HomeMy WebLinkAboutPR 21090: GROUNDWATER, LANDFILL GAS, AIR QUALITY SERVICES lJ
4 City of
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Texas
www.Po rtArthurTx.gov
INTEROFFICE MEMORANDUM
Date: September 30,2019
To: The Honorable Mayor and City Council
Through: Ron Burton, Interim City Manager
From: Alberto Elefano, Director of Public Works
RE: P. R. No. 21090—Groundwater, Landfill Gas, Air Quality Services
Introduction:
Approval of Proposed Resolution No. 21090 authorizing the City Manager to execute an
agreement with SCS Engineers of Bedford, Texas, for groundwater, gas monitoring, and air
compliance services for a not-to-exceed amount of$95,950.
Background:
The Landfill's Title V permit requires that the groundwater must be monitored. It also requires
annual and semi-annual reporting on air quality. The EPA requires annual greenhouse gas
reporting and Tier 2 sampling and analysis every five years.
A registered geologist and environmental engineer are required by the state to perform these
services. SCS Engineers has performed these task for the City in past years making them very
familiar with the process.
Budget Impact:
Funds are provided in Account No. 403-1274-533.59-01, Public Works Department Landfill
Division—Landfill Regulatory Fees/Fines.
Recommendation:
It is recommended that City Council authorize the City Manager to approve P. R. No. 21090.
as discussed and/or outline above.
/aw
"Remember,we are here to serve the Citizens of Port Arthur"
P.O.Box 1089 X Port Arthur,Texas 77641-1089 X 409.983.8101 X FAX 409.982.6743
P. R.21090
09/30/19 aw
RESOLUTION NO.
A RESOLUTION AUTHORIZING THE CITY MANAGER TO
EXECUTE AN AGREEMENT WITH SCS ENGINEERS OF
BEDFORD,TEXAS,FOR THE PERIOD FROM NOVEMBER 2019
TO AUGUST 2020 FOR GROUNDWATER,LANDFILL GAS,AND
AIR QUALITY SERVICES WITH A NOT TO EXCEED AMOUNT
OF $95,950. FUNDING IS AVAILABLE IN ACCOUNT NO. 403-
1274-533.59-01, PUBLIC WORKS DEPARTMENT LANDFILL
DIVISION—REGULATORY FEES/FINES.
WHEREAS,the City's Landfill is required to monitor the groundwater according to Texas
Commission on Environmental Quality (TCEQ)rules; and,
WHEREAS, a registered geologist and environmental engineer are required to perform
this task; and,
WHEREAS, the City Landfill is required to submit annual and semi-annual air quality
deviation reports to the TCEQ and greenhouse gas emissions estimates to the EPA each calendar
year; and,
WHEREAS, the City Landfill is required to perform Tier 2 testing and reporting every
five years; and,
WHEREAS, SCS Engineers of Bedford, Texas, is a qualified professional engineer and
can perform all these services in an not-to-exceed $95,950, Exhibit"A"; now therefore,
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PORT ARTHUR:
THAT, the City Manager is hereby authorized to execute an agreement with SCS
Engineers of Bedford, Texas, for groundwater, gas, and air quality compliance services for a not-
to-exceed amount of$95,950, in substantially the same form as attached as Exhibit"A".
P. R.21090
09/30/19 aw
THAT. funding is available in account 403-1274-533.59-01, Public Works Landfill
Division -Regulatory Fees/Fines.
THAT a copy of the caption of this Resolution be spread upon the Minutes of the City
Council.
READ,ADOPTED, AND APPROVED this the day of , A.D. 2019 at
a meeting of the City of Port Arthur, Texas by the following vote:
AYES: Mayor:
Councilmembers:
Noes:
Mayor Thurman Bartie
ATTEST: APPROVED AS TO FORM:
71/.A-
Sherri Bellard Valecia Tizeno
City Secretary City Attorney
APPROVED FOR ADMINISTRATION: APPROVED AS TO AVAILABLITY
OF FUNDS:
Ron Burton Kandy Daniel
Interim City Manager Interim Director of Finance
C L f/ -- I '0., ,
Alberto Elefano Clifton illiams
Director of Public Works Purchasing Manager
P. R.21090
09/30/19 aw
Exhibit "A"
SCS ENGINEERS Environmental Consulting & Contracting
September 16, 2019
SCS Proposal No. 160113219
Mr.Alberto Elefano, P.E. sent via e-mail
Director of Public Works
City of Port Arthur
444 4th Street
Port Arthur, TX 77640
Subject: Proposal for Groundwater, Landfill Gas,Air Quality, and NSPS Tier 2 Services
November 2019 to August 2020
For the City of Port Arthur Landfill
Dear Mr. Elefano:
As discussed and in response to the City's recent request, SCS Engineers (SCS) is pleased to present
this proposal for continuing to provide groundwater and gas monitoring services as well as air
compliance services for the City of Port Arthur Landfill. SCS has appreciated the opportunity to provide
these services thus far, and we look forward to continuing to provide these important services for the
City. This scope of work covers the period from November 2019 to August 2020.
SCOPE OF WORK
This scope of work covers semiannual groundwater and gas monitoring, as well as air compliance
services,for the period from November 2019 to August 2020, i.e.,the City's FY 2019-2020 fiscal year.
This scope will enable a continued management of groundwater issues at the landfill as well as air
compliance matters, including discerning the applicability of forthcoming new regulations, as
explained herein.
Our proposed scope of services is as follows:
TASK 1 — NOVEMBER 2019 DETECTION MONITORING, METHANE
MONITORING, AND ANNUAL GROUNDWATER REPORT SERVICES
Field Services
A qualified field technician will sample all monitoring wells in accordance with the site GWSAP and
current practice. The technician will be dispatched with the current site GWSAP. Each well will be
inspected for condition, and observations will be documented. Field measurements including water
level, pH,specific conductivity, and temperature will be made using equipment supplied by SCS. Each
well will then be purged and sampled using the already-installed dedicated low-flow pumps in
accordance with the GWSAP. Samples will be packaged and sent to the lab for analysis. SCS will also
inspect the well pads and clear vegetation as necessary.
During the same time that groundwater wells are sampled, the SCS field technician will monitor
methane concentrations in the nine perimeter gas probes and gatehouse in accordance with the site
Landfill Gas Management Plan (LFGMP) and current practice. The technician will be dispatched with
1901 Central Drive,Suite 550, Bedford, TX 76021 1817-571-2288 I 0
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Mr. Alberto Elefano, P.E.
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the current site LFGMP. Each probe and the gatehouse will then be monitored using a calibrated
methane gas detector in accordance with the LFGMP.
Each time monitoring is conducted, the integrity of the gas monitoring probes will be inspected by the
sampler. The sampler will record pertinent information on appropriate field forms. The sampler will
perform the following at each monitoring event:
• Verify that the gas monitoring probe is clearly labeled on the outer casing or lid.
• Verify that the protective casing is intact and is not bent or excessively corroded.
• Verify that the concrete pad is intact (no evidence of cracking or heaving).
• Padlock replacement as necessary.
• Verify that the inner casing is intact.
If damage or excessive wear to a gas monitoring probe is observed, it will be reported to the Landfill
Manager.
Field monitoring data records will be maintained for all methane monitoring and kept on-site as part
of the Site Operating Record. If any gas probe measurements show any exceedance (defined as
methane exceeding 25% of its lower explosive limit in structures or 100% of the lower explosive limit
at the perimeter probes), the SCS technician will immediately report this information to the Landfill
Manager or his/her designated representative. SCS senior staff will consult with the City regarding
appropriate action.
Each time monitoring is conducted,the integrity of the monitoring wells and gas monitoring probes will
be inspected by the sampler. The sampler will record pertinent information on appropriate field forms.
The sampler will perform the following at each monitoring event:
• Verify that the well/monitoring probe is clearly labeled on the outer casing or lid.
• Verify that the protective casing is intact and is not bent or excessively corroded.
• Verify that the concrete pad is intact (no evidence of cracking or heaving).
• Padlock replacement.
• Verify that the inner casing is intact.
•
If damage or excessive wear to a well or gas monitoring probe is observed, it will be reported to the
Landfill Manager.
Field monitoring data records will be maintained for all methane monitoring and kept on-site as part
of the Site Operating Record.
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Reporting Services
Lab Analysis
SCS will oversee all lab-related activities for the project. SCS will coordinate with the lab prior to
sampling to order the appropriate sample containers. After sampling is complete, SCS will be
responsible for proper delivery to the lab. SCS will monitor the progress of sample testing,and address
lab issues as they arise. Metals analysis on the water samples will be for total metals, as required
under the Subchapter J rules.
Reporting
SCS will compile a report of test results for TCEQ as required by 30 TAC 330.407. The Texas Page
Ones (Form 0312) will first be submitted to the City for signature. The data will be merged into a pre-
existing electronic database that contains all Subtitle-D groundwater monitoring data obtained at the
site. The City will be informed of any significant developments that are observed at this stage of data
review.
Statistical analysis will be conducted as required by 30 TAC 330.407(b) for all wells. Note that TCEQ
now requires statistical analysis of data from all wells that have completed background data collection,
upgradient and downgradient; the previous requirement was to do statistical analysis only on
downgradient wells. We anticipate continuing to use the well-accepted Sanitas® software to conduct
the analysis, for which the City of Port Arthur owns a site license. TCEQ solid waste staff are familiar
with this software; SCS personnel continue on an ongoing, regular basis to attend Sanitas® training
side-by-side with TCEQ personnel. SCS staff have utilized this statistical software for numerous Texas
landfills.
The draft report cover letter will be submitted to the City for review and comment prior to submitting a
final draft to the City and TCEQ within 60 days of sampling. SCS will submit two copies of the final
report to the City.
In addition, this task scope includes preparing and submitting the annual report that is a requirement
under Subchapter J rule 30 TAC 330.407(c). A cover letter will summarize all activities for the previous
year, provide an updated groundwater flow map as required by 30 TAC 330.407(c)(4), and updated
groundwater flow velocity calculations as required by 30 TAC 330.407(c)(3). SCS will submit two
copies of the annual report to the City and three copies to TCEQ, including an electronic copy on CD.
TASK 2 — FEBRUARY 2020 METHANE MONITORING
This task has the same scope as the methane monitoring portion of Task 1.
TASK 3 — MAY 2020 DETECTION MONITORING, METHANE
MONITORING, AND SEMIANNUAL GROUNDWATER REPORT
SERVICES
This event has the same scope as Task 2, except no Annual Report is required.
TASK 4 — AUGUST 2020 METHANE MONITORING
This task has the same scope as Task 2.
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Mr. Alberto Elefano, P.E.
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TASK 5 — AIR QUALITY SERVICES
Title V Reporting
The landfill's Title V Permit requires the submittal of semi-annual deviation reports and the submittal
of an annual certification each year. Although semi-annual deviation reports are not required if no
deviations from the Title V permit requirements occurred during a semi-annual period, TCEQ has
requested that landfills be proactive and submit reports explicitly stating that no deviations occurred.
As such, consistent with TCEQ's request and our approach to satisfying TCEQ's requirements in prior
years, this work includes the filing of two semi-annual deviation reports in FY 2019-2020. This work
also includes the preparation of the Title V annual certification report. SCS will track the required
submittal deadlines and notify the City in advance, as information is required and as signatures are
needed.
Each submittal will consist of a cover letter, a certification form that must be signed by the City, and
contain the appropriate TCEQ certification and deviation forms. We will contact you to discuss whether
any potential deviations did occur during each reporting period prior to submitting any certification
forms to you for your signature as Responsible Official. Any discovered deviations will be explained
and included as such in the Title V paperwork. Upon completion of all paperwork and receipt of the
signed certification pages, SCS will transmit the appropriate paperwork to TCEQ and, for the annual
certification, to EPA.
Emissions Inventory and Emissions Fee Calculations
Aformal emissions inventory is filed annually for the landfill per TCEQ requirements to report emissions
annually. SCS will provide the City with a checklist of any needed information to estimate calendar
year 2019 emissions. Upon receipt of the needed information and preparation of emissions
calculations, SCS will then enter the data into TCEQ's State of Texas Environmental Electronic
Reporting System (STEERS). Upon completion of entering the CY2019 data, SCS will provide the
calculations in PDF format for your review, address typical TCEQ comments if received, and work with
you to certify the inventory on to TCEQ in STEERS prior to the March 31, 2020 TCEQ deadline. We will
upload pertinent calculations into STEERS as required by TCEQ.
As part of this scope, SCS will also prepare the TCEQ emissions fee remittance form. As the holder of
a Title V air permit in the State of Texas, the City is required to pay emissions fees to support Texas'
Title V program. Consistent with prior years, we anticipate that the TCEQ will mail you a fee remittance
form in April 2020. SCS will complete the emissions fee form,and remit this form to TCEQ on the City's
behalf. Please note that the fees themselves are not included in this proposal; the City should be
billed directly for these in October or November of 2020 after TCEQ's fiscal year closes and the per
ton fee amount is established.
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Calendar Year 2019 Greenhouse Gas Reporting
SCS will prepare the required reporting associated with the Federal mandatory GHG reporting rules in
calendar year 2020. This work includes the preparation and submittal of the required GHG emissions
estimates and associated information required by the GHG reporting rule. The deadline for this
submittal is March 31, 2020.
As was completed this past March, electronic reporting will be used to file all required information
related to the GHG reporting rule. SCS will work with the City and enter all online information for the
City's review and certification.
SCS will have most of the information necessary to complete the GHG emissions estimates based on
prior work. We will contact you regarding any information that might be needed. When the reporting
has been completed, SCS will provide a memorandum for your files including backup calculation
spreadsheets and pertinent assumptions.
TASK 6 — NSPS TIER 2 FIELD SAMPLING AND REPORTING
Tier 2 landfill gas sampling is required every 5 years by the New Source Performance Standards(NSPS)
rule for Municipal Solid Waste Landfills in order to report site-specific emissions estimates. Our team
is very familiar with the procedures for complying with this requirement. This sampling, if performed
every five years per the current rule, will allow the City to use a site-specific non-methane organic
compound (NMOC) value for the calculation of the landfill's annual NMOC emissions rate.
For this work, SCS will perform Tier 2 sampling and analysis at the landfill to obtain a new site-specific
NMOC content (for the landfill gas). SCS will then use this new NMOC content to report the NMOC
emissions rate for the landfill. NMOC emissions rates for up to five years into the future will also be
included as long as all five years are below 50 Mg/yr.
NSPS rules require that Tier 2 samples be collected at a rate of two samples per hectare of waste in-
place for two years or more, with a maximum of 50 samples. The landfill is of sufficient size to require
the maximum 50 samples be collected. Our fee includes collecting 50 samples from areas of the
landfill with waste in-place two years or more. Surface areas with waste younger than two years will
not be sampled during this effort per the NSPS rule's requirements that more mature waste (and
landfill gas) be sampled.
Our proposal's fee includes 3 days of time for SCS to be at the landfill to obtain all samples. Use of a
portable monitor during sampling is included in the proposal fee so that the gas at each sample point
can be analyzed briefly in the field before collection to help minimize potential air intrusion, which
would necessitate re-sampling after analysis.
Summa® canisters that will be used in the sampling effort will be pre-charged with inert gas and will
not require hazardous shipping. This proposal's fee includes the cost of shipping the sample canisters
to and from the landfill.
Once samples have been collected, they will be sent to Air Technology Laboratories (ATL)for analysis,
and ATL will process the samples per NSPS requirements (using EPA Methods 3C and 25C). SCS has
worked with ATL for twenty years on Tier 2 projects and has found them to be cost-effective as well as
very responsive and reliable. Normal turnaround time pricing is assumed since the sampling and
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Mr. Alberto Elefano, P.E.
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analysis assuming authorization by the City on a timely basis to enable completion prior to the
regulatory deadline.
Upon receipt of analytical results, SCS will prepare the Tier 2 sampling and analysis report for your
review, comment, and signature. No sampling map will be prepared for inclusion in the final report;
however, for the field work, a hand-marked map will be provided to the sampling technician (who will
mark any required field adjustments). Consistent with our prior projects with the City, SCS will submit
the report to TCEQ on the City's behalf. A full "pdf"file with delivery confirmation will also be provided
for your e-files.
CONTINGENCY TASK 7 — RESPOND TO FUTURE TCEQ
CORRESPONDENCE REGARDING GROUNDWATER MONITORING
This task allows for response to potential future TCEQ letters regarding groundwater monitoring
submittals. This task has been added to the proposal because it is SCS' experience that the TCEQ
Permits staff are generating increasing amounts of correspondence requiring non-routine responses.
Because the actual need for these services is unknown at this time, Task 7 will be billed on a time-
and-materials basis utilizing SCS' current fee schedule. The City will be consulted and approval
obtained prior to incurring any Task 7 costs.
TASK 8 — RESAMPLING (ONLY AS NEEDED)
Groundwater monitoring results occasionally indicate that resampling of a well must be conducted in
order to avoid the cost of regulatory actions such as assessment monitoring or corrective measures.
SCS takes all possible measures to avoid the need for resampling, including lab re-analysis,additional
statistical analysis, and implementing Alternate Source Demonstrations where possible. As a result,
the requirement for resampling is not a common occurrence at the City of Port Arthur Landfill. The
Task 8 total budget allows for two resampling events for the two-year term of this proposal, although
history indicates and SCS estimates this will not be required. The City will be consulted and approval
obtained prior to incurring any Task 8 costs.
TASK 9 — ALTERNATE SOURCE DEMONSTRATIONS
Groundwater monitoring results also occasionally indicate the need for an Alternate Source
Demonstration (ASD), to avoid unnecessary assessment monitoring. It has become crucial under the
new rules to avoid unnecessary assessment monitoring, because rule 30 TAC 330.409(b) dictates
that all downgradient wells must go into assessment instead of just one well as under the old rules.
In order for the City to budget for this possibility, we have included Task 9 that includes budget
estimated to be sufficient for two ASDs. ASDs vary widely in the required level of effort and associated
cost, and the budget listed in this optional task is for two ASDs with the likely maximum level of effort
and cost. It is unlikely that this level of effort would be required, and the City will only be invoiced for
costs actually incurred. Also, the City will be consulted and approval obtained prior to incurring any
Task 9 costs.
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TASK 10 — ON-CALL AIR SERVICES
The above scope is based on our years of experience with TCEQ air quality reporting and our current
understanding of TCEQ's current procedures. As you know, with air rules continuing to evolve at the
State and Federal level (including the recently proposed changes to EPA's New Source Performance
Standards), there may be unanticipated air quality-related needs in FY 2019-2020. The new NSPS
rules, Subparts Cf and XXX, were published in the Federal Register on August 29, 2016, and will
eventually affect most active landfills (including the City of Port Arthur Landfill). Since the City's landfill
has not been modified after July 17, 2014, it will be subject to the Subpart Cf, which requires that
TCEQ prepare Existing Guideline (EG) rules or a Federal EG rule will eventually take effect. At no
expense to the City, SCS will continue tracking the evolution of TCEQ's and EPA's EG rules and will
initiate contact with you as soon as any requirements to implement these new rules become effective.
We anticipate that the initial requirements will likely be minor paperwork filings on the landfill's size
and emissions. At that time, we will advise of possible future requirements and be ready to discuss
all possible impacts with you. Also, the City's management team may encounter questions related to
TCEQ inspections and other matters where it may be advantageous to have ready access to consulting
support.
To provide this support, we have established this On-Call Air Services task with a budget of $4,000.
This budget will only be used with the City's prior authorization on a time-and-materials basis using the
SCS fee schedule in effect at that time. Further, any charges to this task will be fully detailed in our
invoice.
FEE AND SCHEDULE
Project fees are detailed in Table 1. Billing will be conducted on a lump sum, monthly percent complete
basis. In order to provide cost savings to the City, fees proposed herein are the same as for the
previous two-year contract period, with a less than 2%annual adjustment for inflation.
Table 1. Tabulation of Estimated Fees
Task# Description Proposed
Fee
November 2019 Semiannual Groundwater and Gas
1 $26,300
Monitoring Event and Annual Reporting
2 February 2020 Quarterly Gas Monitoring $1,325
3 May 2020 Semiannual Groundwater and Gas Monitoring Event $21,750
4 August 2020 Quarterly Gas Monitoring $1,325
5 Air Quality Services $7,000
6 NSPS Tier 2 Field Sampling and Reporting $21,750
7 Respond to TCEQ Correspondence* $5,600
8 Resampling* $2,900
9 Alternate Source Demonstrations* $4,000
10 On-Call Air Services $4,000
Total ) $95,950
*Time-and-materials tasks requiring additional City authorization prior to incurring costs. As noted
above,the estimated fees for these tasks will be invoiced using SCS' current fee schedule (attached).
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SCS will maintain a schedule for all of our services and perform our work to meet compliance and
regulatory deadlines.
ADDITIONAL SERVICES
As with our current monitoring project, the following services are not a part of this scope, and will be
considered additional services. No such additional services will be initiated by SCS prior to receiving
the City's approval:
• Sampling for constituents not listed in the GWSAP;
• Field services time extending beyond three days for one event caused by slow well recharge,
well access problems, well mechanical problems, or weather problems;
• Disposal of purge and other wastewater. It is assumed City will provide drums at each sample
location and will be responsible for emptying drums;
• Well or gas probe repair;
• Follow-up required by landfill gas exceedances;
• Attending TCEQ inspections;
• Redevelopment or any other monitor well maintenance required for field sampling or
requested by any party;
• Additional time associated with VOC occurrences or any exceedances of federally-promulgated
Maximum Contaminant Limits;
• Amending GWSAP; and
• Sampling and analyzing water samples from wells other than the 15 Subtitle D groundwater
monitoring wells.
SUMMARY
SCS appreciates this opportunity to continue to provide these groundwater services for the City of Port
Arthur. As with other recent projects for the City, receipt of a Purchase Order will suffice for our notice
to proceed. In view of our history of working with the City, we have not included a Statement of
Qualifications. Nevertheless, we would be pleased to provide further information on our qualifications
and experience, if you deem appropriate. If you have any questions related to this proposal, please
feel free to contact us at (817) 571-2288.
Sincerely,
Kevin D.Yard, P.E., BCEE James Lawrence, P.G.
Vice President Director of Groundwater Services
SCS ENGINEERS SCS ENGINEERS
TBPE Registration No. F-3407
cc: Mr.Justin Thomas, City of Port Arthur Landfill Manager
Mr.Joseph Krasner, P.E., SCS Engineers
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