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Expert Report
Hydrogeological Investigation
Bridgeton Landfill
Prepared for
Lathrop & Gage
October, 2015
1. Introduction I am John W. Oneacre, President of Ground Water Solutions, Ltd. (GWS), an
environmental consulting firm located at 12902 Bristol Berry Dive, Cypress, Texas
77429. Information concerning my professional credentials is provided in the attached
resume in Appendix A, and summarized below.
a. I have a Bachelor of Science degree in geology from Kent State University
and a Master of Science degree in geology from Kent State University.
b. I am a Certified Professional Geologist (CPGS No. 6338).
c. I am a Registered Geologist in the State of Texas (No. 4556).
d. I am a Registered Geologist in the State of Indiana (No. IN2314).
e. I am a Registered Geologist in California (No. 6450) and Kentucky (No.
2270).
f. I am a Certified Engineering Geologist in California (No. 2008).
g. I am a Certified Environmental Manager (CEM) in Nevada (EM 2169).
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h. I have approximately 41 years of professional geological and
hydrogeological experience working for Fortune 500 companies as well as
geotechnical consulting companies.
i. I have owned Ground Water Solutions for approximately sixteen years.
j. In my career as a hydrogeologist/engineering geologist, I have personally
been involved with several hundred projects dealing with ground water
related issues. As part of my responsibilities on these ground water
projects, I have worked on numerous contracts, consent agreements,
work plans, landfill design, and ground water investigations.
k. I have extensive geological experience throughout the United States and
have worked on landfill ground water projects in 13 countries. I was
responsible for the RCRA ground water monitoring of approximately 100
municipal solid waste landfills in the United States and have worked on
dozens of other landfill projects.
l. I have been an invited speaker at several universities, USEPA Region I
and Region IX, several State regulatory agencies including the Texas
Commission on Environmental Quality (TCEQ), and the Australian EPA.
m. For the past thirty-five years, my experience has focused on ground water
concerns including contamination, assessment, and supply. This
experience includes wok on dozens of contaminated ground water
projects including hazardous waste sites. I have managed the
environmental cleanup of several Federal Superfund sites listed on the
National Priority List (NPL).
n. I have personally designed, conducted, and analyzed dozens of pump
tests conducted in various geological settings. Tests were conducted at
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flow rates as low as a few gallons per minute to wells capable of yielding
over 1,000 gallons per minute.
o. I have worked on many ground water projects in the United States,
including Missouri, that occur in fractured limestones.
p. I have appeared as an expert witness in 9 judicial and administrative
proceedings where the issues focused on potential or existing
contamination of ground water. Several of these proceedings were landfill
cases.
2. Executive Summary
a. I have reviewed the Plaintiff’s report on the groundwater at the Bridgeton
Landfill titled “Bridgeton Sanitary Landfill Groundwater Investigation
Report, St. Louis County, Missouri, August, 2015. In my professional
opinion the report has two serious deficiencies. The first deficiency is the
failure to recognize the industrial setting of the landfill and surrounding
industries that could be alternate sources of impact to groundwater. The
second deficiency of the report is the technical discussion of geochemistry
and groundwater movement. The geochemical discussion failed to
discuss sources of trace VOCs in the groundwater, other than leachate,
such as laboratory artifacts, LUST sources onsite and offsite, and landfill
gas. The groundwater movement discussion failed in several ways; these
included measuring groundwater levels in the MDNR wells after, rather
than before, sampling; uncertainty that the groundwater levels in the
MDNR wells had reached equilibrium prior to taking level measurements,
thus potentially giving an erroneous groundwater flow direction; failure to
use groundwater elevations from four St. Louis Deep/Shallow Salem wells
listed in Table 2 to prepare a potentiometric map that depicts groundwater
flow toward the landfill in that hydrostratigraphic unit; and failure to
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recognize upward trends in groundwater elevations in Champ Landfill
monitor wells. This report provides my review and professional opinions
of Mr. Price’s report.
3. Plaintiff’s Ground Water Investigation at Bridgeton Sanitary Landfill
a. Peter Price of the Missouri Department of Natural Resources (MDNR)
prepared a report titled “Bridgeton Sanitary Landfill Groundwater
Investigation Report, St. Louis County, Missouri, August, 2015.
b. As part of the investigation, MDNR conducted the following tasks:
i. Installation of monitor wells on private property adjacent to the
Bridgeton Sanitary Landfill (BSLF) to determine if off-site
groundwater has been impacted (Price 0000010);
ii. Review of historic groundwater quality for trends (Price 0000010);
iii. Sampling of monitor wells at BSLF and MDNR wells during the
week of August 17-21, 2015 (Price 0000012);
iv. Review of historic groundwater levels for trends (Price 0000010);
v. Measurement of ground water levels at BSLF on August 17, 2015
and MDNR wells on August 20, 25, and 28, 2015 (0000011);
vi. Comparison of historical Champ Landfill data, applicable to the
Bridgeton investigation (Price 0000010);
vii. Leachate sampling (Price 0000010);
viii. Review of BSLF south pit leachate sump levels.
c. In August, 2015, MDNR installed a total of five (5) monitor wells on
property adjacent to BSLF; three wells, MO-1-SS, MO-1-SDR, and MO-2-
SD were installed adjacent to the southeast side of BSLF whereas MO-3-
SS and MO-3-SDR were installed adjacent to the southwest side of BSLF.
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d. Wells were screened in the deep St. Louis/shallow Salem
hydrostratigraphic zone (SS designation) and the deep Salem
hydrostratigraphic zone (SD and SDR designations).
e. Appendix G of Mr. Price’s report contains a report by Dr. David J.
Wronkiewicz of Missouri University of Science and Technology. His report
is titled “Report on Redox Reactions Inferred from the Chemical
Composition of Water Collected from the PZ-104-SD and PZ-106-SD
Monitoring Wells at the Bridgeton Sanitary Landfill, St. Louis County,
Missouri.
f. The remainder of my report will discuss the reports of Mr. Price and Dr.
Wronkiewicz.
4. Plaintiff’s Interpretation of Leachate Impact to Ground Water at the Bridgeton Sanitary Landfill
a. Mr. Price concluded, based upon his groundwater investigation of the
BSLF, that: i. Detections of volatile organic compounds are representative of
leachate from the landfill on the southwest side of the south quarry
area and nearby monitoring wells on adjacent property (Price
0000015); ii. Water levels in those wells are consistent with a groundwater flow
direction outward from the landfill (Price 0000015); and, iii. An inward hydraulic gradient has not been consistently maintained
at the Bridgeton Sanitary Landfill (0000015). I have provided my
response to Mr. Price’s conclusions in the following sections of my
report.
b. Response to claim that volatile organic compounds are representative of leachate from the landfill.
i. Mr. Price concluded that the volatile organic compounds (VOCs)
detected in the groundwater in the southwestern side of the landfill
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are "representative of leachate”; however, Mr. Price apparently did
not consider alternative explanations for the VOCs in the
groundwater. ii. Mr. Price noted that seven VOCs were detected in the leachate
sample (Price 0000014); however, Mr. Price did not discuss
whether the laboratory had to dilute the leachate sample in order to
keep the results within the calibrated scale for the compounds.
Dilution of the sample could introduce common laboratory artifacts
such as acetone and MEK. Once the laboratory has run the
analysis on a diluted sample, the result is multiplied by the amount
of dilution; if a common laboratory artifact is detected in the diluted
sample, the concentration of the artifact is multiplied by the dilution
factor and will indicate a high concentration when, in reality, the
VOC is not actually present but is simply an artifact. Other
compounds such as Hexanone and MIBK could also be artifacts. iii. Mr. Price mentioned three VOCs, benzene, acetone, and 2-
butanone (MEK) in the groundwater. Two of these VOCS, acetone
and MEK are common laboratory artifacts and are poor responders
for calibration (USEPA, 1994). iv. Mr. Price did not indicate in his report whether any control samples
such as Trip Blanks, Field Blanks, Equipment Blanks, etc. showed
these two compounds. v. The USEPA (1994) gives specific guidance on qualifying VOCs
such as acetone and MEK that may be laboratory artifacts. It is not
apparent whether evaluation of laboratory artifacts was conducted. vi. Duplicate samples did show variation of results for acetone and
MEK. For example, acetone results for MO-2-SD were an
estimated “J” value and a non-detect (ND). Similarly, for MO-1-SS,
MEK was reported as an estimated “J” value and a non-detect (ND)
(Price 0000026). Other compounds that showed “J” and ND results
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for duplicate samples include Hexanone, MIBK, Xylene,
Ethylbenzene, and Carbon Disulfide. vii. Mr. Price did not discuss possible sources of VOCs in the
groundwater, unrelated to BSLF. For example, VOC detections at
upgradient well 114-AS appear to be related to contamination from
the upgradient PM Resources, Inc. property (Herst & Associates,
Inc., August, 2014). viii. A report by Environmental Data Resources, Inc. (EDR) identified
numerous sites within a one mile radius of BSLF that have had
known environmental issues. One site, PM Resources, Inc. is
listed as having RCRA Corrective Action Activity. MDNR has
acknowledged that PM Resources, Inc. appears to be the source of
groundwater impact at BSLF’s monitor well 114-AS (MDNR Letter
dated October 23, 2003). ix. EDR identified ten sites with a history of leaking underground
storage tanks within one mile of BSLF; another sixteen sites within
one mile of BSLF are listed as having underground storage tanks.
One site is within one third of a mile from BSLF; this site, the
Hussman Corporation, is listed on the Missouri Voluntary Cleanup
Program. x. A leaking underground storage tank (LUST) area is located on the
Site and is shown in Figures 5-8 through Figure 5-12B of the May,
2008 USEPA Record of Decision (ROD). The onsite LUST could
be a source for benzene, ethylbenzene, toluene, and xylene along
with other components of gasoline or diesel fuel. xi. In the May, 2008 ROD, on Page 8, the USEPA identified other
industrial facilities on Site that include concrete and asphalt batch
plants, and an automotive repair shop. Figure 4-1 of the ROD
shows the locations of these industrial facilities. An active asphalt
facility, Metro Paving, is also in close proximity to BSLF and is
listed as a LUST facility (LUST ID ST0000570.)
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xii. BSLF is situated in an industrial area and as EDR reported,
numerous sites nearby could potentially be sources of impact to
groundwater beneath BSLF. xiii. Industrial sites listed in 3.b.viii through 3.b.xi are not discussed in
Mr. Price’s “Bridgeton Sanitary Landfill Groundwater Investigation
Report”. xiv. BSLF is currently in Assessment Monitoring; nine monitor wells are
part of the site’s Assessment Monitoring Plan (Herst & Associates,
Inc., June 25, 2015). The Assessment Monitoring Plan is dated
December 17, 2013 with an August 18, 2014 Addendum. Of these
nine wells, only PZ-104-SS and PZ-104-SD were included in Mr.
Price’s report. xv. VOCs detected in the monitor wells could be sources other than the
landfill, laboratory artifacts, landfill gas, or landfill leachate. VOCs
in trace amounts are common in landfill gas (Oneacre and
Figueras, 2004). xvi. Mr. Price included the report by Dr. David J. Wronkiewicz in
Appendix G. Dr. Wronkiewicz’s report is a technical discussion
regarding redox conditions and their relationship to solubility of
metals such as iron and manganese along with sulfur. xvii. Dr. Wronkiewicz noted increases in iron and manganese
concurrent with a decrease in sulfate (Wronkiewicz 0000004). A
possible explanation suggested by Dr. Wronkiewicz is that “…the
inclusion of large amounts of municipal waste with a high organic
content will produce reducing conditions. As fluids in a landfill
migrate, they may also promote reducing conditions in surrounding
areas” (Wronkiewicz 0000003). While I agree with Dr.
Wronkiewicz’s statement, there is another explanation that should
be discussed. xviii. Decomposition of waste in a landfill will produce strongly reduced
(anaerobic) conditions. Part of the decomposition process includes
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the production of landfill gas, primarily in the form of methane and
carbon dioxide. The presence of methane is indicative of strongly
reduced conditions. Also, if landfill gas migrates away from the
landfill, the presence of carbon dioxide will cause the pH of
groundwater to decrease. In monitor well PZ-104-SD, the pH
decreased from values above 7.0 to 6.44; this is notable because
pH is measured on a logarithmic scale. PZ-106-SD also showed a
decrease of pH to a low of 6.54 in 2014. This could indicate a
landfill gas issue. Dr. Wronkiewicz also mentioned an increase of
TOC; TOC in landfill gas condensate can have very high values
(USEPA, 1988) and can cause increase in TOC of nearby
groundwater. BOD and COD can also be elevated in landfill gas
condensate and cause increased levels of these constituents in
nearby groundwater. Another constituent mentioned by Dr.
Wronkiewicz is ammonia; he stated that ammonia increased then
decreased in PZ-104-SD. Ammonia is the reduced form of nitrogen
and is a common landfill gas constituent
(http://www.atsdr.cdc.gov/HAC/landfill/html/ch2.html#t2_1). Dr.
Wronkiewicz noted that sulfate decreased; this is due to the
reduced conditions that will result in the production of sulfide, the
reduced form of sulfur. xix. However, increased concentrations of chloride and Total Dissolved
Solids are not considered to be associated with landfill gas and
should be evaluated for the cause of the increases.
c. Response to claim that water levels in those wells are consistent with a groundwater flow direction outward from the landfill
i. Mr. Price stated that “According to Solid Waste Disposal Area
Operating Permit #118912 (MDNR, 1985), BSLF is required to
maintain an inward hydraulic gradient and maintain a liquid
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leachate level within 30 feet of the base of the landfill” (Price
0000013). This statement is not truly representative of the actual
language of the MDNR, 1985 letter for several reasons.
ii. First, the letter from Director Brunner, dated November 18, 1985
does not use the term “inward hydraulic gradient”.
iii. Second, Items 6.D and 6E actually give two different leachate level
criteria. In Item 6.D, “static leachate levels in the collection sumps
in the unfilled area of the quarry, as shown in the approved permit
documents, will be maintained at a level less than 30 feet above the
base of the sump”. In Item 6.E, “static leachate levels in the
previously filled areas of the quarry, as shown in the approved
permit documents, shall be maintained at a level less than 50 feet
above the base of the sump”.
iv. Third, the language of the MDNR November, 1985 letter required
that the leachate levels be maintained at levels referenced to the
base of the sump, not the base of the landfill.
v. Mr. Price infers from the MDNR November, 1985 letter that the
leachate levels within the landfill waste mass should remain at
elevations lower that the ground water levels in the surrounding
monitoring wells at the BSLF site (Price 0000013). However,
Golder Associates in its report titled “Leachate Head Calculation
Report, prepared for Laidlaw Waste Systems, Inc., July, 1996”,
stated on page 1 that: “Based on a November 18, 1985 letter from
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Fred Brunner, then director of the Missouri Department of Natural
Resources, the maximum allowable leachate head in the active pit
measured in each of four leachate risers, is 30 feet above the base
of each riser. The technical rationale for the permitted maximum
leachate head of 30 feet is unknown”. Golder Associates did not
use the term “inward hydraulic gradient” when discussing Director
Brunner’s letter and did not seem to know the technical reason for
the 30 feet criteria. The purpose of Golder’s report was given on
page 2 of the report: “This report documents leachate head
calculations made to determine a technically justifiable leachate
head that is sufficient to maintain an inward hydraulic gradient
without excessive pumping into the MSD sewer system.”
vi. Golder’s report concluded on page 14 that current leachate
pumping was “maintaining a leachate level that is lower than
technically justified”. Golder calculated that leachate levels could
increase another 20 to 35 feet (total leachate head of 50 to 65 feet)
and still maintain an inward gradient with a factor of safety
incorporated into the calculations.
vii. Mr. Price stated that water levels were collected from the BSLF
wells on August 17, 2005 and the State of Missouri wells on August
25, 2015.
viii. It would be better technical practice to take measurements on the
same day, if possible. Also, the MDNR used water level
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measurements for its wells after sampling its new monitor wells.
MDNR should have taken water level measurements prior to
sampling. Also, there is a question as to whether adequate time
was allowed from drilling, well installation, development, and
sampling for the water level in some of the State wells to fully
stabilize.
ix. Questions also arise regarding the selection of monitor wells for
construction of the potentiometric contour maps. In Figure 13, Mr.
Price did not use water level elevations for PZ-105-SS and PZ-107-
SS even though he presented those elevations in Table 2.
Additionally, PZ-204-SS is in close proximity to MO-3-SS but was
not listed in Table 2 and was not used in the construction of the
potentiometric contour map of Figure 13.
x. Utilizing the groundwater elevations of PZ-105-SS and PZ-107-SS
may result in a potentiometric map with different groundwater flow
direction. It is recommended that groundwater elevations from
these wells be used for constructing the potentiometric map.
xi. Mr. Price constructed potentiometric maps for both the Deep St.
Louis/Shallow Salem wells and the Deep Salem wells in Figures 13
and 14. However, only Deep Salem wells were used by Mr. Price
for construction of the potentiometric map along the southeast
corner of the South Quarry Pit, despite the fact that four Deep St.
Louis/Shallow Salem wells exist with the four Deep Salem wells.
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These four Deep St. Louis/Shallow Salem wells are PZ-209-SS,
PZ-211-SS, PZ-104-SS, and PZ-210-SS. Groundwater elevations
for these four Deep St. Louis/Shallow Salem wells are provided by
Mr. Price in Table 2 of his report but he did not produce a
potentiometric map using those four groundwater elevations.
Highest groundwater elevation of 468.15 feet was in PZ-209-SS,
located the greatest distance from the landfill. Conversely, the
lowest groundwater elevations of 464.73 feet and 460.66 feet were
in PZ-104-SS and PZ-210-SS, located the shortest distance from
the landfill. In my opinion, a potentiometric map using these four
wells would show an inward hydraulic gradient.
d. Response to claim that an inward hydraulic gradient has not been
consistently maintained at the Bridgeton Sanitary Landfill
i. Plaintiff’s groundwater expert, Mr. Price stated in the MDNR
August, 2015 report that a comparison of water levels between
BSLF and the IESI MO Champ Landfill showed that:
ii. “Between 2005 and approximately 2010 the water levels in the
BSLF wells ranged in elevation from approximately 360 to 450 feet
amsl for both the SS and SD monitoring wells. From approximately
2010 to the present groundwater levels have increased in all but
five of the BSLF wells, including the period of 2012 and into 2013
when Missouri experienced a severe drought. The groundwater
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elevations in several of the SS and SD wells, particularly those on
the east side of the landfill, are currently at elevations 10 to 15 feet
higher than groundwater elevations prior to 2010.”
iii. Mr. Price continues by stating: “In contrast, water levels graphed
over the same 10 year time period at the IESI MO Champ Landfill
have remained relatively unchanged or have receded. Water levels
in many of the monitoring wells near the south pit quarry area of
IESI MO Champ Landfill are at elevations lower than they have
been for several years” (Price 0000013).
iv. Mr. Price constructed three potentiometric maps, Figures 13
through 15 as a means to illustrate that inward hydraulic
e. Response to Plaintiff’s claim of ground water levels at BSLF
i. Mr. Price’s claim that water levels at the IESI MO Champ Landfill
have remained relatively unchanged or have receded is not correct.
Mr. Price did not show any type of trend for the water levels in the
monitor wells. I have plotted hydrographs of monitor wells at the
IESI MO Champ Landfills that clearly demonstrate that the water
levels in several wells have not remained relativey unchanged or
receded. For example, the hydrograph for SL 1 (Figure 1) covers
the time period used by Mr. Price. I have added a simple linear
trend line to this hydrograph; the trend line clearly shows that the
trend in water levels in SL 1 from 2005 to 2015 is upward. This
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upward trend is due to the fact that over the ten year period, the
water levels have increased from approximately 377 feet to as
much as 425 feet with an ending water level of approximately 407.
The water level increased by nearly 50 feet just prior to 2012 and,
as of 2015, was still approximately 30 feet higher than the level in
2005. SL 1 is screened in the St. Louis limestone.
ii. The hydrograph for SL 4 (Figure 2), another St. Louis limestone
well, also shows a significant increase in water level over the ten
year period used by Mr. Price. The trend line clearly demonstrates
an upward trend over the ten year period; the water level in 2015
was approximately 40 feet higher than the level in 2005.
iii. The hydrograph for S 10 (Figure 3) shows a significant increase in
water level over the ten year period used by Mr. Price. The trend
line clearly demonstrates an upward trend over the ten year period;
the water level in 2015 was approximately 30 feet higher than the
level in 2005. Monitor well S 10 is screened in the Salem
limestone.
iv. The hydrograph for S 7 (Figure 4), another Salem limestone well,
shows a significant increase in water level over the ten year period
used by Mr. Price. The trend line clearly demonstrates an upward
trend over the ten year period; the water level in 2015 was
approximately 45 feet higher than the level in 2005.
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f. Although Mr. Price noted that there are several similar geologic and
hydrologic characteristics (Price 0000010), there are other
considerations when making comparisons:
i. The BSLF is a closed landfill; the north pit ceased taking waste in
1985 and the south pit ceased taking waste in 2004 (Price
0000006).
ii. The IESI Champ landfill is an active landfill and portions of the
quarry are still producing limestone.
iii. The production of limestone may affect the ground water elevations
as a result of dewatering for ground water control.
iv. Operations of the active landfill and quarry could affect the ground
water elevations at the IESI Champ landfill.
v. Geologic and hydrogeologic conditions could be variable over the
distance between the two landfill sites; the distance between the
two landfill sites is approximately 1.25 miles.
vi. Water level data for some IESI Champ landfill wells do not exist
prior to 2010; for example, deep Salem wells S 29, S 30 and S 31
do not have data from the time period of 2005 to 2010. Likewise,
St. Louis monitor well SL 29 does not have ground water elevation
data prior to 2010. Therefore, water level trends cannot be
analyzed over the ten year time period for these wells.
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g. Response to Mr. Price’s claim that groundwater level trends at BSLF
have increased over the past 10 years whereas groundwater levels at
Champ Landfill have remained relatively unchanged or have receded.
i. Mr. Price stated that, regarding the water levels at BSLF, “The
groundwater elevations in several of the SS and SD wells,
particularly those on the east side of the landfill, are currently at
elevations 10 to 15 feet higher than groundwater elevations prior to
2010 (Price 0000013).
ii. Mr. Price’s Section 3.1.1 is titled “Groundwater Elevation Trend
Analysis”; however, Mr. Price does not show any trend lines for any
of the monitor well hydrographs.
iii. Mr. Price’s groundwater elevation scale on Figures 8 through 12
tends to mask the upward trend in several monitor wells, including
the Champ Landfill wells.
iv. Conversely, 2015 water levels at several of the IESI Champ landfill
monitor wells are as much as 45 feet higher than the groundwater
levels prior to 2010 as stated in Section 3 of this report.
v. Water levels in the BSLF monitor wells do show increasing trends;
however, some of these increases over the period of 2005 to 2015
are small compared to the water level increases at several IESI
wells. For example, well 114 AS showed nearly identical beginning
and ending water levels of approximately Elevation 430. Over the
10 year period, the water level increase was limited to
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approximately 5 feet; therefore, the overall upward trend was
nominal.
vi. Overall, the beginning and ending water levels in the BSLF monitor
wells ranged from virtually no change to a maximum change of 30
feet in 201A SS; most changes ranged from 3 feet to 25 feet. Half
of the BSLF wells used by Mr. Price showed changes of 10 feet or
less.
vii. Conversely, the greatest increase of water levels over the ten year
period actually occurred at the IESI Champ landfill; water level
increases of 45 feet occurred at the IESI Champ landfill in S 7.
viii. Therefore, increases in water levels alone may not be indicative of
a hydraulic gradient problem at the BSLF.
ix. Mr. Price correctly noted that from 2010 to the present water levels
at BSLF have increased in all but five wells (Price 0000013);
however, Mr. Price did not discuss the fact that between 2005 and
2010 many wells showed a decreasing trend in water levels. I
prepared a graph for 106 SD (Figure 5) that clearly shows this initial
downward trend from 2005 through 2010. I placed a polynomial
trend on the graph that shows the downward trend followed by an
upward trend. This gives a clearer picture of the actual fluctuation
in water levels over the ten year time period. The water level
increased by about 30 feet from the lowest level to the present level
in 2015. However, looking at the entire ten year interval, the water
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level increased by only about 10 feet from November, 2005 to the
present.
5. Conclusions
a. Having reviewed multiple documents, I have made the following
conclusions.
i. Multiple sources of benzene can be a source or sources of
groundwater impact. The LUST that exists onsite is just one
example of a potential source of benzene that could be impacting
groundwater. Other potential benzene sources include nearby
LUST sites such as PM Resources.
ii. Some of the VOCs listed in Table 4 of Mr. Price’s report may simply
be laboratory artifacts; these artifacts include acetone, MEK, MIBK,
Carbon Disulfide, Chloroform, and Hexanone. A thorough QA/QC
study of these VOCs.
iii. A review of the leachate sample would determine if the sample
were diluted by the laboratory and help explain high concentrations
of suspected laboratory artifacts.
iv. Some groundwater elevations in the MDNR wells may not be truly
representative if the levels had not fully stabilized. This could
change the potentiometric maps and ground water flow direction.
v. Groundwater level measurements should be taken on the same
day, if possible, in wells with stable water levels.
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vi. Deep St. Louis/Shallow Salem potentiometric map in the southeast
corner of the South Quarry Pit should be constructed to determine
groundwater flow direction. It is my professional opinion that
construction of a potentiometric map using the groundwater
elevations from Table 2 of Mr. Price’s report would show
groundwater flow toward the landfill, indicating an inward hydraulic
gradient.
vii. Drawing trend lines on several Champ Landfill monitor well
hydrographs clearly shows upward trend; some of the Champ wells
have groundwater level increases greater than monitor wells at
BSLF. This fact is contrary to Mr. Price’s statement that the Champ
Landfill monitor well levels remained relatively unchanged or have
receded.
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REFERENCES
Environmental Data Resources, Inc., 2015. Bridgeton Landfill, 12976 St. Charles
Rock Road, Bridgeton, MO 63044, Inquiry Number 4422106.2s, September 25,
2015. 788pp.
Golder Associates, Inc. 1996. Leachate Head Calculation Report, prepared for
Laidlaw Waste Systems, Inc. 16 pp.
Herst & Associates, Inc. 2014. Detection Monitoring Program Groundwater
Statistical Analysis, Semi-Annual Report, May 2014 Sampling Event. Bridgeton
Landfill, LLC. Bridgeton Landfill, Bridgeton, Missouri. MO DNR Permit #MO-
118912. 684 pp.
Herst & Associates, 2015. Second Quarter 2015 Assessment Monitoring Event
Summary Report, Bridgeton Landfill, LLC-Bridgeton Landfill, Bridgeton, Missouri,
Missouri Department of Natural Resources Permit #MO-118912. 14 pp.
Missouri Department of Natural Resources, 1985. Letter from Director Frederick
A. Brunner to Mr. William McCullough, President, West Lake Landfill, Inc. RE:
Solid Waste Disposal Area Operating Permit #118912. 8 pp.
Missouri Department of Natural Resources, 2003. Letter RE: Groundwater
impact to monitor well 114-AS from PM Resources.
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Oneacre, John, and Figueras, Deborah, 1996. Innovative Ground Water
Monitoring at Municipal Solid Waste Landfills. Proceedings: Texas Solid Waste
Management Conference, Austin, TX. 13 pp.
Price, Peter, 2015. Bridgeton Sanitary Landfill Groundwater Investigation
Report, St. Louis County, Missouri. August, 2015. 58 pp.
USEPA, 1988. Project Summary: Municipal Landfill Gas Condensate,
Hazardous Waste Engineering Research Laboratory, Cincinnati, OH 45268,
EPA/600/S2-87/090. 4 pp.
USEPA, 1994. Laboratory Data Validation Functional Guidelines for Evaluating
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EPA/540/R/94/082. 47 pp.
USEPA, 1994. USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review, Office of Solid Waste and Emergency
Response, EPA/540/R-94/012. 129 pp.
USEPA, 2008. Record of decision, West Lake Landfill Site, Bridgeton, Missouri,
Operable Unit 1, May, 2008. Prepared by US EPA, Region 7, Kansas City,
Missouri. 112 pp.
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Wronkiewicz, Dr. David J., 2015. Report on Redox Reactions from the Chemical
Composition of Water Collected from the PZ-104-SD and PZ-106-SD Monitoring
Wells at the Bridgeton Sanitary Landfill, St. Louis, County, Missouri. 7 pp.
ONEACRE_0000024