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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

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Page 1: TSK/SSparkhill.com/.../07/Technical-NOD-1-Response_Full.pdf · \\Data1\Projects\2018\0945.18\03_DSGN\03_REPT\00_CLERICAL\PERMIT\NOD 2\Admin NOD Cover Letter.docm April 20, 2020 Terance

\\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

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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.

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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

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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

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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://

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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.”

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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.

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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

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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.

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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):

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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):

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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):

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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.

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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

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Revised November 2019Revision 02 April 2020

04/20/2020For November 2019and April 2020For revision only

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Revised November 2019Revision 02 April 2020

04/20/2020For November 2019and April 2020 Revision only

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SITE DEVELOPMENT PLAN

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Revised November 2019

04/2020 For November2019 and April 2020Revision only

Revision 02 April 2020

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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

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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

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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

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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”.

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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.

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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.

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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.

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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.

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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

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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

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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)

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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

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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.

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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).

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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.

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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

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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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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. 15 Revision 02 April 2020

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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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. 16 Revision 02 April 2020

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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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. 17 Revision 02 April 2020

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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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. 18 Revision 02 April 2020

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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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. 19 Revision 02 April 2020

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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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. 20 Revision 02 April 2020

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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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. 21 Revision 02 April 2020

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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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. 22 Revision 02 April 2020

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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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. 23 Revision 02 April 2020

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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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 2020

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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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 2020

• 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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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 2020

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.

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Revised November 2019 Revision 02 April 2020
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SITE DEVELOPMENT PLAN
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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

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Revised November 2019 Revision 02 April 2020
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Revised By: Parkhill, Smith & Cooper, Inc. 4222 85th St, Lubbock, TX 79423 TBPE F-560
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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

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City of Dumas, Moore County, MSW Permit No. 211B

Part III, Attachment 5 - Groundwater Characterization Report

April 2020November 2019

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”.

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City of Dumas, Moore County, MSW Permit No. 211B

Part III, Attachment 5 - Groundwater Characterization Report

April 2020November 2019

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. 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

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City of Dumas, Moore County, MSW Permit No. 211B

Part III, Attachment 5 - Groundwater Characterization Report

April 2020November 2019

PARKHILL, SMITH & COOPER INC. GCR-4 01094518

11.18.19

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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City of Dumas, Moore County, MSW Permit No. 211B

Part III, Attachment 5 - Groundwater Characterization Report

April 2020November 2019

PARKHILL, SMITH & COOPER INC. GCR-5 01094518

11.18.19

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

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City of Dumas, Moore County, MSW Permit No. 211B

Part III, Attachment 5 - Groundwater Characterization Report

April 2020November 2019

PARKHILL, SMITH & COOPER INC. GCR-6 01094518

11.18.19

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.

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City of Dumas, Moore County, MSW Permit No. 211B

Part III, Attachment 5 - Groundwater Characterization Report

April 2020November 2019

PARKHILL, SMITH & COOPER INC. GCR-7 01094518

11.18.19

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.

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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)

DAGerman
Text Box
SSamir
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SSamir
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11/18/19
SSamir
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For this revision only
eviramontes
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eviramontes
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04/20/2020 For November 2019 and April 2020 Revision only
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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

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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)

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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 2020Revised 11.18.19

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

TKrueger
Strikethrough
Indicate that
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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 2020Revised 11.18.19

"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.

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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 2020Revised 11.18.19

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).

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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 2020Revised 11.18.19

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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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 2020Revised 11.18.19

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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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 2020Revised 11.18.19

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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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. 15 Revision 02 April 2020Revised 11.18.19

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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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. 16 Revision 02 April 2020Revised 11.18.19

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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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. 17 Revision 02 April 2020Revised 11.18.19

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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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. 18 Revision 02 April 2020Revised 11.18.19

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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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. 19 Revision 02 April 2020Revised 11.18.19

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).

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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. 20 Revision 02 April 2020Revised 11.18.19

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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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. 21 Revision 02 April 2020Revised 11.18.19

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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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. 22 Revision 02 April 2020Revised 11.18.19

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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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. 23 Revision 02 April 2020Revised 11.18.19

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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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;

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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.

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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.