 TAC §305.70, if a
compromised well requires replacement, a permit modification request will be submitted
within 45 days of discovery.
Plugging and abandoning monitoring wells will be performed in accordance with 16 TAC
§76.702 and §76.1004. No abandonment will be performed without prior written
authorization.
All parts of groundwater monitoring system will be operated and maintained so they perform
at least to design specifications through life of groundwater monitoring program. Facility must
notify executive director if changes in site construction, operation, or changes in adjacent
property affect or are likely to affect direction and rate of groundwater flow and potential for
detecting groundwater contamination from the facility.
Dumas Municipal Solid Waste LandfillPart III, Attachment 11 – Groundwater Sampling and Analysis Plan
PARKHILL, SMITH & COOPER INC. 01094518
10.15.19
ATTACHMENT 11
GROUNDWATER SAMPLING AND ANALYSIS PLAN (GWSAP)
04/20/2020For November 2019
and April 2020Revision only
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. i Revision 02 April 2020
TABLE OF CONTENTS 1.0 STATEMENT OF PURPOSE .................................................................................................... 1
1.1 Field Setup and Well Inspection .................................................................................................... 1 1.2 Water-Level Measurements ........................................................................................................... 2
1.3 Well Purging .................................................................................................................................. 2
1.4 Timing and Order Of Sampling ..................................................................................................... 3
1.5 Sample Collection, Preservation, and Shipment ............................................................................ 4
1.5.1 Sample Collection ................................................................................................................. 4
1.5.2 Field Measurements .............................................................................................................. 5 1.5.3 Sample Containers and Labeling .......................................................................................... 5 1.5.4 Sample Preservation and Shipment ...................................................................................... 5
1.6 Quality Assurance and Quality Control ......................................................................................... 6
1.7 Chain-Of-Custody Documentation ................................................................................................ 6
1.8 Field Documentation ..................................................................................................................... 7
1.9 Equipment Decontamination ......................................................................................................... 7
2.0 LABORATORY QUALITY ASSURANCE AND QUALITY CONTROL ........................... 8
3.0 GROUNDWATER MONITORING REQUIREMENTS ...................................................... 10
3.1 Analyzed Constituents ................................................................................................................. 10
3.2 Background Monitoring ............................................................................................................... 10
3.3 Statistically Significant Increase and Verification Resampling ................................................... 12
3.4 Groundwater Analysis Result Submittals .................................................................................... 13
3.5 Detection Monitoring ................................................................................................................... 13
3.6 Assessment Monitoring ............................................................................................................... 14
3.7 Assessment of Corrective Measures ............................................................................................ 18
3.8 Selection of Remedy .................................................................................................................... 18
3.9 Implementation of the Corrective Action Program ..................................................................... 22
4.0 GROUNDWATER QUALITY ................................................................................................. 26
4.1 Plume of Contamination .............................................................................................................. 25
APPENDICES
APPENDIX A – LABORATORY CHECKLIST
APPENDIX B – FLOWCHART FOR SELECTING STATISTICAL METHODS
APPENDIX C – GROUNDWATER MONITORING SYSTEM PLAN
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. 4 Revision 02 April 2020
If contamination is known to be present in one or more wells at the Municipal Solid Waste Landfill
(MSWLF), sampling should begin at the well that is known to be least contaminated and end with
the most contaminated well. Where no contamination is known, the order should generally be from
the well with the highest water-level elevation to the one with the lowest elevation (upgradient to
downgradient) for each group of wells completed in a water-bearing unit.
1.5 SAMPLE COLLECTION, PRESERVATION, AND SHIPMENT
Sample collection, preservation and shipment to the laboratory are probably the most important steps
in the sampling process. Physical or chemical changes occur in ground-water samples no matter how
carefully sampling is done and can certainly occur if inappropriate sampling devices, collection
procedures, preservations and temperature controls, or inadequate shipment is employed.
The method and federal regulatory program requirements for sample management aspects will be
followed for all methods of testing and, if violated, have the data flagged and qualified. Field
personnel will follow correct procedures for recording relevant characteristics and other data relating
to the sampling operations that form part of the testing or measurement that is undertaken. Chain-of-
custody records and field notes will include the sampling procedure used, the identification of the
sampler, environmental conditions (if relevant), diagrams or other equivalent means to identify the
sampling location and all associated sample identification numbers.
1.5.1 Sample Collection
Groundwater samples will be collected using a new, disposable bailer, dedicated pump, or portable
pump. Sample collection should be initiated within 24 hours of purging but, with prior TCEQ
approval, may occur up to seven days after purging to allow adequate recovery in low-yield wells.
Groundwater samples shall not be filtered in the field. Based on water-level measurements taken
before well purging, sampling should proceed from well with highest groundwater elevation to those
with successively lower elevations. This sequence should be followed unless contamination is known
to be present. If contamination is present, monitoring wells not likely to be contaminated must be
sampled before those known to be contaminated, following these sampling procedures:
• Temperature, specific conductance, and pH of a sample collected in a container not used for
analysis should be measured in that order and recorded in log book.
• Samples should be collected by slowly discharging water from dedicated/non-dedicated
pump/bailer directly into each required container. If dedicated/non-dedicated pumps are used
for sample collection, flow rate will be reduced after purging. Flow rates for pumps used for
sampling will be carefully controlled and maintained at less than 1 liter per minute (0.26 gpm)
to avoid degassing samples. Repeat as necessary to collect sufficient sample for analysis. If
bailer used, ensure bailer and string do not touch the ground during sampling.
• Under normal conditions, sample bottles must be filled in order of decreasing volatilization
sensitivity. Generally, that will be in the following order, as applicable:
o Volatile organic compounds (VOCs)
o Total metals
o Dissolved metals (if collected)
o Other inorganic parameters (if collected)
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. 6 Revision 02 April 2020
Samples should be placed in re-sealable bags, then in an ice chest or other insulated container
packed with sufficient ice or re-freezable materials to keep them as near 4°C as possible. Sample
containers must be packed to prevent breakage. Under no circumstances, should water ice or dry
ice be used for samples shipped via public transportation.
1.6 QUALITY ASSURANCE AND QUALITY CONTROL
To document sample collection and handling procedures utilized in field have not affected quality of
groundwater samples, blanks are to be prepared and analyzed. Blanks consist of one trip blank and
one field blank per sampling event.
Trip blank is prepared by filling a water sample container with Type II reagent-grade water,
transporting to site, handling as sample, and transporting to laboratory for analysis. A field blank is
prepared by filling sample container with Type II reagent-grade water in field adjacent to a well being
sampled, and transporting to laboratory for analysis. Field blank should be prepared at a downgradient
well. Field and trip blanks are to be analyzed for VOCs only. Equipment blanks should be collected
once per day or sampling event and that field duplicates should be collected once every sampling
event. Groundwater samples should be sent to the laboratory within 48 hours of collection.
1.7 CHAIN-OF-CUSTODY DOCUMENTATION
A suitable chain-of-custody (COC) document must accompany the samples at every step from field
to laboratory and must be signed by each party handling the samples, from sampler through
transported to the laboratory, to document the possession of the samples at all times. Proper COC
procedures are essential to ensure sample integrity and to provide legally and technically defensible
data.
COC documentation is maintained on a chain-of-custody record form as collected. Information on
COC record form includes:
• Project name and number (includes site name)
• Site location
• Sample number
• Sample date and time
• Sample type
• Number and type of sample containers
• Analyses required
• Sample preservative
• Lab destination
• Carrier/shipping number
• Special instructions
• Spaces for signatures of sampler(s) and everyone assuming sample custody
The COC record form must contain the signatures of anyone assuming custody of the samples. Each
time custody changes hands, the party releasing the samples should sign under "Relinquished By"
and record the date and time. The party receiving the samples should sign under the heading
"Received By" and record the date and time. The COC form is typically provided by the analytical
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. 7 Revision 02 April 2020
"Received By" and record the date and time. The COC form is typically provided by the analytical
laboratory.
If available or required, COC seals can be placed over the shipping container lid or sample container
lids to deter sample tampering by unauthorized parties.
1.8 FIELD DOCUMENTATION
Information related to a sampling event and field activities must be thoroughly documented on field
data sheets or field log book. All entries should be legible and made in black, indelible ink. Entry
errors should be crossed out with a single line, dated, and initialed by the person making the
corrections. Below is an outline of the information that should be documented during field activities.
• Project name and number
• Date and time of all activities
• Weather conditions
• Sampling personnel
• Field instrument calibration remarks
• Well identification number
• Well description, including casing size
• Description of well condition
• Initial water-level measurement with point of reference (top of casing) and time of
measurement
• Depth to the well bottom with point of reference (from well records)
• Well volume calculations
• Presence and thicknesses of immiscible layers, if present
• Physical description of groundwater (color, odor, turbidity)
• Time starting and ending well purging, volume purged, and method of removal
• Sampling equipment and remarks
• Initial temperature, conductivity, and pH measurements
• Sample time and date
• Description of sample
• Quality control remarks
1.9 EQUIPMENT DECONTAMINATION
Reusable sampling equipment and measurement instruments coming in contact with groundwater in
wells or samples are to be decontaminated before use at each well location. Decontamination
standards or equivalent procedures are to be followed for nondedicated well purging and sampling
equipment. Equipment should be washed with non-phosphate detergent and rinsed with tap water and
Type II reagent-grade water. Sampling equipment should be thoroughly dried before use to ensure
residual cleaning agents are not carried to sample. Any equipment used for dedicated pumps reused
at other wells will follow the same de-contamination requirements. Disposable bailers and
nondedicated bailer line must be discarded along with disposable health and safety garments. Water
and cleaning agents are to be disposed in accordance with applicable regulations.
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. 11 Revision 02 April 2020
The quarterly sampling will provide data representative of each of the four seasons of the year.
Background quarterly sampling will be collected and analyzed for the total metals constituents
referenced in Title 30 TAC §330.419(a) and presented in Table 11.1. Background values for all metals
listed in 40 Code of Federal Regulations (CFR) Part 258, Appendix I will be calculated using
intrawell prediction limits. Background values for volatile organic compounds (VOCs) listed in 40
Code of Federal Regulations (CFR) Part 258, Appendix I are set by practical quantitation limits
(PQL) listed in the TCEQ letter dated May 25, 2010; whereas, any exceedance of the listed PQL for
the given VOC constituent is an exceedance of background for that VOC constituent. Upon
completion of background monitoring and during background updates, the facility will evaluate the
data to ensure that they are representative of background groundwater constituent concentrations
unaffected by waste management activities or other sources of contamination. The evaluation will be
documented in a report and submitted to the executive director before the next subsequent
groundwater monitoring event following the updated (or initial) background period.
The executive director may establish an alternative list of inorganic indicator constituents for a
municipal solid waste management unit in lieu of some or all of the heavy metals (constituents (1) -
(15) in the table located in 40 CFR Part 258, Appendix I) if the alternative constituents provide a
reliable indication of inorganic releases from the municipal solid waste management unit to the
groundwater. The executive director may also add inorganic or organic constituents to those to be
tested if they are reasonably expected to be in or derived from the waste contained in the unit or if
they are likely to provide a useful indication of releases from the municipal solid waste management
unit to the groundwater. In determining alternative or additional constituents, the executive director
shall consider the following factors:
(1) the types, concentrations, quantities, and persistence of waste constituents in wastes at the
municipal solid waste management unit;
(2) the mobility, stability, and persistence of waste constituents or their reaction products in
the unsaturated and saturated zones adjacent to or beneath the municipal solid waste
management unit;
(3) the detectability of indicator constituents, waste constituents, and reaction products in the
groundwater; and
(4) the concentrations and coefficients of variation of monitoring parameters or constituents
in the groundwater background.
In accordance with 30 TAC 330.407 (a)(2), the executive director may specify an appropriate
alternative frequency for repeated sampling and analysis of the constituents listed in §330.419 for the
new monitoring wells (MW-5 and MW-6). The alternative frequency will be no less than annual and
will be based on factors such as lithology and hydraulic conductivity of the aquifer and unsaturated
zone, groundwater flow rates, minimum distance of travel from waste to monitoring wells, and
resource value of the uppermost aquifer.
For the purpose of establishing background groundwater quality, the executive director may agree to
consider analytical data acquired prior to the effective date of Chapter 30 of the Texas Administrative
Code in addition to the data required in this section and in 30 TAC §330.409(b).
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. 12 Revision 02 April 2020
3.3 STATISTICALLY SIGNIFICANT CONSTITUENTS AND VERIFICATION
RESAMPLING
If an individual well (or sampling point) comparison procedure is used to compare an individual
compliance well constituent concentration with background constituent concentrations or a
groundwater protection standard, the test shall be done at a Type I error level no less than 0.01. If a
control-chart approach is used to evaluate groundwater monitoring data, the specific type of control
chart and its associated parameter values shall be protective of human health and the environment.
These parameters shall be determined after considering the number of samples in the background
database, the data distribution, and the range of the concentration values for each constituent of
concern.
Statistical analysis of constituents in Table 11.1 (i.e. 30 TAC §330.419) will commence within six
(6) months after completion of the eight (8) quarterly background events. An initial excedance will
be based on any compound detected in any monitor well at a concentration above the specific
constituent’s statistical limit. If an initial exceedance of any constituent is indicated at any monitoring
well, a notice will be made to the Executive Director (ED), and any local pollution agency with
jurisdiction that has requested to be notified, in writing within fourteen (14) days of the determination
of the initial exceedance.
In the event of an initial exceedance for any constituent listed in 30 TAC §330.419, verification
resampling will be completed within 60 days of the notification of the initial exceedance in
accordance with 30 TAC §330.407(b)(2).
In the event that one or more constituents listed in 30 TAC §330.419 are confirmed through
verification resampling as an Statistically Significant Increase (SSI) in any monitoring well and no
source other than the MSWLF, error, or natural variation is demonstrated the facility will immediately
place a notice in the operating record describing the increase. The notice may be in the form of a
groundwater monitoring report.
If a statistically significant increase over a background limit of any tested constituent at any
monitoring well has occurred and the owner or operator has reasonable cause to think that a source
other than a landfill caused the contamination or that the statistically significant increase resulted
from error in sampling, analysis, or statistical evaluation, or from natural variation in groundwater
quality, then the owner or operator may submit a report providing documentation to this effect, in
accordance with 330.407(b)(3). The report is commonly referred to as an “alternate source
demonstration (ASD),” but may be a demonstration of an error or of natural variation, instead of a
source other than the landfill.
An owner or operator pursuing an ASD must first notify the executive director of the TCEQ (and any
local pollution agency with jurisdiction that has requested to be notified) in writing, within 14 days
of determining an SSI over a background limit, that the owner or operator intends to make the
demonstration. The ASD must be submitted within 90 days of determining an SSI.
If the ASD is satisfactory to the executive director, the facility may continue detection monitoring. If
the ASD is not satisfactory, the owner or operator must proceed with assessment monitoring.
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. 13 Revision 02 April 2020
3.4 GROUNDWATER ANALYSIS RESULT SUBMITTALS
Statistical analysis using a prediction limit procedure will be performed in accordance with Appendix
B no later than 60 days after each semi-annual sampling event. In the event that statistical analysis
of the groundwater analytical results indicates an initial statistically significant increase (SSI) from
background of any tested constituent at any point of compliance well, a notice in writing to the
Executive Director, and any local pollution agency with jurisdiction that has requested to be notified,
will be submitted within fourteen (14) days of the determination of the SSI (30 TAC §330.407(b)).
The groundwater chemistry data will be evaluated to determine statistically significant increases from
background values for each of the constituents monitored. The statistical analyses will be performed
in accordance with 30 TAC 330.405(e) and (f). A prediction interval method is anticipated to be
used. A prediction interval procedure is specifically allowed in 30 TAC §330.405(e)(3). Statistical
analyses will be performed using Sanitas®, a commercial software program developed by Sanitas
Technologies, Inc. or another comparable computer program.
3.5 DETECTION MONITORING
The monitoring frequency for all constituents listed in 30 TAC §330.419 will be at least semi-annual
during the active life of the facility, the closure and the post-closure care period, unless another
sampling schedule is approved by the TCEQ.
A minimum of four statistically independent samples from each background and each point of
compliance well will be collected and analyzed for the constituents listed in 30 TAC §330.419 to
establish background groundwater quality. Initial background sampling for a well will be completed
on a quarterly basis, unless an alternative schedule is approved by the executive director. Background
data sets may be updated once every two years with semiannual detection monitoring results that are
demonstrated to be representative of background groundwater quality. Upon completion of
background monitoring and during background updates, the facility will evaluate the background data
to ensure that the data are representative of background groundwater constituent concentrations
unaffected by waste management activities or other sources of contamination. The evaluation will
be documented in a report and submitted to the executive director before the next subsequent
groundwater monitoring event following the updated background period. At least one sample from
each background and point of compliance well will be collected and analyzed during each subsequent
semiannual sampling event.
The executive director may specify an appropriate alternative frequency for repeated sampling and
analysis of the constituents listed in 30 TAC §330.419 during the active life and the closure and post-
closure care period. The alternative frequency will be no less than annual and will be based on factors
such as lithology and hydraulic conductivity of the aquifer and unsaturated zone, groundwater flow
rates, minimum distance of travel from waste to monitoring wells, and resource value of the
uppermost aquifer.
For the purpose of establishing background groundwater quality, the executive director may agree to
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. 14 Revision 02 April 2020
consider analytical data acquired prior to the effective date of this chapter in addition to the data
required in this subsection and in 30 TAC §330.409(b). Not later than 60 days after each sampling
event, the facility will determine whether there has been a statistically significant increase over
background of any tested constituent at any monitoring well. If there has been a statistically
significant increase, the facility will notify the executive director, and any local pollution agency with
jurisdiction that has requested to be notified, in writing within 14 days of this determination. If a
statistically significant increase over background of any tested constituent at any monitoring well has
occurred, the facility will immediately place a notice in the operating record describing the increase
and will establish an assessment monitoring program meeting the requirements of 30 TAC §330.409
within 90 days of the date of the notice to the executive director, except as provided for in 30TAC
§330.407(b)(2) and (3).
If a statistically significant increase over background of any tested constituent at any monitoring well
has occurred, the facility may submit the results of resampling as appropriate for the statistical method
being used within 60 days of determining the statistically significant increase. The resample data may
be used to statistically confirm or disprove the determination made.
If a statistically significant increase over background of any tested constituent at any monitoring well
has occurred and the facility has reasonable cause to think that a source other than a landfill unit
caused the contamination or that the statistically significant increase resulted from error in sampling,
analysis, statistical evaluation, or natural variation in groundwater quality, then the facility may
submit a report providing documentation to this effect. In making a demonstration under this
paragraph, the facility will:
1. Notify the executive director, and any local pollution agency with jurisdiction that has
requested to be notified, in writing within 14 days of determining a statistically significant
increase over background at the compliance point that the facility intends to make a
demonstration under this paragraph;
2. Within 90 days of determining a statistically significant increase, submit a report to the
executive director, and any local pollution agency with jurisdiction that has requested to
be notified, that demonstrates that a source other than a monitored landfill unit caused the
contamination or that the statistically significant increase resulted from error in sampling,
analysis, statistical evaluation, or natural variation in groundwater quality. The report will
be prepared and certified by a qualified groundwater scientist;
3. Not filter the groundwater sample for constituents addressed by the demonstration prior
to laboratory analysis. The executive director may also require facility to provide analyses
of the landfill leachate to support the demonstration; and;
4. Continue to monitor in accordance with the detection monitoring program.
If the facility does not make a demonstration satisfactory to the executive director within 90 days
after the date of the notice to the executive director required under this subsection, the facility will
initiate an assessment monitoring program. The executive director may require the facility to install
additional wells at the point of compliance to further characterize the release.
The facility will submit an annual detection monitoring report within 90 days after the facility's last
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groundwater monitoring event in a calendar year that will include the following information
determined since the previously submitted annual report:
1. A statement regarding whether a statistically significant increase has occurred over
background values in any well during the previous calendar year period and the status of any
statistically significant increase events;
2. The results of all groundwater monitoring, testing, and analytical work obtained or prepared
under the requirements of this permit, including a summary of background groundwater
quality values, groundwater monitoring analyses, statistical calculations, graphs, and
drawings;
3. The groundwater flow rate and direction in the uppermost aquifer. The groundwater flow rate
and direction of groundwater flow will be established using the data collected during the
preceding calendar year's sampling events from the monitoring wells of the detection
monitoring program. The facility will also include in the report all documentation used to
determine the groundwater flow rate and direction of groundwater flow;
4. A contour map of piezometric water levels in the uppermost aquifer based at a minimum upon
concurrent measurement in all monitoring wells. All data or documentation used to establish
the contour map will be included in the report;
5. Recommendation for any changes; and
6. Any other items requested by the executive director.
If the facility determines that the detection monitoring program no longer satisfies the requirements
of this section, the facility will, within 90 days of this determination, submit an application for a
permit amendment or modification to make any appropriate changes to the program.
Three (3) copies (triplicate) of an annual detection monitoring report describing groundwater
sampling and analysis results will be completed on state reporting forms (e.g. TCEQ-0312 or
subsequent versions) and will be submitted to the TCEQ no later than ninety (90) days after the
facility’s last groundwater sampling event in a calendar year and will include information determined
since the previously submitted annual report (30 TAC §330.407(c)). In the event the facility is in
assessment monitoring, three (3) copies (triplicate) of an annual assessment monitoring report
describing groundwater sampling and analyses results will be completed on state reporting forms
(e.g. TCEQ-0312 or subsequent versions) and will be submitted to the TCEQ no later than sixty (60)
days after the facility’s last groundwater sampling event in a calendar year and will include
information determined since the previously submitted annual report (30 TAC §330.409(k)). Data
may also be required to be submitted to the TCEQ on diskette or another format as specified by the
TCEQ.
3.6 ASSESSMENT MONITORING
Assessment monitoring is required whenever the facility determines there has been a statistically
significant increase over background for one or more of the constituents listed in §330.419. If a
statistically significant increase (SSI) over background occurs in a well, the well exhibiting the SSI
and the two immediately adjacent will be sampled for the full set of constituents listed in Appendix
II to 40 Code of Federal Regulations (CFR) Part 258 during the next semiannual monitoring event.
A minimum of one sample will be collected and analyzed for the 40 CFR Part 258, Appendix II
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constituents during each sampling event. For any new constituent(s) detected in the point of
compliance wells as a result of the complete Appendix II analysis, a minimum of four statistically
independent samples from each background well will be collected and analyzed to establish
background levels for the additional constituent(s). After sampling the wells for Appendix II
constituents, the executive director may specify an appropriate subset of wells to be sampled and
analyzed for the Appendix II constituents during assessment monitoring and may delete any of the
Appendix II constituents for a municipal solid waste management unit if the facility can document
that the removed constituents are not reasonably expected to be in or derived from the waste contained
in the unit.
The Executive Director may specify an appropriate alternative frequency for repeated sampling and
analysis for the full set of 40 CFR Part 258, Appendix II constituents during the active life and the
closure and post-closure care period of the unit considering the following factors:
1. Lithology and hydraulic conductivity of the aquifer and unsaturated zone;
2. Groundwater flow rates;
3. Minimum distance of travel from the waste nearest to any point of compliance monitoring
well;
4. Resource value of the uppermost aquifer; and
5. Nature (fate and transport) of any constituents detected in response to this section.
Not later than 60 days after each sampling event, the facility will submit to the executive director
the results from the initial and subsequent sampling events and also place them in the operating
record. Assessment monitoring information and a description of any special waste previously
handled at the facility will be provided to the Executive Director. The facility will also:
1. Within 90 days from the submittal of the results from a sampling event and on at least a
semiannual basis thereafter, resample all wells specified by §330.403(a) and conduct analyses
for all constituents in §330.419 and for those additional constituents in 40 CFR Part 258,
Appendix II that are detected during the initial assessment monitoring sampling event. The
results will be submitted to the executive director not later than 60 days after the sampling
event and will also be placed in the operating record. At least one sample must be collected
and analyzed from each background and point of compliance well at each sampling event.
The executive director may specify an alternative monitoring frequency during the active life
and the closure and post-closure care period for the constituents referred to in this paragraph.
The alternative frequency during the active life and the closure and post-closure care period
will not be less than annual. The alternative frequency will be based on consideration of the
factors described 30 TAC 330.409(c)(1) through (5);
2. Establish background concentrations for any additional Appendix II constituents detected
during the initial assessment monitoring sampling event; and
Establish groundwater protection standards for all constituents in point of compliance wells
detected. The groundwater protection standards will be established in accordance with 30
TAC 330.409(h) or (i).
If the concentrations of all 40 CFR Part 258, Appendix II constituents are shown to be at or below
background values, using the statistical procedures in §330.405(f) for two consecutive sampling
events, the facility will notify the executive director in writing and return to detection monitoring if
approved.
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If the concentrations of any 40 CFR Part 258, Appendix II constituents are above background values,
but all concentrations are below the groundwater protection standard established under 30 TAC
330.409 (h) or (i), using the statistical procedures in §330.405(f), the facility will continue
assessment monitoring.
Not later than 60 days after each sampling event, the facility will determine whether any 40 CFR
Part 258, Appendix II constituents were detected at statistically significant levels above the
groundwater protection standard. If the groundwater protection standard has been exceeded, the
facility will notify the executive director and appropriate local government officials in writing within
seven days of the determination. Assessment monitoring information and a description of any
special waste previously handled at the facility will be provided to the Executive Director. The
facility will also:
1. Characterize the nature and extent of the release by installing additional monitoring wells as
necessary;
2. Install at least one additional monitoring well between the monitoring well with the
statistically significant level and the next adjacent wells along the point of compliance before
the next sampling event and sample these wells in accordance with 30 TAC 330.409(d)(1);
3. Notify in writing all persons that own or occupy the land that directly overlies any part of
the plume of contamination if contaminants have migrated off-site as indicated by sampling
of wells in accordance with 30 TAC 330.409(d)(1); and;
4. Initiate an assessment of corrective measures as required by 30 TAC §330.411 all within 90
days of the notice to the executive director.
The facility may demonstrate that a source other than the monitored solid waste management unit
caused the contamination or that the statistically significant level resulted from error in sampling,
analysis, statistical evaluation, or natural variation in groundwater quality. In making a
demonstration under this paragraph, the facility will:
1. Notify the executive director in writing within 14 days of determining a statistically
significant level above the groundwater protection standard at the point of compliance that
the facility intends to make a demonstration under this paragraph;
2. Within 90 days of determining a statistically significant level above the groundwater
protection standard, submit a report to the executive director that demonstrates that a source
other than the monitored solid waste management unit caused the contamination or that the
statistically significant level resulted from error in sampling, analysis, statistical evaluation,
or natural variation in groundwater quality. The report will be prepared and certified by a
qualified groundwater scientist;
3. Not filter the groundwater samples for constituents addressed by the demonstration prior to
laboratory analysis. The executive director may also require the facility to provide analysis
of landfill leachate to support the demonstration, and;
4. Continue to monitor in accordance with the assessment monitoring program.
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If a successful demonstration is made, the facility will continue monitoring in accordance with the
assessment monitoring program and may return to detection monitoring if the 40 CFR Part 258,
Appendix II constituents are at or below background using the statistical procedures in §330.405(f)
for two consecutive sampling events.
If the facility determines that the assessment monitoring program no longer satisfies the
requirements of this section, the facility will, within 90 days, submit an application for a permit
amendment or modification to make any appropriate changes to the program.
The facility will establish a groundwater protection standard for each 40 CFR Part 258, Appendix II
constituent detected in the point of compliance monitoring wells. The groundwater protection
standard will be:
1. for constituents for which a maximum contaminant level (MCL) has been promulgated under
40 CFR Part 141, Safe Drinking Water Act (codified), §1412, the MCL for that constituent;
2. for constituents for which MCLs have not been promulgated, the background concentration
for the constituent established from wells in accordance with §330.405(d); or
3. for constituents for which the background level is higher than the MCL or health-based levels,
the background concentration.
The executive director may establish an alternative groundwater protection standard for 40 CFR Part
258, Appendix II constituents for which MCLs have not been established. These groundwater
protection standards will be appropriate health-based levels:
1. The level is derived in a manner consistent with United States Environmental Protection
Agency guidelines for assessing the health risks of environmental pollutants (51 FR 33992,
34006, 34014, 34028, September 24, 1986);
2. The level is based on scientifically valid studies conducted in accordance with the Toxic
Substances Control Act Good Laboratory Practice Standards (40 CFR Part 792) or
equivalent;
3. For carcinogens, the level represents a concentration associated with an excess lifetime
cancer risk level (due to continuous lifetime exposure) with the 1 x 10-4 to 1 x 10-6 range;
and
4. For systemic toxicants, the level represents a concentration to which the human population
(including sensitive subgroups) could be exposed to on a daily basis that is likely to be
without appreciable risk of deleterious effects during a lifetime. For purposes of this
document, systemic toxicants include toxic chemicals that cause effects other than cancer or
mutation; or
5. The level is developed in accordance with 30 TAC 350 (relating to Texas Risk Reduction
Program).
In establishing groundwater protection standards, the executive director may consider multiple
contaminants in the groundwater, exposure threats to sensitive environmental receptors, and other
site-specific exposure or potential exposure to groundwater.
The facility will submit an annual assessment monitoring report within 60 days after the facility's
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second semiannual groundwater monitoring event that includes the following information
determined since the previously submitted report:
1. A statement whether a statistically significant level above a groundwater protection standard
has occurred in any well during the previous calendar year period and the status of any
statistically significant level events;
2. The results of all groundwater monitoring, testing, and analytical work obtained or prepared
in accordance with this plan, including a summary of background groundwater quality
values, groundwater monitoring analyses, statistical calculations, graphs, and drawings;
3. The groundwater flow rate and direction in the uppermost aquifer. The groundwater flow
rate and direction of groundwater flow will be established using the data collected during the
preceding calendar year's sampling events from the monitoring wells of the Assessment
Monitoring Program. The facility will also include in the report all documentation used to
determine the groundwater flow rate and direction of groundwater flow;
4. A contour map of piezometric water levels in the uppermost aquifer based, at a minimum,
upon concurrent measurement in all monitoring wells. All data or documentation used to
establish the contour map should be included in the report;
5. Recommendation for any changes; and
6. Any other items requested by the executive director.
3.7 ASSESSMENT OF CORRECTIVE MEASURES
Within 90 days of finding that any of the 40 Code of Federal Regulations Part 258, Appendix II
constituents have been detected at a statistically significant level above the groundwater protection
standards defined under §330.409(h), (i), or (j), the facility will initiate an assessment of corrective
measures. The assessment will be completed within 180 days of its initiation. During this time the
facility will continue to monitor in accordance with the assessment monitoring program as specified
in §330.409. The assessment will include an analysis of the effectiveness of potential corrective
measures in meeting all of the requirements objectives of the remedy described under §330.413
addressing at least the following:
1. Performance, reliability, ease of implementation, and potential impacts of appropriate
potential remedies, including safety impacts, cross-media impacts, and control of
exposure to any residual contamination;
2. Time required to begin and complete the remedy;
3. Costs of remedy implementation; and
4. Institutional requirements such as state or local permit requirements or other
environmental or public health requirements that may substantially affect
implementation of the remedy or remedies.
The facility will discuss the results of the corrective measures assessment, prior to the selection of a
remedy, in a public meeting with interested and affected parties. The facility will arrange for the
meeting and provide notice in accordance with the provisions of 30 TAC §39.501(e)(3).
3.8 SELECTION OF REMEDY
Based on the results of the corrective measures assessment conducted under §330.411, the facility
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will select a remedy that, at a minimum, meets the standards listed in 30 TAC §330.413(b) and is in
accordance with rules of the commission. Within 30 days of completing the assessment of corrective
measures described in 30 TAC §330.411 the facility will submit a report to the executive director
for review and approval and place it in the operating record. The report will describe the remedy or
remedies proposed for selection and the way it or they meet the standards in §330.413(b).
Remedies will:
1. Be protective of human health and the environment;
2. Attain the groundwater protection standard as specified in accordance with §330.409(h),
(i), or (j);
3. Control the source(s) of releases so as to reduce or eliminate, to the maximum extent
practicable, further releases of 40 Code of Federal Regulations Part 258, Appendix II
constituents into the environment that may pose a threat to human health or the
environment; and
4. Comply with standards for management of wastes as specified in §330.415(d).
In selecting a remedy that meets the standards of §330.413(b), the facility will consider the
following evaluation factors:
1. Long- and short-term effectiveness and protectiveness of the potential remedy, along
with the degree of certainty that the remedy will prove successful based on consideration
of:
A. magnitude of reduction of existing risks;
B. magnitude of residual risks in terms of likelihood of further releases due to waste
remaining following implementation of a remedy;
C. type and degree of long-term management required, including monitoring, operation,
and maintenance;
D. short-term risks that might be posed to the community, workers, or the environment
during implementation of such a remedy, including potential threats to human health
and the environment associated with excavation, transportation, re-disposal, or
containment;
E. time until full protection is achieved;
F. potential for exposure of humans and environmental receptors to remaining wastes,
considering potential threats to human health and the environment associated with
excavation, transportation, re-disposal, or containment;
G. long-term reliability of the engineering and institutional controls; and
H. potential need for replacement of the remedy;
2. Effectiveness of the remedy in controlling the source to reduce further releases based on
the extent to which containment practices will reduce further releases and the extent to
which treatment technologies may be used;
3. Ease or difficulty of implementing a potential remedy based on consideration of:
A. degree of difficulty associated with constructing the technology;
B. expected operational reliability of the technologies;
C. need to coordinate with and obtain necessary approvals and permits from other
agencies and regulatory bodies;
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D. availability of necessary equipment and specialists; and
E. available capacity and location of needed treatment, storage, and disposal services;
4. Practicable capability of the facility, including a consideration of the technical and
economic capability; and
5. Degree to which community concerns are addressed by a potential remedy.
The facility will specify as part of the selected remedy a schedule for initiating and completing
remedial activities. The schedule will require the initiation of remedial activities within a reasonable
time approved by the executive director, taking into consideration the following factors:
1. Extent and nature of contamination;
2. Practical capabilities of remedial technologies in achieving compliance with groundwater
protection standards established under §330.409(h), (i), or (j) of this title and other
objectives of the remedy;
3. Availability of treatment or disposal capacity for wastes managed during implementation of
the remedy;
4. Desirability of utilizing technologies that are not currently available but that may offer
significant advantages over available technologies in terms of effectiveness, reliability,
safety, or ability to achieve remedial objectives;
5. Potential risks to human health and the environment from exposure to contamination prior
to completion of the remedy;
6. resource value of the aquifer, including current and future uses; proximity and withdrawal
rate of users; groundwater quantity and quality; potential damage to wildlife, crops,
vegetation, and physical structures from exposure to waste constituents; hydrogeologic
characteristics of the facility and adjacent land; groundwater removal and treatment costs;
and cost and availability of alternative water supplies;
7. practicable capability of the facility; and
8. other relevant factors.
The executive director may determine that remediation of a release of a 40 Code of Federal
Regulations Part 258, Appendix II is not necessary if the facility demonstrates to the satisfaction of
the executive director that:
1. The groundwater is additionally contaminated by substances that have originated from a
source other than a solid waste management unit and those substances are present in
concentrations such that cleanup of the release from the solid waste management unit
would provide no significant reduction in risk to actual or potential receptors; or
2. The constituent is present in groundwater that is not currently or reasonably expected to be
a source of drinking water and is not hydraulically connected with waters to which the
constituent is migrating or is likely to migrate in a concentration that would exceed the
groundwater protection standards established under §330.409(h), (i), or (j) of this title; or
3. Remediation of the release is technically impracticable; or
4. remediation of the release results in unacceptable cross-media impacts.
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A determination by the executive director in accordance with subsection (e) of this section will not
affect the authority of the state to require the facility to undertake source-control measures or other
measures that may be necessary to eliminate or minimize further releases to the groundwater, to
prevent exposure to the groundwater, or to remediate the groundwater to concentrations that are
technically practicable and that significantly reduce threats to human health or the environment.
3.9 IMPLEMENTATION OF THE CORRECTIVE ACTION PROGRAM
Based on the schedule established under 30 TAC §330.413(d) for initiation and completion of
remedial activities, the facility will:
1. establish and implement a corrective action groundwater monitoring program that:
• At least meets the requirements of an assessment monitoring program under 30 TAC
§330.409;
• Indicates the effectiveness of the corrective action remedy; and
• Demonstrates compliance with groundwater protection standards under 30 TAC
§330.405(e);
2. implement the corrective action remedy selected under 30 TAC §330.413; and
3. take any interim measures necessary to ensure the protection of human health and the
environment. Interim measures should, to the greatest extent practicable, be consistent with
the objectives of and contribute to the performance of any remedy that may be required under
30 TAC §330.413. The following factors will be considered by the facility in determining if
interim measures are necessary:
• Time required to develop and implement a final remedy;
• Actual or potential exposure of nearby populations or environmental receptors to
hazardous constituents;
• Actual or potential contamination of drinking water supplies or sensitive ecosystems;
• Further degradation of the groundwater that may occur if remedial action is not
initiated expeditiously;
• Weather conditions that may cause hazardous constituents to migrate or be released;
• Risks of fire or explosion, or potential for exposure to hazardous constituents as a
result of an accident or failure of a container or handling system; and
• Other situations that may pose threats to human health and the environment.
The facility may determine, based on information developed after implementation of the remedy has
begun or other information, that compliance with requirements of §330.413(b) of this title are not
being achieved through the remedy selected. In such cases, the facility will, with approval of the
executive director, implement other methods or techniques that could practicably achieve
compliance with the requirements unless the facility makes the determination and if it is approved
by the executive director. Failure to obtain approval from the executive director for the other
methods and techniques does not relieve the facility of the burden to implement an acceptable
remedy.
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If the facility determines that compliance with requirements under 30 TAC §330.413(b) cannot be
practically achieved with any currently available methods, the facility will:
1. Present to the executive director certification by a qualified groundwater scientist that
compliance with requirements under 30 TAC §330.413(b) cannot be practically
achieved with any currently available methods;
2. Implement alternative measures, with the approval of the executive director, to control
exposure of humans or the environment to residual contamination, as necessary to
protect human health and the environment;
3. Implement alternative measures, with the approval of the executive director, for
control of the sources of contamination, or for removal or decontamination of
equipment, units, devices, or structures that are technically practicable and consistent
with the overall objective of the remedy; and
4. Place a copy of all approved alternative measures in the operating record.
All solid wastes that are managed in accordance with a remedy required under 30 TAC §330.413,
or an interim measure, will be managed in a manner that is protective of human health and the
environment and that complies with applicable Resource Conservation and Recovery Act
requirements.
Upon implementation of a corrective action program, the facility will submit an annual corrective
action report by March 1st every year that includes the following information determined since the
previously submitted report:
1. A statement regarding whether a statistically significant level above a groundwater
Protection standard established in 30 tac §330.409(h), (i), or (j) in any well during
The previous calendar year period has occurred and the status of any statistically
Significant level events;
2. The results of all groundwater monitoring, testing, and analytical work obtained or
Prepared in accordance with the requirements of 30 tac §330.415, including a
Summary of background groundwater quality values, groundwater monitoring
Analyses, statistical calculations, graphs, and drawings;
3. The groundwater flow rate and direction in the uppermost aquifer. The groundwater
Flow rate and direction of groundwater flow will be established using the data
Collected during the preceding calendar year’s sampling events from the monitoring
Wells of the corrective action program. The facility will also include in the report all
documentation used to determine the groundwater flow rate and direction of
Groundwater flow;
4. A contour map of piezometric water levels in the uppermost aquifer based at a
Minimum upon concurrent measurement in all monitoring wells. All data or
Documentation used to establish the contour map should be included in the report;
5. Recommendation for any changes; and
6. Any other items requested by the executive director.
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Remedies selected under §330.413 of this title will be considered complete when:
1. The facility complies with the groundwater protection standards established under 30
TAC §330.409(h), (i), or (j) at all points within the plume of contamination that lies
beyond the groundwater monitoring system established under 30 TAC §330.403;
2. compliance with the groundwater protection standards established under §330.409 (h),
(i), or (j) has been achieved by demonstrating that concentrations of 40 Code of Federal
Regulations Part 258, Appendix II constituents have not exceeded the groundwater
protection standards for a period of three consecutive years, using the statistical
procedures in §330.405(e) and (f) and performance standards in §330.409(h), (i), or (j).
The executive director may specify an alternative length of time during which the facility
will demonstrate that concentrations of 40 Code of Federal Regulations Part 258,
Appendix II constituents have not exceeded the groundwater protection standards. The
alternative length of time will be based on:
• extent and concentration of the release;
• behavior characteristics of the hazardous constituents in the groundwater;
• accuracy of monitoring or modeling techniques, including any seasonal,
meteorological, or other environmental variabilities that may affect the accuracy; and
• characteristics of the groundwater; and
3. all actions required to complete the remedy have been satisfied.
Within 15 days of completion of the remedy, the facility will submit to the executive director and
also place in the operating record a certification by a qualified groundwater scientist that the remedy
has been completed.
Upon submittal of satisfactory certification of the completion of the corrective action remedy, the
executive director may release the facility from the requirements for financial assurance for
corrective action under 30 TAC §330.509.
1. The facility complies with the groundwater protection standards established under 30
TAC §330.409(h), (i), or (j) at all points within the plume of contamination that lies
beyond the groundwater monitoring system established under 30 TAC §330.403;
2. Compliance with the groundwater protection standards established under
§330.409(h), (i), or (j) has been achieved by demonstrating that concentrations of 40
Code of Federal Regulations Part 258, Appendix II constituents have not exceeded
the groundwater protection standards for a period of three consecutive years, using
the statistical procedures in §330.405I and (f) and performance standards in
§330.409(h), (i), or (j). The executive director may specify an alternative length of
time during which the facility will demonstrate that concentrations of 40 Code of
Federal Regulations Part 258, Appendix II constituents have not exceeded the
groundwater protection standards. The alternative length of time will be based on:
• Extent and concentration of the release;
• Behavior characteristics of the hazardous constituents in the groundwater;
• Accuracy of monitoring or modeling techniques, including any seasonal,
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• Meteorological, or other environmental variabilities that may affect the accuracy;
and
• Characteristics of the groundwater; and
3. All actions required to complete the remedy have been satisfied.
Within 15 days of completion of the remedy, the facility will submit to the executive director and
also place in the operating record a certification by a qualified groundwater scientist that the remedy
has been completed.
Upon submittal of satisfactory certification of the completion of the corrective action remedy, the
executive director may release the facility from the requirements for financial assurance for
corrective action under 30 TAC §330.509(b).
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4.0 GROUNDWATER QUALITY
4.1 PLUME OF CONTAMINATION
A description of any plume of contamination that has entered the groundwater is required by 30
TAC §330.63(f)(2). There is no plume of contamination that has entered the groundwater.
Any future plume of contamination identified during groundwater monitoring will be managed in
accordance with 30 TAC Subchapter J – Groundwater Monitoring and Corrective Action.
Attachment 5 - Groundwater Characterization Report
Request for Limited Scope Major Permit Amendment
City of Dumas Municipal Solid Waste Landfill
MSW Permit No. 211B
City of Dumas
Moore County, Texas
Revision 02 April 2020
Revision 00 November 2019
PSC Project # 01094518
City of Dumas, Moore County, MSW Permit No. 211B
Part III, Attachment 5 - Groundwater Characterization Report
April 2020November 2019
PARKHILL, SMITH & COOPER INC. GMP-i 01094518 Revision 00 November 201911.18.19
Revision 02 April 2020
TABLE OF CONTENTS
1.0 GROUNDWATER MONITORING PROGRAM ............................................................. 1
1.1 Site Hydrogeology .............................................................................................................. 1
1.2 Groundwater Flow Direction and Rate ............................................................................... 1
2.0 OPERATIONAL CONSIDERATIONS FOR GROUNDWATER SYSTEM
DESIGN ................................................................................................................................................... 2
2.1 Critical Receptors................................................................................................................ 2
2.2 Relationship of Excavation Bottom-to-Uppermost Aquifer ............................................... 2
2.3 Contaminant Pathway Analysis .......................................................................................... 2
3.0 SUBTITLE D GROUNDWATER MONITORING SYSTEM ....................................... 3
3.1 Monitoring Well Locations ................................................................................................. 3
3.2 Monitor Well Design and Construction .............................................................................. 3
APPENDICES
APPENDIX A – GROUNDWATER MONITORING WELL LOCATIONS
APPENDIX B – GROUNDWATER GRADIENT MAPS
APPENDIX C – HISTORICAL GROUNDWATER LEVELS
11/18/19 For this revision only 04/20/2020 For November 2019 And April 2020 Revision Only
City of Dumas, Moore County, MSW Permit No. 211B
Part III, Attachment 5 - Groundwater Characterization Report
April 2020November 2019
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1.0 GROUNDWATER MONITORING PROGRAM
Originally permitted Groundwater Monitoring Plan was based on the groundwater gradient map from
February 1997. It was noted groundwater flow was radially away from lagoon area, probably
influenced by adjacent unlined wastewater lagoon. Unlined lagoon was possibly a source of recharge
to groundwater and created a localized shift in gradient. The groundwater gradient map, as shown in
Figure 5-1, indicated a groundwater gradient predominantly west for the landfill. Existing
groundwater monitoring system was installed down-gradient from the landfill, as determined by
groundwater gradient plats from the late 1990s. Groundwater gradient gradually returned to regional
gradient of northeast once wastewater lagoon was lined, as shown in Figure 5-2.
1.1 SITE HYDROGEOLOGY
Moore County Soil Survey shows two streams cut through and dissect the High Plains, North
Palo Duro Creek and South Palo Duro Creek. South Palo Duro Creek begins in the western
part of the county, flows eastward, and eventually empties into the Red River Drainage
System. North Palo Duro Creek flows eastward along the north county line, mainly Sherman
County, but swings South into Moore County in several places.
Underground water used in Moore County comes predominately from saturated sand and
gravel in the lower part of the Ogallala Formation. Underlying red beds act as an aquiclude
which kept water from percolating to a greater depth. The Ogallala Formation was cut off
from the Rocky Mountains by Pecos River and Canadian River to the south, with little
recharge of the Ogallala Aquifer from the local rainfall. Minimal recharge results from an
accumulation of rainfall that collects in Playa lakes. In the immediate area of the landfill, the
wastewater lagoon was noted a significant source of recharge when the lagoon was unlined.
Since the lagoon has been lined, groundwater flow in the adjacent area of the landfill has
returned to the natural gradient of northeast.
Amount of water available for use varies according to thickness of sands and gravel in the
Ogallala Formation and depth to red beds. Ogallala Aquifer is generally unconfined in the
region of the site of interest. Depth of groundwater in the general area of the site is
approximately 180-200 feet.
1.2 GROUNDWATER FLOW DIRECTION AND RATE
Groundwater flow direction is northeast based on recent groundwater gradient map from
March 2019 as shown in Figure 5-2. Hydraulic conductivity is approximately 250 gallons per
day per square foot according to the Bureau of Economic Geology’s Report of Investigation
No. 177, “Hydrogeology and Hydrochemistry of the Ogallala Aquifer, Southern High Plains,
Texas Panhandle and Eastern New Mexico”.
City of Dumas, Moore County, MSW Permit No. 211B
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size or other sample data from well, and a site map showing location of all monitoring wells and point
of compliance will be submitted at the same time.
3.1 MONITORING WELL LOCATIONS
Uppermost aquifer beneath the City of Dumas MSW Landfill for Groundwater monitoring
purposes is identified as the Ogallala Aquifer. Four groundwater monitoring wells (MW-1
through MW-4) are already installed around the site perimeter. Locations of these wells were
identified based on groundwater gradient depicted in Figure 5-1, when adjacent wastewater
lagoon was unlined. These four wells are currently being sampled in accordance with
approved Groundwater Sampling and Analysis Plan (GWSAP).
Groundwater flow gradient in the adjacent area of the landfill gradually changed once the
wastewater lagoon was lined. Over time, groundwater gradient returned to regional gradient
of northeast. Change in groundwater gradient necessitates installation of additional
down-gradient monitoring wells north and east of the landfill. Immediately north and east of
the active landfill cell is the wastewater lagoon. Feasible locations for additional monitoring
wells are immediately adjacent to the active landfill cell. Proposed locations for two, new
groundwater monitoring wells are depicted in Figure 5-2.
The two, new monitoring wells will be designated as MW-5 and MW-6, respectively. These
new wells will be sampled semi-annually as down-gradient wells. The existing four
monitoring wells will be up-gradient wells as of March 2019 gradient map. All Wells will be
sampled semiannually. These wells will be sampled in an alternate schedule of two wells every
other six months. For example, if MW-2, MW-3, MW-5, and MW-6 are sampled in Spring,
MW-1, MW-4, MW-5 and MW-6 are to be sampled in FallAll wells will be sampled
semiannually. Point of compliance well spacing will not be exceeded 600 feet. Point of
compliance well spacing will not exceed 600 feet.
3.2 MONITOR WELL DESIGN AND CONSTRUCTION
Five soil borings were conducted at the City of Dumas MSW Landfill, Moore County, Texas
on April 1997. Attachment 4 – Geology Report, includes detailed discussion on locations and
subsurface investigations of borings. Geologic logs of all borings with standard sample
methods are included in Attachment 4, Appendix 7.
In accordance with 30 TAC §330.421 – Monitor Well Construction Specifications, a Texas-
licensed driller will install monitoring wells according to applicable regulations. Construction
of monitoring wells will provide integrity, representative samples, prevent migration of water
in the bore hole. Well construction shall follow prescribed specifications below. A licensed
professional geoscientist or engineer familiar with area geology will supervise monitoring
well installation, development, and provide a boring log. Equivalent alternatives to
City of Dumas, Moore County, MSW Permit No. 211B
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construction specifications in TCEQ rules may be used if prior written approval is obtained
from the executive director.
Monitoring well construction will be completed in accordance with 30 TAC §330.63,
§330.403, and §330.421. Boring diameter will be at least 4 inches larger than the casing
diameter. When boring is in hard rock, executive director may approve the smaller annulus.
A boring log will be made by or under the supervision of a licensed professional geoscientist
or engineer familiar with area geology, and will be sealed, signed, and dated by the licensed
professional.
The well shall be drilled by a method that will allow installation of the casing, screen, etc.,
and that will not introduce contaminants into the borehole or casing. Drilling techniques used
for boring shall take into account the materials to be drilled, depth to groundwater, total depth
of the hole, adequate soil sampling, and other such factors that affect the selection of the
drilling method. If any fluids are necessary in drilling or installation, then clean, treated city
water shall be used; other fluids must be approved in writing by the executive director before
use. If city water is used, a current chemical analysis of the city water shall be provided with
the monitor-well report.
The well casing will be 2 to 4 inches in diameter, National Science Foundation-certified
polyvinyl chloride (PVC) Schedule 40 or 80 pipe, flush-thread, screw joint (no glue or
solvents), polytetrafluorethylene (PTFE, such as Teflon) tape or O-rings in joints, and no
collar couplings. Top of casing will be at least 2 feet above ground level. Where high levels
of volatile organic compounds (VOCs) or corrosive compounds are anticipated, stainless steel
or PTFE casing and screen may be used, subject to executive director approval. 4-inch
diameter casing is recommended because it allows larger volume samples to be obtained and
provides easier access for development, pumps, and repairs. Casing will be cleaned and
packaged at the manufacturer and packaging include a PVC wrapping on each section of
casing to protect from contamination before installation. Casing will be free of ink, labels, or
other markings. Casing (and screen) will be centered in the hole to allow installation of a good
filter pack and annular seal. Centralizers are recommended on wells over 20 feet in length, but
may not be needed if wells are installed through hollow-stem augers. Top of casing will be
protected by a threaded/slip-on top cap or sealing cap or screw-plug seal inserted into top of
casing. Cap will be vented to prevent buildup of methane or other gases and designed to
prevent moisture from entering well.
Screen will be compatible with casing and should generally be same material. Screen will not
involve use of any glues or solvents for construction. A wire-wound screen is recommended
to provide maximum inflow area. Field-cut slots are not permitted for well screen. Filter cloth
will not be used. A blank-pipe sediment trap, typically 1 to 2 feet, should be installed below
screen. A bottom cap will be placed on the bottom of sediment trap. Sediment trap will not
extend through the lower confining layer of water-bearing zone tested. Screen sterilization
methods are same as casing. Selection of screen size opening should be by a person
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experienced with such work and include consideration of distribution of particle sizes in
water-bearing zone and filter pack surrounding screen. Screen opening will not be larger than
the smallest fraction of filter pack.
Filter pack, placed between screen and well bore, will consist of prepackaged, inert, clean
silica sand or glass beads, extending 1 to 4 feet above top of screen. Open stockpile sources
of sand or gravel will not be used. Filter pack usually has a 30-percent finer grain size four-
to-10 times larger than the 30-percent finer grain size of water-bearing zone. Filter pack should
have a uniformity coefficient less than 2.5 and placed with a tremie pipe to ensure material
completely surrounds screen and casing without bridging. Tremie pipe will be steam cleaned
before first well and each subsequent well.
Annular seal will be placed on top of filter pack and be at least 2 feet thick, placed in zone of
saturation to maintain hydration. Seal will be composed of coarse-grain sodium bentonite,
coarse-grit sodium bentonite, or bentonite grout. Special care will be taken to ensure fine
material or grout does not plug underlying filter pack. Placement of a few inches of
prepackaged clean fine sand on top of filter pack will help prevent migration of annular seal
material into filter pack. Seal will be placed on top of filter pack with a tremie pipe to ensure
good distribution and should be tamped with a rod to determine seal is thick enough. Bentonite
will be hydrated with clean water before any further activities on well and left to stand until
hydration is complete (eight to 12 hours, depending on grain size of bentonite). If bentonite-
grout (without cement) casing seal is used in well bore, it may replace annular seal described
herein.
A casing seal will be placed on top of annular seal to prevent fluids and contaminants from
entering borehole from the surface. Casing seal will consist of a commercial bentonite grout
or cement-bentonite mixture. Drilling spoil, cuttings, or other native materials are not
permitted for use as casing seal. Quick-setting cements are not permitted for use because
contaminants may leach into groundwater. Top of casing seal will be 2 - 5 feet from surface.
High-quality structural-type concrete will be placed from top of casing seal (2 - 5 feet below
surface) continuously to top of ground to form a pad at the surface. This formed surface pad
will be at least 6 inches thick but not less than 4 (preferably 6) feet square or 5 (preferably 6)
feet in diameter. Pad will contain sufficient reinforcing steel to ensure structural integrity in
the event soil support is lost. Top of pad will slope away from well bore to edges to prevent
ponding of water around casing or collar.
A steel protective pipe collar will be placed around casing "stickup" to protect from damage
and unwanted entry. Collar will be set at least 1 foot into surface pad during construction and
should extend at least 3 inches above top of well casing (and top cap, if present). Top of collar
will have a lockable, hinged-top flap or cover. A sturdy lock will be installed, maintained, and
kept locked when well is not bailed/purged or sampled. Well number or other designation will
City of Dumas, Moore County, MSW Permit No. 211B
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be marked permanently on protective steel collar (it is useful to mark total depth of well and
elevation on collar).
Where monitoring wells are likely to be damaged by moving equipment or located in heavily
traveled areas, a protective barrier will be installed. Barrier will consist of three or four 6- to
12-inch diameter pipes set in concrete just off concrete pad. Pipes may be joined by pipes
welded between them.
Upon completion of a monitoring well, location of well and all appropriate elevations
associated with top-well equipment will be surveyed by a registered professional surveyor.
Elevation will be surveyed to nearest 0.01 foot above mean sea level (with year of sea-level
datum shown). Point on well casing for elevation determined will be permanently marked on
casing. Location will be given in terms of latitude and longitude at least to nearest tenth of a
second or accurately located with respect to landfill grid system described in 30 TAC
§330.143(b)(5).
If wells are installed in ususual conditions, all aspects must be approved by the TCEQ
Executive Director. If any fluid is required in drilling monitoring wells, clean, treated water
shall be used and a chemical analysis provided to executive director. No glue or solvents will
be used in monitoring well construction.
After installation, monitoring wells will be developed to remove drilling artifacts and open
water-bearing zone for maximum flow until all water used/affected during drilling activities
is removed and field measurements of pH, specific conductance, and temperature are
stabilized. A registered professional land surveyor will survey well location and elevation.
Within 30 days of completion of a monitoring well or other part of monitoring system, an
installation report will be submitted to TCEQ. Report will include construction and installation
details for each well on forms available from commission, site map drawn to scale showing
location of all monitoring wells, and relevant point(s) of compliance, well elevations to nearest
0.01 foot above msl (with year of datum shown), latitude and longitude, or landfill grid
location of each well, copies of detailed geologic logs including soil sample data, and copies
of driller reports required by other agencies.
Damaged monitoring wells no longer usable will be reported to executive director to
determine whether to replace or repair well. In accordance with 30 TAC §305.70, if a
compromised well requires replacement, a permit modification request will be submitted
within 45 days of discovery.
Plugging and abandoning monitoring wells will be performed in accordance with 16 TAC
§76.702 and §76.1004. No abandonment will be performed without prior written
authorization.
City of Dumas, Moore County, MSW Permit No. 211B
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All parts of groundwater monitoring system will be operated and maintained so they perform
at least to design specifications through life of groundwater monitoring program. Facility must
notify executive director if changes in site construction, operation, or changes in adjacent
property affect or are likely to affect direction and rate of groundwater flow and potential for
detecting groundwater contamination from the facility.
Dumas Municipal Solid Waste LandfillPart III, Attachment 11 – Groundwater Sampling and Analysis Plan
PARKHILL, SMITH & COOPER INC. 01094518
10.15.19
ATTACHMENT 11
GROUNDWATER SAMPLING AND ANALYSIS PLAN (GWSAP)
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. i Revision 02 April 2020Revised 11.18.19
TABLE OF CONTENTS 1.0 STATEMENT OF PURPOSE .................................................................................................... 1
1.1 Field Setup and Well Inspection .................................................................................................... 1 1.2 Water-Level Measurements ........................................................................................................... 2
1.3 Well Purging .................................................................................................................................. 2
1.4 Timing and Order Of Sampling ..................................................................................................... 3
1.5 Sample Collection, Preservation, and Shipment ............................................................................ 4
1.5.1 Sample Collection ................................................................................................................. 4
1.5.2 Field Measurements .............................................................................................................. 5 1.5.3 Sample Containers and Labeling .......................................................................................... 5 1.5.4 Sample Preservation and Shipment ...................................................................................... 5
1.6 Quality Assurance and Quality Control ......................................................................................... 6
1.7 Chain-Of-Custody Documentation ................................................................................................ 6
1.8 Field Documentation ..................................................................................................................... 7
1.9 Equipment Decontamination ......................................................................................................... 7
2.0 LABORATORY QUALITY ASSURANCE AND QUALITY CONTROL ........................... 8
3.0 GROUNDWATER MONITORING REQUIREMENTS ...................................................... 10
3.1 Analyzed Constituents ................................................................................................................. 10
3.2 Background Monitoring ............................................................................................................... 10
3.3 Statistically Significant IncreaseConstituents and Verification Resampling ............................... 12
3.4 Groundwater Analysis Result Submittals .................................................................................... 13
3.5 Detection Monitoring ................................................................................................................... 13
3.6 Assessment Monitoring ............................................................................................................... 14
3.7 Assessment of Corrective Measures ............................................................................................ 18
3.8 Selection of Remedy .................................................................................................................... 18
3.9 Implementation of the Corrective Action Program ..................................................................... 22
4.0 GROUNDWATER QUALITY ................................................................................................. 26
4.1 Plume of Contamination .............................................................................................................. 25
APPENDICES
APPENDIX A – LABORATORY CHECKLIST
APPENDIX B – FLOWCHART FOR SELECTING STATISTICAL METHODS
APPENDIX C – GROUNDWATER MONITORING SYSTEM PLAN
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. 4 Revision 02 April 2020Revised 11.18.19
If contamination is known to be present in one or more wells at the Municipal Solid Waste Landfill
(MSWLF), sampling should begin at the well that is known to be least contaminated and end with
the most contaminated well. Where no contamination is known, the order should generally be from
the well with the highest water-level elevation to the one with the lowest elevation (upgradient to
downgradient) for each group of wells completed in a water-bearing unit.
1.5 SAMPLE COLLECTION, PRESERVATION, AND SHIPMENT
Sample collection, preservation and shipment to the laboratory are probably the most important steps
in the sampling process. Physical or chemical changes occur in ground-water samples no matter how
carefully sampling is done and can certainly occur if inappropriate sampling devices, collection
procedures, preservations and temperature controls, or inadequate shipment is employed.
The method and federal regulatory program requirements for sample management aspects will be
followed for all methods of testing and, if violated, have the data flagged and qualified. Field
personnel will follow correct procedures for recording relevant characteristics and other data relating
to the sampling operations that form part of the testing or measurement that is undertaken. Chain-of-
custody records and field notes will include the sampling procedure used, the identification of the
sampler, environmental conditions (if relevant), diagrams or other equivalent means to identify the
sampling location and all associated sample identification numbers.
1.5.1 Sample Collection
Groundwater samples will be collected using a new, disposable bailer, dedicated pump, or portable
pump. Sample collection should be initiated within 4824 hours of purging but, with prior TCEQ
approval, may occur up to seven days after purging to allow adequate recovery in low-yield wells.
Groundwater samples shall not be filtered in the field. Based on water-level measurements taken
before well purging, sampling should proceed from well with highest groundwater elevation to those
with successively lower elevations. This sequence should be followed unless contamination is known
to be present. If contamination is present, monitoring wells not likely to be contaminated must be
sampled before those known to be contaminated, following these sampling procedures:
• Temperature, specific conductance, and pH of a sample collected in a container not used for
analysis should be measured in that order and recorded in log book.
• Samples should be collected by slowly discharging water from dedicated/non-dedicated
pump/bailer directly into each required container. If dedicated/non-dedicated pumps are used
for sample collection, flow rate will be reduced after purging. Flow rates for pumps used for
sampling will be carefully controlled and maintained at less than 1 liter per minute (0.26 gpm)
to avoid degassing samples. Repeat as necessary to collect sufficient sample for analysis. If
bailer used, ensure bailer and string do not touch the ground during sampling.
• Under normal conditions, sample bottles must be filled in order of decreasing volatilization
sensitivity. Generally, that will be in the following order, as applicable:
o Volatile organic compounds (VOCs)
o Total metals
o Dissolved metals (if collected)
o Other inorganic parameters (if collected)
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
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Samples should be placed in re-sealable bags, then in an ice chest or other insulated container
packed with sufficient ice or re-freezable materials to keep them as near 4°C as possible. Sample
containers must be packed to prevent breakage. Under no circumstances, should water ice or dry
ice be used for samples shipped via public transportation.
1.6 QUALITY ASSURANCE AND QUALITY CONTROL
To document sample collection and handling procedures utilized in field have not affected quality of
groundwater samples, blanks are to be prepared and analyzed. Blanks consist of one trip blank and
one field blank per sampling event.
Trip blank is prepared by filling a water sample container with Type II reagent-grade water,
transporting to site, handling as sample, and transporting to laboratory for analysis. A field blank is
prepared by filling sample container with Type II reagent-grade water in field adjacent to a well being
sampled, and transporting to laboratory for analysis. Field blank should be prepared at a
downgradientnwind well. Field and trip blanks are to be analyzed for VOCs only. Equipment blanks
should be collected once per day or sampling event and that field duplicates should be collected once
every sampling event. Indicate that groundwater samples should be sent to the laboratory within 48
hours of collection.
1.7 CHAIN-OF-CUSTODY DOCUMENTATION
A suitable chain-of-custody (COC) document must accompany the samples at every step from field
to laboratory and must be signed by each party handling the samples, from sampler through
transported to the laboratory, to document the possession of the samples at all times. Proper COC
procedures are essential to ensure sample integrity and to provide legally and technically defensible
data.
COC documentation is maintained on a chain-of-custody record form as collected. Information on
COC record form includes:
• Project name and number (includes site name)
• Site location
• Sample number
• Sample date and time
• Sample type
• Number and type of sample containers
• Analyses required
• Sample preservative
• Lab destination
• Carrier/shipping number
• Special instructions
• Spaces for signatures of sampler(s) and everyone assuming sample custody
The COC record form must contain the signatures of anyone assuming custody of the samples. Each
time custody changes hands, the party releasing the samples should sign under "Relinquished By"
and record the date and time. The party receiving the samples should sign under the heading
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
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"Received By" and record the date and time. The COC form is typically provided by the analytical
laboratory.
If available or required, COC seals can be placed over the shipping container lid or sample container
lids to deter sample tampering by unauthorized parties.
1.8 FIELD DOCUMENTATION
Information related to a sampling event and field activities must be thoroughly documented on field
data sheets or field log book. All entries should be legible and made in black, indelible ink. Entry
errors should be crossed out with a single line, dated, and initialed by the person making the
corrections. Below is an outline of the information that should be documented during field activities.
• Project name and number
• Date and time of all activities
• Weather conditions
• Sampling personnel
• Field instrument calibration remarks
• Well identification number
• Well description, including casing size
• Description of well condition
• Initial water-level measurement with point of reference (top of casing) and time of
measurement
• Depth to the well bottom with point of reference (from well records)
• Well volume calculations
• Presence and thicknesses of immiscible layers, if present
• Physical description of groundwater (color, odor, turbidity)
• Time starting and ending well purging, volume purged, and method of removal
• Sampling equipment and remarks
• Initial temperature, conductivity, and pH measurements
• Sample time and date
• Description of sample
• Quality control remarks
1.9 EQUIPMENT DECONTAMINATION
Reusable sampling equipment and measurement instruments coming in contact with groundwater in
wells or samples are to be decontaminated before use at each well location. Decontamination
standards or equivalent procedures are to be followed for nondedicated well purging and sampling
equipment. Equipment should be washed with non-phosphate detergent and rinsed with tap water and
Type II reagent-grade water. Sampling equipment should be thoroughly dried before use to ensure
residual cleaning agents are not carried to sample. Any equipment used for dedicated pumps reused
at other wells will follow the same de-contamination requirements. Disposable bailers and
nondedicated bailer line must be discarded along with disposable health and safety garments. Water
and cleaning agents are to be disposed in accordance with applicable regulations.
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
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The quarterly sampling will provide data representative of each of the four seasons of the year. The
analytical parameters to be tested include those metal constituents presented in Table 11.1.
Background quarterly sampling will be collected and analyzed for the total metals constituents
referenced in Title 30 TAC §330.419(a) and presented in Table 11.1. Background values for all metals
listed in 40 Code of Federal Regulations (CFR) Part 258, Appendix I will be calculated using
intrawell prediction limits. Background values for volatile organic compounds (VOCs) listed in 40
Code of Federal Regulations (CFR) Part 258, Appendix I are set by practical quantitation limits
(PQL) listed in the TCEQ letter dated May 25, 2010; whereas, any exceedance of the listed PQL for
the given VOC constituent is an exceedance of background for that VOC constituent. Upon
completion of background monitoring and during background updates, the facility will evaluate the
data to ensure that they are representative of background groundwater constituent concentrations
unaffected by waste management activities or other sources of contamination. The evaluation will be
documented in a report and submitted to the executive director before the next subsequent
groundwater monitoring event following the updated (or initial) background period.
The executive director may establish an alternative list of inorganic indicator constituents for a
municipal solid waste management unit in lieu of some or all of the heavy metals (constituents (1) -
(15) in the table located in 40 CFR Part 258, Appendix I) if the alternative constituents provide a
reliable indication of inorganic releases from the municipal solid waste management unit to the
groundwater. The executive director may also add inorganic or organic constituents to those to be
tested if they are reasonably expected to be in or derived from the waste contained in the unit or if
they are likely to provide a useful indication of releases from the municipal solid waste management
unit to the groundwater. In determining alternative or additional constituents, the executive director
shall consider the following factors:
(1) the types, concentrations, quantities, and persistence of waste constituents in wastes at the
municipal solid waste management unit;
(2) the mobility, stability, and persistence of waste constituents or their reaction products in
the unsaturated and saturated zones adjacent to or beneath the municipal solid waste
management unit;
(3) the detectability of indicator constituents, waste constituents, and reaction products in the
groundwater; and
(4) the concentrations and coefficients of variation of monitoring parameters or constituents
in the groundwater background.
In accordance with 30 TAC 330.407 (a)(2), the executive director may specify an appropriate
alternative frequency for repeated sampling and analysis of the constituents listed in §330.419 for the
new monitoring wells (MW-5 and MW-6). The alternative frequency will be no less than annual and
will be based on factors such as lithology and hydraulic conductivity of the aquifer and unsaturated
zone, groundwater flow rates, minimum distance of travel from waste to monitoring wells, and
resource value of the uppermost aquifer.
For the purpose of establishing background groundwater quality, the executive director may agree to
consider analytical data acquired prior to the effective date of Chapter 30 of the Texas Administrative
Code in addition to the data required in this section and in 30 TAC §330.409(b).
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
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3.3 STATISTICALLY SIGNIFICANT INCREASE CONSTITUENTS AND VERIFICATION
RESAMPLING
If an individual well (or sampling point) comparison procedure is used to compare an individual
compliance well constituent concentration with background constituent concentrations or a
groundwater protection standard, the test shall be done at a Type I error level no less than 0.01. If a
control-chart approach is used to evaluate groundwater monitoring data, the specific type of control
chart and its associated parameter values shall be protective of human health and the environment.
These parameters shall be determined after considering the number of samples in the background
database, the data distribution, and the range of the concentration values for each constituent of
concern.
Statistical analysis of constituents in Table 11.1 (i.e. 30 TAC §330.419) will commence within six
(6) months after completion of the eight (8) quarterly background events. An initial
excedanceStatistical Significant Increase (SSI) will be based on any compound detected in any
monitor well at a concentration above the specific constituent’s statistical limit. If an initial
SSIexceedance of any constituent is indicated at any monitoring well, a notice will be made to the
Executive Director (ED), and any local pollution agency with jurisdiction that has requested to be
notified, in writing within fourteen (14) days of the determination of the initial exceedanceSSI.
In the event of an initial exceedanceSSI for any constituent listed in 30 TAC §330.419, verification
resampling will be completed within 60 days of the notification of the initial exceedanceSSI in
accordance with 30 TAC §330.407(b)(2).
In the event that one or more constituents listed in 30 TAC §330.419 are confirmed through
verification resampling as a Statistically Significant Increase (an SSI) in any monitoring well and no
source other than the MSWLF, error, or natural variation is demonstrated the facility will immediately
place a notice in the operating record describing the increase. The notice may be in the form of a
groundwater monitoring report.
If a statistically significant increase over a background limit of any tested constituent at any
monitoring well has occurred and the owner or operator has reasonable cause to think that a source
other than a landfill caused the contamination or that the statistically significant increase resulted
from error in sampling, analysis, or statistical evaluation, or from natural variation in groundwater
quality, then the owner or operator may submit a report providing documentation to this effect, in
accordance with 330.407(b)(3). The report is commonly referred to as an “alternate source
demonstration (ASD),” but may be a demonstration of an error or of natural variation, instead of a
source other than the landfill.
An owner or operator pursuing an ASD must first notify the executive director of the TCEQ (and any
local pollution agency with jurisdiction that has requested to be notified) in writing, within 14 days
of determining an SSI over a background limit, that the owner or operator intends to make the
demonstration. The ASD must be submitted within 90 days of determining an SSI.
If the ASD is satisfactory to the executive director, the facility may continue detection monitoring. If
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MSW Permit 211B Ground Water Sampling and Analysis Plan
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the ASD is not satisfactory, the owner or operator must proceed with assessment monitoring.
3.4 GROUNDWATER ANALYSIS RESULT SUBMITTALS
Statistical analysis using a prediction limit procedure will be performed in accordance with Appendix
B no later than 60 days after each semi-annual sampling event. In the event that statistical analysis
of the groundwater analytical results indicates an initial statistically significant increase (SSI) from
background of any tested constituent at any point of compliance well, a notice in writing to the
Executive Director, and any local pollution agency with jurisdiction that has requested to be notified,
will be submitted within fourteen (14) days of the determination of the SSI (30 TAC §330.407(b)).
The groundwater chemistry data will be evaluated to determine statistically significant increases from
background values for each of the constituents monitored. The statistical analyses will be performed
in accordance with 30 TAC 330.405(e) and (f). A prediction interval method is anticipated to be
used. A prediction interval procedure is specifically allowed in 30 TAC §330.405(e)(3). Statistical
analyses will be performed using Sanitas®, a commercial software program developed by Sanitas
Technologies, Inc. or another comparable computer program.
3.5 DETECTION MONITORING
The monitoring frequency for all constituents listed in 30 TAC §330.419 will be at least semi-annual
during the active life of the facility, the closure and the post-closure care period, unless another
sampling schedule is approved by the TCEQ.
A minimum of four statistically independent samples from each background and each point of
compliance well will be collected and analyzed for the constituents listed in 30 TAC §330.419 to
establish background groundwater quality. Initial background sampling for a well will be completed
on a quarterly basis, unless an alternative schedule is approved by the executive director. Background
data sets may be updated once every two years with semiannual detection monitoring results that are
demonstrated to be representative of background groundwater quality. Upon completion of
background monitoring and during background updates, the facility will evaluate the background data
to ensure that the data are representative of background groundwater constituent concentrations
unaffected by waste management activities or other sources of contamination. The evaluation will
be documented in a report and submitted to the executive director before the next subsequent
groundwater monitoring event following the updated background period. At least one sample from
each background and point of compliance well will be collected and analyzed during each subsequent
semiannual sampling event.
The executive director may specify an appropriate alternative frequency for repeated sampling and
analysis of the constituents listed in 30 TAC §330.419 during the active life and the closure and post-
closure care period. The alternative frequency will be no less than annual and will be based on factors
such as lithology and hydraulic conductivity of the aquifer and unsaturated zone, groundwater flow
rates, minimum distance of travel from waste to monitoring wells, and resource value of the
uppermost aquifer.
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MSW Permit 211B Ground Water Sampling and Analysis Plan
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For the purpose of establishing background groundwater quality, the executive director may agree to
consider analytical data acquired prior to the effective date of this chapter in addition to the data
required in this subsection and in 30 TAC §330.409(b). Not later than 60 days after each sampling
event, the facility will determine whether there has been a statistically significant increase over
background of any tested constituent at any monitoring well. If there has been a statistically
significant increase, the facility will notify the executive director, and any local pollution agency with
jurisdiction that has requested to be notified, in writing within 14 days of this determination. If a
statistically significant increase over background of any tested constituent at any monitoring well has
occurred, the facility will immediately place a notice in the operating record describing the increase
and will establish an assessment monitoring program meeting the requirements of 30 TAC §330.409
within 90 days of the date of the notice to the executive director, except as provided for in 30 TAC
§330.409(b)(2) and (3)30TAC§ 330.407(b)(2) and (3) .
If a statistically significant increase over background of any tested constituent at any monitoring well
has occurred, the facility may submit the results of resampling as appropriate for the statistical method
being used within 60 days of determining the statistically significant increase. The resample data may
be used to statistically confirm or disprove the determination made.
If a statistically significant increase over background of any tested constituent at any monitoring well
has occurred and the facility has reasonable cause to think that a source other than a landfill unit
caused the contamination or that the statistically significant increase resulted from error in sampling,
analysis, statistical evaluation, or natural variation in groundwater quality, then the facility may
submit a report providing documentation to this effect. In making a demonstration under this
paragraph, the facility will:
1. Notify the executive director, and any local pollution agency with jurisdiction that has
requested to be notified, in writing within 14 days of determining a statistically significant
increase over background at the compliance point that the facility intends to make a
demonstration under this paragraph;
2. Within 90 days of determining a statistically significant increase, submit a report to the
executive director, and any local pollution agency with jurisdiction that has requested to
be notified, that demonstrates that a source other than a monitored landfill unit caused the
contamination or that the statistically significant increase resulted from error in sampling,
analysis, statistical evaluation, or natural variation in groundwater quality. The report will
be prepared and certified by a qualified groundwater scientist;
3. Not filter the groundwater sample for constituents addressed by the demonstration prior
to laboratory analysis. The executive director may also require facility to provide analyses
of the landfill leachate to support the demonstration; and;
4. Continue to monitor in accordance with the detection monitoring program.
If the facility does not make a demonstration satisfactory to the executive director within 90 days
after the date of the notice to the executive director required under this subsection, the facility will
initiate an assessment monitoring program. The executive director may require the facility to install
additional wells at the point of compliance to further characterize the release.
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MSW Permit 211B Ground Water Sampling and Analysis Plan
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The facility will submit an annual detection monitoring report within 90 days after the facility's last
groundwater monitoring event in a calendar year that will include the following information
determined since the previously submitted annual report:
1. A statement regarding whether a statistically significant increase has occurred over
background values in any well during the previous calendar year period and the status of any
statistically significant increase events;
2. The results of all groundwater monitoring, testing, and analytical work obtained or prepared
under the requirements of this permit, including a summary of background groundwater
quality values, groundwater monitoring analyses, statistical calculations, graphs, and
drawings;
3. The groundwater flow rate and direction in the uppermost aquifer. The groundwater flow rate
and direction of groundwater flow will be established using the data collected during the
preceding calendar year's sampling events from the monitoring wells of the detection
monitoring program. The facility will also include in the report all documentation used to
determine the groundwater flow rate and direction of groundwater flow;
4. A contour map of piezometric water levels in the uppermost aquifer based at a minimum upon
concurrent measurement in all monitoring wells. All data or documentation used to establish
the contour map will be included in the report;
5. Recommendation for any changes; and
6. Any other items requested by the executive director.
If the facility determines that the detection monitoring program no longer satisfies the requirements
of this section, the facility will, within 90 days of this determination, submit an application for a
permit amendment or modification to make any appropriate changes to the program.
Three (3) copies (triplicate) of an annual detection monitoring report describing groundwater
sampling and analysis results will be completed on state reporting forms (e.g. TCEQ-0312 or
subsequent versions) and will be submitted to the TCEQ no later than ninety (90) days after the
facility’s last groundwater sampling event in a calendar year and will include information determined
since the previously submitted annual report (30 TAC §330.407(c)). In the event the facility is in
assessment monitoring, three (3) copies (triplicate) of an annual assessment monitoring report
describing groundwater sampling and analyses results will be completed on state reporting forms
(e.g. TCEQ-0312 or subsequent versions) and will be submitted to the TCEQ no later than sixty (60)
days after the facility’s last groundwater sampling event in a calendar year and will include
information determined since the previously submitted annual report (30 TAC §330.409(k)). Data
may also be required to be submitted to the TCEQ on diskette or another format as specified by the
TCEQ.
3.6 ASSESSMENT MONITORING
Assessment monitoring is required whenever the facility determines there has been a statistically
significant increase over background for one or more of the constituents listed in §330.419. If a
statistically significant increase (SSI) over background occurs in a well, the well exhibiting the SSI
and the two immediately adjacent point of compliance wells will be sampled for the full set of
constituents listed in Appendix II to 40 Code of Federal Regulations (CFR) Part 258 during the next
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MSW Permit 211B Ground Water Sampling and Analysis Plan
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semiannual monitoring event. A minimum of one sample will be collected and analyzed for the 40
CFR Part 258, Appendix II constituents during each sampling event. For any new constituent(s)
detected in the point of compliance wells as a result of the complete Appendix II analysis, a minimum
of four statistically independent samples from each background well will be collected and analyzed
to establish background levels for the additional constituent(s). After sampling the wells for Appendix
II constituents, the executive director may specify an appropriate subset of wells to be sampled and
analyzed for the Appendix II constituents during assessment monitoring and may delete any of the
Appendix II constituents for a municipal solid waste management unit if the facility can document
that the removed constituents are not reasonably expected to be in or derived from the waste contained
in the unit.
The Executive Director may specify an appropriate alternative frequency for repeated sampling and
analysis for the full set of 40 CFR Part 258, Appendix II constituents during the active life and the
closure and post-closure care period of the unit considering the following factors:
1. Lithology and hydraulic conductivity of the aquifer and unsaturated zone;
2. Groundwater flow rates;
3. Minimum distance of travel from the waste nearest to any point of compliance monitoring
well;
4. Resource value of the uppermost aquifer; and
5. Nature (fate and transport) of any constituents detected in response to this section.
Not later than 60 days after each sampling event, the facility will submit to the executive director
the results from the initial and subsequent sampling events and also place them in the operating
record. Assessment monitoring information and a description of any special waste previously
handled at the facility will be provided to the Executive Director. The facility will also:
1. Within 90 days from the submittal of the results from a sampling event and on at least a
semiannual basis thereafter, resample all wells specified by §330.403(a) and conduct analyses
for all constituents in §330.419 and for those additional constituents in 40 CFR Part 258,
Appendix II that are detected during the initial assessment monitoring sampling event. The
results will be submitted to the executive director not later than 60 days after the sampling
event and will also be placed in the operating record. At least one sample must be collected
and analyzed from each background and point of compliance well at each sampling event.
The executive director may specify an alternative monitoring frequency during the active life
and the closure and post-closure care period for the constituents referred to in this paragraph.
The alternative frequency during the active life and the closure and post-closure care period
will not be less than annual. The alternative frequency will be based on consideration of the
factors described 30 TAC 330.409(c)(1) through (5);
2. Establish background concentrations for any additional Appendix II constituents detected
during the initial assessment monitoring sampling event; and
Establish groundwater protection standards for all constituents in point of compliance wells
detected. The groundwater protection standards will be established in accordance with 30
TAC 330.409(h) or (i).
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MSW Permit 211B Ground Water Sampling and Analysis Plan
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If the concentrations of all 40 CFR Part 258, Appendix II constituents are shown to be at or below
background values, using the statistical procedures in §330.405(f) for two consecutive sampling
events, the facility will notify the executive director in writing and return to detection monitoring if
approved.
If the concentrations of any 40 CFR Part 258, Appendix II constituents are above background values,
but all concentrations are below the groundwater protection standard established under 30 TAC
330.409 (h) or (i), using the statistical procedures in §330.405(f), the facility will continue
assessment monitoring.
Not later than 60 days after each sampling event, the facility will determine whether any 40 CFR
Part 258, Appendix II constituents were detected at statistically significant levels above the
groundwater protection standard. If the groundwater protection standard has been exceeded, the
facility will notify the executive director and appropriate local government officials in writing within
seven days of the determination. Assessment monitoring information and a description of any
special waste previously handled at the facility will be provided to the Executive Director. The
facility will also:
1. Characterize the nature and extent of the release by installing additional monitoring wells as
necessary;
2. Install at least one additional monitoring well between the monitoring well with the
statistically significant level and the next adjacent wells along the point of compliance before
the next sampling event and sample these wells in accordance with 30 TAC 330.409(d)(1);
3. Notify in writing all persons that own or occupy the land that directly overlies any part of
the plume of contamination if contaminants have migrated off-site as indicated by sampling
of wells in accordance with 30 TAC 330.409(d)(1); and;
4. Initiate an assessment of corrective measures as required by 30 TAC §330.411 all within 90
days of the notice to the executive director.
The facility may demonstrate that a source other than the monitored solid waste management unit
caused the contamination or that the statistically significant level resulted from error in sampling,
analysis, statistical evaluation, or natural variation in groundwater quality. In making a
demonstration under this paragraph, the facility will:
1. Notify the executive director in writing within 14 days of determining a statistically
significant level above the groundwater protection standard at the point of compliance that
the facility intends to make a demonstration under this paragraph;
2. Within 90 days of determining a statistically significant level above the groundwater
protection standard, submit a report to the executive director that demonstrates that a source
other than the monitored solid waste management unit caused the contamination or that the
statistically significant level resulted from error in sampling, analysis, statistical evaluation,
or natural variation in groundwater quality. The report will be prepared and certified by a
qualified groundwater scientist;
3. Not filter the groundwater samples for constituents addressed by the demonstration prior to
laboratory analysis. The executive director may also require the facility to provide analysis
of landfill leachate to support the demonstration, and;
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MSW Permit 211B Ground Water Sampling and Analysis Plan
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4. Continue to monitor in accordance with the assessment monitoring program.
If a successful demonstration is made, the facility will continue monitoring in accordance with the
assessment monitoring program and may return to detection monitoring if the 40 CFR Part 258,
Appendix II constituents are at or below background using the statistical procedures in §330.405(f)
for two consecutive sampling events.
If the facility determines that the assessment monitoring program no longer satisfies the
requirements of this section, the facility will, within 90 days, submit an application for a permit
amendment or modification to make any appropriate changes to the program.
The facility will establish a groundwater protection standard for each 40 CFR Part 258, Appendix II
constituent detected in the point of compliance monitoring wells. The groundwater protection
standard will be:
1. for constituents for which a maximum contaminant level (MCL) has been promulgated under
40 CFR Part 141, Safe Drinking Water Act (codified), §1412, the MCL for that constituent;
2. for constituents for which MCLs have not been promulgated, the background concentration
for the constituent established from wells in accordance with §330.405(d); or
3. for constituents for which the background level is higher than the MCL or health-based levels,
the background concentration.
The executive director may establish an alternative groundwater protection standard for 40 CFR Part
258, Appendix II constituents for which MCLs have not been established. These groundwater
protection standards will be appropriate health-based levels:
1. The level is derived in a manner consistent with United States Environmental Protection
Agency guidelines for assessing the health risks of environmental pollutants (51 FR 33992,
34006, 34014, 34028, September 24, 1986);
2. The level is based on scientifically valid studies conducted in accordance with the Toxic
Substances Control Act Good Laboratory Practice Standards (40 CFR Part 792) or
equivalent;
3. For carcinogens, the level represents a concentration associated with an excess lifetime
cancer risk level (due to continuous lifetime exposure) with the 1 x 10-4 to 1 x 10-6 range;
and
4. For systemic toxicants, the level represents a concentration to which the human population
(including sensitive subgroups) could be exposed to on a daily basis that is likely to be
without appreciable risk of deleterious effects during a lifetime. For purposes of this
document, systemic toxicants include toxic chemicals that cause effects other than cancer or
mutation; or
5. The level is developed in accordance with 30 TAC 350 (relating to Texas Risk Reduction
Program).
In establishing groundwater protection standards, the executive director may consider multiple
contaminants in the groundwater, exposure threats to sensitive environmental receptors, and other
site-specific exposure or potential exposure to groundwater.
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MSW Permit 211B Ground Water Sampling and Analysis Plan
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The facility will submit an annual assessment monitoring report within 60 days after the facility's
second semiannual groundwater monitoring event that includes the following information
determined since the previously submitted report:
1. A statement whether a statistically significant level above a groundwater protection standard
has occurred in any well during the previous calendar year period and the status of any
statistically significant level events;
2. The results of all groundwater monitoring, testing, and analytical work obtained or prepared
in accordance with this plan, including a summary of background groundwater quality
values, groundwater monitoring analyses, statistical calculations, graphs, and drawings;
3. The groundwater flow rate and direction in the uppermost aquifer. The groundwater flow
rate and direction of groundwater flow will be established using the data collected during the
preceding calendar year's sampling events from the monitoring wells of the Assessment
Monitoring Program. The facility will also include in the report all documentation used to
determine the groundwater flow rate and direction of groundwater flow;
4. A contour map of piezometric water levels in the uppermost aquifer based, at a minimum,
upon concurrent measurement in all monitoring wells. All data or documentation used to
establish the contour map should be included in the report;
5. Recommendation for any changes; and
6. Any other items requested by the executive director.
3.7 ASSESSMENT OF CORRECTIVE MEASURES
Within 90 days of finding that any of the 40 Code of Federal Regulations Part 258, Appendix II
constituents have been detected at a statistically significant level above the groundwater protection
standards defined under §330.409(h), (i), or (j), the facility will initiate an assessment of corrective
measures. The assessment will be completed within 180 days of its initiation. During this time the
facility will continue to monitor in accordance with the assessment monitoring program as specified
in §330.409. The assessment will include an analysis of the effectiveness of potential corrective
measures in meeting all of the requirements and objectives of the objectives of the remedy as
described under §330, addressing at least the followingremedy described under §330.413 addressing
at least the following:
1. Performance, reliability, ease of implementation, and potential impacts of appropriate
potential remedies, including safety impacts, cross-media impacts, and control of
exposure to any residual contamination;
2. Time required to begin and complete the remedy;
3. Costs of remedy implementation; and
4. Institutional requirements such as state or local permit requirements or other
environmental or public health requirements that may substantially affect
implementation of the remedy or remedies.
The facility will discuss the results of the corrective measures assessment, prior to the selection of a
remedy, in a public meeting with interested and affected parties. The facility will arrange for the
meeting and provide notice in accordance with the provisions of 30 TAC §39.501(e)(3).
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
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Based on the results of the corrective measures assessment conducted under §330.411, the facility
will select a remedy that, at a minimum, meets the standards listed in 30 TAC §330.413(b) and is in
accordance with rules of the commission. Within 30 days of completing the assessment of corrective
measures described in 30 TAC §330.411 the facility will submit a report to the executive director
for review and approval and place it in the operating record. The report will describe the remedy or
remedies proposed for selection and the way it or they meet the standards in §330.413(b).
Remedies will:
1. Be protective of human health and the environment;
2. Attain the groundwater protection standard as specified in accordance with §330.409(h),
(i), or (j);
3. Control the source(s) of releases so as to reduce or eliminate, to the maximum extent
practicable, further releases of 40 Code of Federal Regulations Part 258, Appendix II
constituents into the environment that may pose a threat to human health or the
environment; and
4. Comply with standards for management of wastes as specified in §330.415(d).
In selecting a remedy that meets the standards of §330.413(b), the facility will consider the
following evaluation factors:
1. Long- and short-term effectiveness and protectiveness of the potential remedy, along
with the degree of certainty that the remedy will prove successful based on consideration
of:
A. magnitude of reduction of existing risks;
B. magnitude of residual risks in terms of likelihood of further releases due to waste
remaining following implementation of a remedy;
C. type and degree of long-term management required, including monitoring, operation,
and maintenance;
D. short-term risks that might be posed to the community, workers, or the environment
during implementation of such a remedy, including potential threats to human health
and the environment associated with excavation, transportation, re-disposal, or
containment;
E. time until full protection is achieved;
F. potential for exposure of humans and environmental receptors to remaining wastes,
considering potential threats to human health and the environment associated with
excavation, transportation, re-disposal, or containment;
G. long-term reliability of the engineering and institutional controls; and
H. potential need for replacement of the remedy;
2. Effectiveness of the remedy in controlling the source to reduce further releases based on
the extent to which containment practices will reduce further releases and the extent to
which treatment technologies may be used;
3. Ease or difficulty of implementing a potential remedy based on consideration of:
A. degree of difficulty associated with constructing the technology;
B. expected operational reliability of the technologies;
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MSW Permit 211B Ground Water Sampling and Analysis Plan
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C. need to coordinate with and obtain necessary approvals and permits from other
agencies and regulatory bodies;
D. availability of necessary equipment and specialists; and
E. available capacity and location of needed treatment, storage, and disposal services;
4. Practicable capability of the facility, including a consideration of the technical and
economic capability; and
5. Degree to which community concerns are addressed by a potential remedy.
The facility will specify as part of the selected remedy a schedule for initiating and completing
remedial activities. The schedule will require the initiation of remedial activities within a reasonable
time approved by the executive director, taking into consideration the following factors:
1. Extent and nature of contamination;
2. Practical capabilities of remedial technologies in achieving compliance with groundwater
protection standards established under §330.409(h), (i), or (j) of this title and other
objectives of the remedy;
3. Availability of treatment or disposal capacity for wastes managed during implementation of
the remedy;
4. Desirability of utilizing technologies that are not currently available but that may offer
significant advantages over available technologies in terms of effectiveness, reliability,
safety, or ability to achieve remedial objectives;
5. Potential risks to human health and the environment from exposure to contamination prior
to completion of the remedy;
6. resource value of the aquifer, including current and future uses; proximity and withdrawal
rate of users; groundwater quantity and quality; potential damage to wildlife, crops,
vegetation, and physical structures from exposure to waste constituents; hydrogeologic
characteristics of the facility and adjacent land; groundwater removal and treatment costs;
and cost and availability of alternative water supplies;
7. practicable capability of the facility; and
8. other relevant factors.
The executive director may determine that remediation of a release of a 40 Code of Federal
Regulations Part 258, Appendix II is not necessary if the facility demonstrates to the satisfaction of
the executive director that:
1. The groundwater is additionally contaminated by substances that have originated from a
source other than a solid waste management unit and those substances are present in
concentrations such that cleanup of the release from the solid waste management unit
would provide no significant reduction in risk to actual or potential receptors; or
2. The constituent is present in groundwater that is not currently or reasonably expected to be
a source of drinking water and is not hydraulically connected with waters to which the
constituent is migrating or is likely to migrate in a concentration that would exceed the
groundwater protection standards established under §330.409(h), (i), or (j) of this title; or
3. Remediation of the release is technically impracticable; or
4. remediation of the release results in unacceptable cross-media impacts.
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A determination by the executive director in accordance with subsection (e) of this section will not
affect the authority of the state to require the facility to undertake source-control measures or other
measures that may be necessary to eliminate or minimize further releases to the groundwater, to
prevent exposure to the groundwater, or to remediate the groundwater to concentrations that are
technically practicable and that significantly reduce threats to human health or the environment.
3.9 IMPLEMENTATION OF THE CORRECTIVE ACTION PROGRAM
Based on the schedule established under 30 TAC §330.413(d) for initiation and completion of
remedial activities, the facility will:
1. establish and implement a corrective action groundwater monitoring program that:
• At least meets the requirements of an assessment monitoring program under 30 TAC
§330.409;
• Indicates the effectiveness of the corrective action remedy; and
• Demonstrates compliance with groundwater protection standards under 30 TAC
§330.413(f);
2. implement the corrective action remedy selected under 30 TAC §330.413; and
3. take any interim measures necessary to ensure the protection of human health and the
environment. Interim measures should, to the greatest extent practicable, be consistent with
the objectives of and contribute to the performance of any remedy that may be required under
30 TAC §330.413. The following factors will be considered by the facility in determining if
interim measures are necessary:
• Time required to develop and implement a final remedy;
• Actual or potential exposure of nearby populations or environmental receptors to
hazardous constituents;
• Actual or potential contamination of drinking water supplies or sensitive ecosystems;
• Further degradation of the groundwater that may occur if remedial action is not
initiated expeditiously;
• Weather conditions that may cause hazardous constituents to migrate or be released;
• Risks of fire or explosion, or potential for exposure to hazardous constituents as a
result of an accident or failure of a container or handling system; and
• Other situations that may pose threats to human health and the environment.
The facility may determine, based on information developed after implementation of the remedy has
begun or other information, that compliance with requirements of §330.413(b) of this title are not
being achieved through the remedy selected. In such cases, the facility will, with approval of the
executive director, implement other methods or techniques that could practicably achieve
compliance with the requirements unless the facility makes the determination and if it is approved
by the executive director. Failure to obtain approval from the executive director for the other
methods and techniques does not relieve the facility of the burden to implement an acceptable
remedy.
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MSW Permit 211B Ground Water Sampling and Analysis Plan
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If the facility determines that compliance with requirements under 30 TAC §330.413(b) cannot be
practically achieved with any currently available methods, the facility will:
1. Present to the executive director certification by a qualified groundwater scientist that
compliance with requirements under 30 TAC §330.413(b) cannot be practically
achieved with any currently available methods;
2. Implement alternative measures, with the approval of the executive director, to control
exposure of humans or the environment to residual contamination, as necessary to
protect human health and the environment;
3. Implement alternative measures, with the approval of the executive director, for
control of the sources of contamination, or for removal or decontamination of
equipment, units, devices, or structures that are technically practicable and consistent
with the overall objective of the remedy; and
4. Place a copy of all approved alternative measures in the operating record.
All solid wastes that are managed in accordance with a remedy required under 30 TAC §330.413,
or an interim measure, will be managed in a manner that is protective of human health and the
environment and that complies with applicable Resource Conservation and Recovery Act
requirements.
Upon implementation of a corrective action program, the facility will submit an annual corrective
action report by March 1st every year that includes the following information determined since the
previously submitted report:
1. A statement regarding whether a statistically significant level above a groundwater
Protection standard established in 30 tac §330.409(h), (i), or (j) in any well during
The previous calendar year period has occurred and the status of any statistically
Significant level events;
2. The results of all groundwater monitoring, testing, and analytical work obtained or
Prepared in accordance with the requirements of 30 tac §330.415, including a
Summary of background groundwater quality values, groundwater monitoring
Analyses, statistical calculations, graphs, and drawings;
3. The groundwater flow rate and direction in the uppermost aquifer. The groundwater
Flow rate and direction of groundwater flow will be established using the data
Collected during the preceding calendar year’s sampling events from the monitoring
Wells of the corrective action program. The facility will also include in the report all
documentation used to determine the groundwater flow rate and direction of
Groundwater flow;
4. A contour map of piezometric water levels in the uppermost aquifer based at a
Minimum upon concurrent measurement in all monitoring wells. All data or
Documentation used to establish the contour map should be included in the report;
5. Recommendation for any changes; and
6. Any other items requested by the executive director.
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. 24 Revision 02 April 2020Revised 11.18.19
Remedies selected under §330.413 of this title will be considered complete when:
1. The facility complies with the groundwater protection standards established under 30
TAC §330.409(h), (i), or (j) at all points within the plume of contamination that lies
beyond the groundwater monitoring system established under 30 TAC §330.403;
2. compliance with the groundwater protection standards established under §330.409 (h),
(i), or (j) has been achieved by demonstrating that concentrations of 40 Code of Federal
Regulations Part 258, Appendix II constituents have not exceeded the groundwater
protection standards for a period of three consecutive years, using the statistical
procedures in §330.405I (e) and (f) and performance standards in §330.409(h), (i), or (j).
The executive director may specify an alternative length of time during which the facility
will demonstrate that concentrations of 40 Code of Federal Regulations Part 258,
Appendix II constituents have not exceeded the groundwater protection standards. The
alternative length of time will be based on:
• extent and concentration of the release;
• behavior characteristics of the hazardous constituents in the groundwater;
• accuracy of monitoring or modeling techniques, including any seasonal,
meteorological, or other environmental variabilities that may affect the accuracy; and
• characteristics of the groundwater; and
3. all actions required to complete the remedy have been satisfied.
Within 15 days of completion of the remedy, the facility will submit to the executive director and
also place in the operating record a certification by a qualified groundwater scientist that the remedy
has been completed.
Upon submittal of satisfactory certification of the completion of the corrective action remedy, the
executive director may release the facility from the requirements for financial assurance for
corrective action under 30 TAC §330.509.
1. The facility complies with the groundwater protection standards established under 30
TAC §330.409(h), (i), or (j) at all points within the plume of contamination that lies
beyond the groundwater monitoring system established under 30 TAC §330.403;
2. Compliance with the groundwater protection standards established under
§330.409(h), (i), or (j) has been achieved by demonstrating that concentrations of 40
Code of Federal Regulations Part 258, Appendix II constituents have not exceeded
the groundwater protection standards for a period of three consecutive years, using
the statistical procedures in §330.405I and (f) and performance standards in
§330.409(h), (i), or (j). The executive director may specify an alternative length of
time during which the facility will demonstrate that concentrations of 40 Code of
Federal Regulations Part 258, Appendix II constituents have not exceeded the
groundwater protection standards. The alternative length of time will be based on:
• Extent and concentration of the release;
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. 25 Revision 02 April 2020Revised 11.18.19
• Behavior characteristics of the hazardous constituents in the groundwater;
• Accuracy of monitoring or modeling techniques, including any seasonal,
• Meteorological, or other environmental variabilities that may affect the accuracy;
and
• Characteristics of the groundwater; and
3. All actions required to complete the remedy have been satisfied.
Within 15 days of completion of the remedy, the facility will submit to the executive director and
also place in the operating record a certification by a qualified groundwater scientist that the remedy
has been completed.
Upon submittal of satisfactory certification of the completion of the corrective action remedy, the
executive director may release the facility from the requirements for financial assurance for
corrective action under 30 TAC §330.509(b)0.509.
City of Dumas MSW Landfill Part III Attachment 11
MSW Permit 211B Ground Water Sampling and Analysis Plan
01094518 Revision 00 November 2019
Revised by PARKHILL, SMITH & COOPER INC. 26 Revision 02 April 2020Revised 11.18.19
4.0 GROUNDWATER QUALITY
4.1 PLUME OF CONTAMINATION
A description of any plume of contamination that has entered the groundwater is required by 30
TAC §330.63(f)(2). There is no plume of contamination that has entered the groundwater.
Any future plume of contamination identified during groundwater monitoring will be managed in
accordance with 30 TAC Subchapter J – Groundwater Monitoring and Corrective Action.