austin, texas 78753-1808 12100 park 35 circle building a...

\\Data1\Projects\2018\0945.18\03_DSGN\03_REPT\02_PERMIT (Limited_Scope)\Submitted\03_Technical NOD 2\Admin NOD Cover Letter.docm

June 12, 2020Terance Virtue, Geoscientist IVMC 124, Municipal Solid Waste Permits SectionTexas Commission on Environmental QualityBuilding A, Room 12212100 Park 35 CircleAustin, Texas 78753-1808

Re: Technical Notice of Deficiency #2 ResponseCity of Dumas MSW Management FacilityDumas, Moore County, TexasMunicipal Solid Waste Permit Number: 211BRN101667053/CN600649370Tracking No. 25063819Type 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 #2 submittal are enclosed with this letter. In response to the TCEQ email dated June 11, 2020, we have included our responses to each of your comments below:

Comment 1: Revise sentence “Point of compliance well spacing will not be exceeded 600 feet” to “Point of compliance well spacing will not exceed 600 feet” in Part III, Attachment 5, Section 3.1.Response 1: Revision has been made.Comment 2: Revise rule reference from “76.702 and 76.1004” to 76.102 and 76.104 in Part III, Attachment 5, Section 3.2.Response 2: Revision has been made.Comment 3: Revise rule reference from 330.405I and (f) to 330.405(e) and (f) in Part III, Attachment 11, Section 3.9 on page 24.Response 3: Revision has been made.We believe this submittal 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

TCEQ-0650, Part I Application (rev. 09-01-2019) Form - Page 1 of 11

Facility Name: City of Dumas MSW Manangement FacilityPermittee/Registrant Name: City of DumasMSW Authorization #:211BInitial Submittal Date: 11/18/2019Revision Date: 6/25/2020

Texas Commission on Environmental Quality

Part I Application Form for New Permit, PermitAmendment, 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://www.team-psc.com/engineering-sector/solid-waste/tceq-permits/

https://www3.tceq.texas.gov/epay/


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.”


11. Permits and Construction Approvals

Permit or Approval Received Pending Not Applicable

Hazardous Waste Management Program under the Texas Solid Waste Disposal ActUnderground Injection Control Program under the Texas Injection Well ActNational Pollutant Discharge Elimination System Program under the Clean Water Act and Waste Discharge Program under Texas Water Code, Chapter 26Prevention of Significant Deterioration Program under the Federal Clean Air Act (FCAA).Nonattainment Program under the FCAANational Emission Standards for Hazardous Air Pollutants Preconstruction Approval under the FCAAOcean Dumping Permits under the Marine Protection Research and Sanctuaries ActDredge 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 MSW Management Facility

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


(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): 3597.24 ft.

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


*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 well 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



Mailing Address: PO Box 438

City: Dumas County: Moore State: TX Zip Code: 79029-0438


Email Address: [email protected]

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.


Operator Name1: City of Dumas

Customer Reference No. (if issued)*: 600649370


Mailing Address: PO Box 438

City: Dumas County: Moore State: TX Zip Code: 79029-0438


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, and 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


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):


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


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: P.O. Box 100




City Mayor Information

City Mayor’s Name: Bob Brinkmann

Office Address: 124 W. 6th St.




City Health Authority:Department of State Health Services, PHR 1

Contact Person’s Name: Rick Tull

Street Address or P.O. Box: 3407 Pony Express Way





County Judge Information

County Judge’s Name: Johnnie "Rowdy" Rhoades

Street Address or P.O. Box: 715 S. Dumas Ave, Room 202




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




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



State Senator Information

District Number: 31

State Senator’s Name: Kel Seliger

District Office Address: 410 S. Taylor, Suite 1600




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




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: 415 W. 8th Avenue



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.


Part I Attachments

(See Instructions for P.E. seal requirements.)

Required Attachments Attachment No.Supplementary Technical Report N/AProperty Legal Description N/AProperty Metes and Bounds Description N/AFacility Legal Description N/A Facility Metes and Bounds Description N/A Metes and Bounds Drawings N/A On-Site Easements Drawing N/ALand Ownership Map FIG.AL-1Land Ownership List FIG.AL-2 Electronic List or Mailing Labels CD (original Submittal)Texas Department of Transportation (TxDOT) County Map N/AGeneral Location Map N/AGeneral Topographic Map N/AVerification of Legal Status N/AProperty Owner Affidavit N/AEvidence of Competency N/AAdditional Attachments as Applicable- Select all those apply and add as necessary

TCEQ Core Data Form(s) Front of application Signatory Authority Delegation N/A Fee Payment Receipt N/A Confidential Documents N/A Waste Storage, Processing and Disposal Ordinances N/A Final Plat Record of Property N/A Certificate of Fact (Certificate of Incorporation) N/A Assumed Name Certificate N/A

Revised November 2019Revision 02 April 2020Revision 03 June 2020

11/18/1906/12/2020For November 2019April 2020, and June2020 revisions only

Revised November 2019; Revision 02 April 2020; Revision 03 June 2020

06/12/2020For November 2019, April 2020, and June 2020 Revisions only

SITE DEVELOPMENT PLAN

Revision 03 June 2020Revision 02 April 2020Revised November 2019

06/12/2020 For November 2019,April 2020, and June 2020Revisions only

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 03 June 2020

Revision 02 April 2020

Revision 00 November 2019

PSC Project # 01094518


Revised By:Parkhill, Smith & Cooper, Inc.

4222 85th St, Lubbock, TX 79423

TBPE F-560 06/12/2020For November 2019,April 2020 and June 2020revisions only

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

Part III, Attachment 5 - Groundwater Characterization Report

June 2020

PARKHILL, SMITH & COOPER INC. GMP-i 01094518 Revision 00 November 2019; Revision 02 April 2020; Revision 03 June 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

06/12/2020 For November 2019, April 2020 and June 2020 Revisions Only



June 2020

PARKHILL, SMITH & COOPER INC. GCR-3 01094518

11.18.19, 4.20.20, 6.12.20

3.0 SUBTITLE D GROUNDWATER MONITORING SYSTEM

Groundwater monitoring system has been designed in accordance with requirements of 30 TAC

§330.403 based on site-specific technical information including identification of uppermost aquifer

and lower confining unit beneath the uppermost aquifer. The landfill is completely constructed and

no more landfill units will be constructed in future. Monitoring wells MW-1 through MW-4 are

constructed and currently being sampled. Change in gradient of groundwater necessitates the addition

of two, new groundwater wells (MW-5 and MW-6). Owner/Operator will submit monitoring well

installations and construction details within 60 days of well completion in accordance with §330.421.

A copy of the detailed geologic log of boring, description of development procedures, any particle

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. Point of compliance well spacing will not

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.

exceed 600 feet.



June 2020


11.18.19, 4.20.20, 6.12.20

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.

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



June 2020


11.18.19, 4.20.20, 6.12.20

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.

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

City of Dumas, Moore County, MSW Permit No. 211B Part III, Attachment 5 - Groundwater Characterization Report

June 2020

PARKHILL, SMITH & COOPER INC. GCR-6 0109451811.18.19, 4.20.20, 6.12.20

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.

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 unusual 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 nearest0.01 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§76.102 and §76.104. No abandonment will be performed without prior written authorization.



June 2020


11.18.19, 4.20.20, 6.12.20

All parts of groundwater monitoring system will be operated and maintained so they perform

at least to design specifications through life of groundwater monitoring program. Facility must

notify executive director if changes in site construction, operation, or changes in adjacent

property affect or are likely to affect direction and rate of groundwater flow and potential for

detecting groundwater contamination from the facility.

Dumas Municipal Solid Waste LandfillPart III, Attachment 11 – Groundwater Sampling and Analysis Plan

PARKHILL, SMITH & COOPER INC. 01094518

10.15.19

ATTACHMENT 11

GROUNDWATER SAMPLING AND ANALYSIS PLAN (GWSAP)

11/18/19For this revision only

06/12/2020For November 2019,

April 2020, and June 2020Revisions only

11.18.19; 04.20.20; 06.12.20

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; Revision 03 – June 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

06/12/2020 For November 2019, April 2020, and June 2020 revisions only




Revised by PARKHILL, SMITH & COOPER INC. 24 Revision 02 - April 2020; Revision 03 – June 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.




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,

TKrueger

Text Box

REDLINE/STRIKEOUT


11/18/1906/12/2020For November 2019April 2020, and June2020 revisions only

Revised November 2019; Revision 02 April 2020; Revision 03 June 2020

06/12/2020For November 2019, April 2020, and June 2020 Revisions only

SITE DEVELOPMENT PLAN

Revision 03 June 2020Revision 02 April 2020Revised November 2019

06/12/2020 For November 2019,April 2020, and June 2020Revisions only

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 03 June 2020

Revision 02 April 2020

Revision 00 November 2019

PSC Project # 01094518


Revised By:Parkhill, Smith & Cooper, Inc.

4222 85th St, Lubbock, TX 79423

TBPE F-560 06/12/2020For November 2019,April 2020 and June 2020revisions only



June 2020

PARKHILL, SMITH & COOPER INC. GMP-i 01094518 Revision 00 November 2019; Revision 02 April 2020; Revision 03 June 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

06/12/2020 For November 2019, April 2020 and June 2020 Revisions Only



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11.18.19, 4.20.20, 6.12.20

3.0 SUBTITLE D GROUNDWATER MONITORING SYSTEM

Groundwater monitoring system has been designed in accordance with requirements of 30 TAC

§330.403 based on site-specific technical information including identification of uppermost aquifer

and lower confining unit beneath the uppermost aquifer. The landfill is completely constructed and

no more landfill units will be constructed in future. Monitoring wells MW-1 through MW-4 are

constructed and currently being sampled. Change in gradient of groundwater necessitates the addition

of two, new groundwater wells (MW-5 and MW-6). Owner/Operator will submit monitoring well

installations and construction details within 60 days of well completion in accordance with §330.421.

A copy of the detailed geologic log of boring, description of development procedures, any particle

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. 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 Fall. All wells will be sampled semiannually. Point of compliance well spacing

will not

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

exceed 600 feet.



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11.18.19, 4.20.20, 6.12.20

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.

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.



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11.18.19, 4.20.20, 6.12.20

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.

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.

City of Dumas, Moore County, MSW Permit No. 211B Part III, Attachment 5 - Groundwater Characterization Report


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.

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 usnusual 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 nearest0.01 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.

TKrueger

Snapshot

TKrueger

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Plugging and abandoning monitoring wells will be performed in accordance with 16 TAC

§76.702 and §76.1004 §76.102 and §76.104. No abandonment will be performed without prior

written authorization.

All parts of groundwater monitoring system will be operated and maintained so they perform

at least to design specifications through life of groundwater monitoring program. Facility must

notify executive director if changes in site construction, operation, or changes in adjacent

property affect or are likely to affect direction and rate of groundwater flow and potential for

detecting groundwater contamination from the facility.

Dumas Municipal Solid Waste LandfillPart III, Attachment 11 – Groundwater Sampling and Analysis Plan

PARKHILL, SMITH & COOPER INC. 01094518

10.15.19

ATTACHMENT 11

GROUNDWATER SAMPLING AND ANALYSIS PLAN (GWSAP)

11/18/19For this revision only

06/12/2020For November 2019,

April 2020, and June 2020Revisions only

11.18.19; 04.20.20; 06.12.20




Revised by PARKHILL, SMITH & COOPER INC. i Revision 02 - April 2020; Revision 03 – June 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

06/12/2020 For November 2019, April 2020, and June 2020 revisions only




Revised by PARKHILL, SMITH & COOPER INC. 24 Revision 02 - April 2020; Revision 03 – June 2020

Remedies selected under §330.413 of this title will be considered complete when:




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.




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)I 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,