A D escription of Groundwater Monitoring Reports Requirements for MSW Type I Facilities

1. A Description of Groundwater Monitoring Reports Requirements for MSW Type I Facilities Presented by IrynaKushnirsky Work Leader MSW Permits Section Waste Permits Division Texas Commission on Environmental Quality Environmental Trade Fair May 7, 2014

2. Agenda • Provide clarity on the number of reports • Provide clarification on amount of data required to be submitted • Avoid data duplication from one report to the next • Provide clarification on how to combine detection and assessment monitoring report requirements

3. Annual Reports Received What to submit? When to submit? What to include?

4. Section I: Background Monitoring • Background Sampling Report • Background Evaluation Report • Background Update Report • Section II: Detection Monitoring • Notice of Initial Statistical Exceedance • Verification Resampling Report • Alternate Source Demonstration Report • Annual Detection Monitoring Report • Section III: Assessment Monitoring • Report of Assessment Monitoring Results • Notice of Statistically Significant Level • Annual Assessment Monitoring Report

5. Section I: Background MonitoringBackground Sampling Report (BSR) • In accordance with §330.407(c), results of all groundwater monitoring events performed during the calendar year shall be included in the annual groundwater detection monitoring report • However, we request that quarterly background sampling results be submitted semiannually • The report should include the following information: • Sampling results on Form TCEQ-0312 (Available Online) • The laboratory case narrative and laboratory checklist (Available Online) • The chain of custody record

7. Background Evaluation Report (BR) • In accordance with §330.407(a)(1) a BR shall be submitted after collecting enough (at least four) background sample results before the next groundwater monitoring event • The details of BR requirements were described in our letter, dated August 30, 2010 • The report should include the following information: • Narrative explanation of the statistical process • Table of background data • Table of intermediate statistics, listing mean, standard deviation and appropriate statistical limits • Charts with statistical limits (Example Chart Included)

11. Background Update Report • In accordance with §330.407(a)(1), the background data set may be updated once every two years with semiannual detection monitoring results The report should include the following information: • Narrative explanation of the statistical process used to evaluate data • Discussion of changes between the existing background data sets and updated data sets • Table of updated background data sets • Table of intermediate statistics and updated statistical limits • Charts with updated statistical limits

12. Section II: Detection MonitoringNotice of Initial Statistical Exceedance (ISE) • If an ISE is determined after a semiannual event, the executive director shall be notified within 14 days of the determination as required by §330.407(b) • The notice should include the following information: • A table indicating which initial statistical increases were determined along with their reported concentrations relative to their background limits (Example Table 1) • A statement explaining how the facility intends to proceed • We encourage you to consider submitting a semiannual report including a “Notice of ISE”

13. Example Table 1 – Summary of ISEs Determined during the Current Detection Monitoring Sampling Event

14. Verification Resampling Report • In accordance with §330.407(b)(2), if an ISE is determined, the results of resampling shall be submitted within 60 days of determining the ISE • The report should include the following information: • A discussion of the statistical evaluations and conclusions • A table indicating verification resampling results (Example Table 2) • Resampling results on Form TCEQ-00312 • The laboratory case narrative and laboratory checklist • The chain of custody record

15. Example Table 2 – Verification Resampling Results

16. Alternate Source Demonstration (ASD) • In accordance with §330.407(b)(3), an alternate source demonstration shall be submitted within 90 days of determining an Statistically Significant Increase (SSI) • The ASD should include evidence that: • The contamination is from a source other than the landfill unit, or • The SSI resulted from error in sampling, analysis, or • The SSI resulted from natural variation in groundwater quality • Data supporting the alternate source: samples collected from offsite source, background data from other wells, analysis of the landfill leachate

17. Annual Detection Monitoring Report(Second Semiannual) • In accordance with §330.407(c), an annual detection monitoring report shall be submitted within 90 days after the facility’s last groundwater monitoring event (last semiannual event) • The report should include the following information: • A discussion regarding SSIs during the calendar year • A table of the groundwater monitoring events (Example Table 3) • A table of the groundwater elevation measurements

18. Annual Detection Monitoring Report (continue) • Results of all groundwater monitoring, testing, resampling, including: • A table of background statistical limits (Example Table 4) • Groundwater Sampling Results on the TCEQ-00312 forms • A laboratory case narrative and laboratory checklist • The chain of custody record • Charts of the detected concentrations, including statistical limits

19. Annual Detection Monitoring Report (continue) • Results of all groundwater monitoring, testing, resampling, including (continue): • Charts of the detected concentrations, including statistical limits • A contour map of piezometric water levels and groundwater flow direction • Pre-Subtitle D cells should be clearly identified on the map, if applicable • Recommendations for any changes and any other items requested by the executive director

20. Example Table 3 – Groundwater Monitoring Events

21. Example Table 4 – Summary of Background Statistical Limits

22. Detection Monitoring Timetable • 60 days to determine if an ISE has occurred • After 60-day ISE determination window, within… • 14 days (total 74days after semiannual) submit “Notice of ISE” • 14 days (total 74 days) submit “Notice of intent to make a demonstration” • Note: instead of “Notices”, a semiannual report can be submitted • 60 days (total 120 days) submit “Verification Resampling” • 90 days (total 150 days) submit “ASD” • 90 days after the second semiannual event submit “Annual Detection Monitoring Report”

23. Detection Monitoring Timetable ASD Resampling SSI Determination Notice of SSI Days 0 150 30 60 90 120 180 74 Annual Report 0 day = Semiannual Event

24. Section III: Assessment MonitoringAssessment Monitoring Results • In accordance with §330.409(d), not later than 60 days after each sampling event, the results of sampling shall be submitted • The report include the following information: • Sampling results from assessment monitoring wells on Form TCEQ-00312 • The laboratory case narrative, and laboratory checklist • The chain of custody record • We encourage you to consider submitting a semiannual report including “Assessment Monitoring Results”

25. Notice of Statistically Significant Level (SSL) • If an SSL is determined after a semiannual event, the executive director shall be notified in writing within 7 days of the determination as required by §330.409(g) • The notice of an SSL includes the following information: • A table indicating which SSLs were determined, detected concentrations, calculated 95% lower confidence limits (LCL) and groundwater protection standards (Example Table 5) • A statement explaining how the facility intends to proceed • We encourage you to consider submitting a semiannual report instead of “Notice of SSL”

26. Example Table 5 – Summary of SSLs Determined during the Current Assessment Monitoring Event

27. Annual Assessment Monitoring Report (Second Semiannual) • In accordance with §330.409(k), an annual assessment monitoring report shall be submitted within 60 days after the facility’s second semiannual groundwater monitoring event • The report should include the following information: • A statement whether an SSL above a groundwater protection standard has occurred during the calendar year • A table of the groundwater monitoring events with the monitoring status of each well • A table of the groundwater elevation measurements • A historical data, statistical limits and calculations of 95% LCLs

28. Annual Assessment Monitoring Report (continue) • Groundwater Sampling Results on the TCEQ-00312 forms • A laboratory case narrative and laboratory checklist • The chain of custody record • A contour map of piezometric water levels and groundwater flow direction for each sampling event • Pre-Subtitle D cells should be clearly identified on the map, if applicable • Recommendations for any changes

29. Our Recommendations • We suggest submitting • Semiannual Reports (fist semiannual event) • Annual Reports (second semiannual event) • Note: do not copy data from 1st semiannual report to annual report • Detection Semiannual/Annual Reports can be combined with Assessment Semiannual/Annual Reports

30. First Semiannual Event and Report Requirements

31. Second Semiannual Event and Report Requirements

32. How Many Copies? • The facility shall provide: • One hard copy of the report to the Austin (central) office • One PDF file of the report on a CD to the Austin (central) office • The analytical data and laboratory QA/QC should be added to the PDF file of the report • One hard copy of the report to the appropriate TCEQ regional office

33. How Many Copies? (cont’d) • All PDF electronic documents should be properly named • The name should consist of: Record series (MSW PA), Permit number, Folder code (RP for reports and PA for permits), Date of document (Year Month Day) and Document name • Example: MSW PA_1222_RP_20131215_GW Annual 2013 Report.pdf • Small reports such as “ASDs”, “Verification Resampling” or other may be submitted in hard copy only (2 copies to central office, 1 copy to region)

34. Thank You! • IrynaKushnirsky • Phone: (512)239-1471 • E-mail: Iryna.Kushnirsky@tceq.texas.gov