ADEQ ARK A N 5 A S Department of Environmental Quality

August 172017

Certified Mail 9489 0090 0027 6022 1854 93

City of Little Rock Public Works Solid Waste Services Attn Mr Warren Atkins 10803 Ironton Cutoff Little Rock AR 72206

RE City of Little Rock Class 1 LandfiU ADEQ Review of First Half 2016 Semiannual Groundwater Monitoring Report Second Half 2016 Semiannual Groundwater Monitoring Report Fourth Quarter 2016 Water Level Measurements First Half 2017 Semiannual Groundwater Monitoring Report AFIN 60-01071 Permit No 0266-S1 Document ID 72403 Cross Reference 71139 71140 72219 amp72399

Dear Mr Atkins

The Arkansas Department of Environmental Quality Office of Land Resources (ADEQ) Regulated Waste Operations has reviewed the First Half 2016 Semiannual Groundwater Monitoring Report (Document ID 72399) Second Half 2016 Semiannual Groundwater Monitoring Report (Document 71139) Fourth Quarter 2016 Water Level Measurements (Document 71140) First Half 2017 Semiannual Groundwater Monitoring Report (Document 72219) for the City of Little Rock Class 1 Landfill After review ADEQ has the following comments

1 In First Half 2016 Semiannual Groundwater Monitoring Report Second Half 2016 Semiannual Groundwater Monitoring Report and First Half 2017 Semiannual Groundwater Monitoring Report there is no documentation of the rate of groundwater flow across the site Regulation 221203(k) states The permittee shall also provide a determination of the rate of groundwater flow across the site Please submit a groundwater flow rate in future reports

2 In the First Half2016 Second Half 2016 and First Half2017 Semiannual Groundwater Monitoring Reports it is stated that MW-2A and MW-3A are upgradient wells but on each of the potentiometric maps and Section 12 Site Groundwater Monitoring System they are mentioned as downgradient wells Therefore the Alternative Source Demonstration (ASD) submitted is not approved at this time The document referenced in Section 12 Groundwater Monitoring Program for the City of Little Rock Solid Water Management Facility (Document 611) also mentions that MW-2 and MW-3 are

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

5301 NORTHSHORE DRIVE NORTH LlTILE ROCK ARKANSAS 72118-5317

TELEPHONE 501-682-0744 FAX 501-682-0880 wwwadeqstatearus

downgradient wells and were replaced with MW-2A and MW-3A April through May 1999 which are located near the same location as MW-2 and MW-3

3 When a statistically significant increase (SSI) is detected in sampling events please provide an ASD for that detection or begin assessment monitoring If an ASD is made detennining that SSIs are caused by natural fluctuations in the groundwater quality of the area then data should be presented in support of this assertion In addition should the faci lity choose verification sampling as part of the statistical methodology the resampling should take place as soon as the well has stabilized to allow an independent sampling event to occur The resampling event should occur at a practicable time as to allow the facil ity to submit the groundwater monitori ng results from the verification sampling within the ninety (90) calendar day ti me frame from the initial SS

4 MW-6A was plugged and abandoned on February 22 2002 and replaced with MW-6B on January 30 2003 This well is mentioned in the First Half20 16 Semiannual Groundwater Monitoring Report Sections 323 50 and Notification of SS Letter as having SSIs Please use correct wells in future reports

Please respond to these comments within thirty (30) calendar days from the receipt of this letter If you have any questions or comments please contact me at (501) 682-0590 or by email at crameradeq statearus

Robert D Cramer Geologist Regulated Waste Operations Office of Land Resources

cc David Jaros PG Terracon

ADEQ ARK A N S A S Department of Environmental Quality

REGULA TED WASTE OPERA TIONS OFFICE OF LAND RESOURCES ROUTING SLIP

DATE August 15 2017

Subject City of Little Rock Class 1 Landfill ADEQ Review of Second Half 2016 Semi-Annual Groundwater Monitoring Report Fourth Quarter 2016 Water Level Measurements First Half 2017 Groundwater Monitoring Report

From Robert Cramer

Route in turn to Action Needed Date Received Date Reviewed Initials ~ BSadler ~urrence ~view ~-IS ~-~ BS cJk

(t~t(JRich o Concurrence 0 Review K-15 1--11-11 flf

THynum o Concurrence 0 Review ~

o Concurrence 0 Review

o Concurrence 0 Review

Note Marking the Concurrence box indicates the individual agrees with the applicable text as it relates to their individual discipline and Work Section (eg Engineer Risk Assessor Geology Compliance PolicyManagement) as applicable Marking the Review box indicates the individual has read the document

Return to Robert Cramer for distribution

COMMENTS