South Quarry Subsurface Assessment Actions & LCS ......Bridgeton Landfill, a closed landfill located...

WORK PLAN - SOUTH QUARRY SUBSURFACE ASSESSMENT ACTIONS & LEACHATE COLLECTION SUMP (LCS)

INSTALLATIONS

Section XII, Final Consent Judgment 06-29-2018

Prepared for:

Bridgeton Landfill, LLC Bridgeton, Missouri

July 2018

Prepared by:

406 East Walnut Street Chatham, IL 62629 3377 Hollenberg Drive Bridgeton, MO 63044

Work Plan – South Quarry Subsurface Assessment Actions & LCS Installations Bridgeton Landfill, LLC – Bridgeton, Missouri i

TABLE OF CONTENTS LIST OF ACRONYMS ............................................................................................................... A1

1.0 INTRODUCTION ............................................................................................................... 1 1.1 Project Overview .............................................................................................................. 2 1.2 General Facility Health and Safety, Site Control, and PPE Requirements ....................... 2

2.0 RESPONSE ACTIONS – SOUTH QUARRY SUBSURFACE ASSESSMENT ........... 3 2.1 Evaluation of Continuing Assessment Indicators ............................................................. 3

2.1.1 South Quarry Topographic Surface Changes .............................................................. 4 2.1.2 South Quarry Landfill Gas Temperature Monitoring Data .......................................... 4 2.1.3 Evaluation Responses .................................................................................................. 4

2.2 Temperature Monitoring Probe (TMP) Installations ........................................................ 5 2.2.1 Additional Health & Safety Considerations ................................................................ 6 2.2.2 TMP Location Determinations .................................................................................... 6 2.2.3 TMP Drilling/Installation Equipment and Construction Materials .............................. 7 2.2.4 Occupational Monitoring and Odor Management ....................................................... 7 2.2.5 Waste Handling and Decontamination ........................................................................ 8 2.2.6 Construction Quality Assurance .................................................................................. 8 2.2.7 TMP Monitoring, Maintenance, Replacement, and Reporting .................................... 9

2.3 Criteria for Action in Response to Subsurface Assessment ............................................ 11

3.0 RESPONSE ACTION – SOUTH QUARRY LCS INSTALLATIONS ........................ 11 3.1 Leachate Collection Sump (LCS) Design and Location Determinations ....................... 12 3.2 LCS Drilling/Installation Equipment and Construction Materials .................................. 12

3.2.1 Well Development and Waste Handling .................................................................... 13 3.2.2 Equipment Decontamination ..................................................................................... 14

3.3 Occupational Monitoring and Odor Management .......................................................... 14 3.4 Construction Quality Assurance ..................................................................................... 14 3.5 LCS Liquid Handling Equipment Installation ................................................................ 15

4.0 PROJECT REVIEW & REPORTING ........................................................................... 15

5.0 RESPONSE ACTION TIMELINE & COMPLIANCE SCHEDULE .......................... 16

6.0 PROJECT TEAM ............................................................................................................. 17

7.0 REFERENCES .................................................................................................................. 19

FIGURES

Figure 1........................................................................... Bridgeton Landfill South Quarry Site Plan Figure 2............................................................................................... TMP Construction Schematic Figure 3................................................................................................ LCS Construction Schematic Figure 4.................................................................................................. Decision Tree / Action Plan

APPENDIX

Appendix A ...................................................... Example Missouri Asbestos Inspector Certification

Work Plan – South Quarry Subsurface Assessment Actions & LCS Installations Bridgeton Landfill, LLC – Bridgeton, Missouri A1

LIST OF ACRONYMS ACM – Asbestos-Containing Materials ASTM – American Society for Testing and Materials BGS – Below Ground Surface CEC – Civil & Environmental Consultants, Inc. CO – Carbon Monoxide EVOH – Ethylene Vinyl Alcohol FEI – Feezor Engineering, Inc. GCCS – Gas Collection and Control System GEW – Gas Extraction Well GIW – Gas Interceptor Well GPS – Global Positioning System HASP – Health and Safety Plan HAZWOPER – Hazardous Waste Operations and Emergency Response HDPE – High-Density Polyethylene HEPA – High-Efficiency Particulate Arresting/Arrestance HES – Heat Extraction System H2S – Hydrogen Sulfide LCS – Leachate Collection Sump LEL – Lower Explosive Limit MAGO – Missouri Attorney General’s Office MDNR – Missouri Department of Natural Resources PPE – Personal Protective Equipment PPM – Parts Per Million QA/QC – Quality Assurance/Quality Control SSR – Subsurface Reaction TMP – Temperature Monitoring Probe VOC – Volatile Organic Compound

Work Plan – South Quarry Subsurface Assessment Actions & LCS Installations Bridgeton Landfill, LLC – Bridgeton, Missouri 1

1.0 INTRODUCTION This Work Plan (the Plan) describes the design, installation, and implementation of response actions at the Bridgeton Landfill in Bridgeton, Missouri through which compliance with certain requirements described in the facility’s Operating Permit (MDNR, 1985) will be achieved. In accordance with a Final Consent Judgment issued to Bridgeton Landfill, LLC (Bridgeton Landfill) and entered June 29, 2018, the Plan details the specific response actions to be undertaken at the site to comply with an Operating Permit condition (6D) associated with leachate extraction in specific portions of the closed landfill (South Quarry). A subsurface reaction (SSR) within the South Quarry of the Bridgeton Landfill has led to conditions that have adversely affected leachate collection sumps (LCSs) installed in this portion of the site, severely diminishing their effectiveness. Conditions include significant settlement of the surface topography and subsurface temperatures (at depths ranging from 40 to more than 200 feet below the surface) in excess of 200° F. The significant settlement creates forces on the leachate collection piping that are greater than those that can be tolerated by the piping material, thus causing structural collapse. Some of the LCSs maintain their ability to pump leachate and Bridgeton Landfill continues to perform preventative maintenance and rehabilitation of this infrastructure. In addition to the LCSs, Bridgeton Landfill has developed an aggressive program of leachate collection utilizing other leachate and condensate collection structures such as landfill gas extraction wells, horizontal collectors and sumps, perimeter sumps, condensate sumps and traps, trench drains, and toe drains. This network of structures includes a series of forcemains and gravity flow pipes that convey leachate to grit chambers and lift stations that ultimately route leachate/condensate to the on-site leachate pre-treatment plant. As of July 2018, there are from 100-120 pumps operating in the South Quarry actively extracting and conveying leachate from the waste mass.1 Bridgeton Landfill continues to aggressively inspect and maintain infrastructure at the facility on a daily basis. The facility inspects the leachate collection system using a series of “Quad Checks” to ensure the continuation of pumping efforts. These checks, combined with the stocking of replacement pumps/parts and a staff of qualified, well-trained employees and contractors, assures that leachate continues to be safely collected from the South Quarry in spite of the reaction and the excess residual heat caused by it. Due to the dynamic nature of the South Quarry as a result of the reaction, this Plan includes a timeline for implementing response actions (based on milestone events that trigger the actions) in lieu of a calendar-date compliance schedule. The Plan describes the criteria to be used for initial and follow-up actions and provides for frequent review of project status. Feezor Engineering, Inc., on behalf of Bridgeton Landfill, has developed this Work Plan in cooperation with and assistance from Civil & Environmental Consultants, Inc. and Weaver Consultants Group.

1 The number of pumps actively operating in the South Quarry infrastructure changes as equipment is brought on-line or taken out-of-service for maintenance/repair/replacement or changing well conditions.


1.1 Project Overview Bridgeton Landfill, a closed landfill located within the 200-acre West Lake Landfill Superfund Site in St. Louis County, Missouri, was used for limestone quarrying and crushing operations before portions of the quarried areas (North Quarry and South Quarry) were used for municipal waste disposal (Figure 1). LCSs are located in both the North and South Quarry, but due to the occurrence of a reaction in the South Quarry, the performance of its leachate collection sumps has been impacted. Condition 6D of Bridgeton Landfill’s operating permit requires the static leachate level in each LCS in the “unfilled area of the quarry” (South Quarry) be maintained at a height of less than 30 feet above the base of the LCS. Section XII of the Final Consent Judgment (MAGO, 2018) includes a requirement that the facility submit a Work Plan to MDNR, within 30 days of entry of the judgment, that details planned actions to achieve compliance with Condition 6D. The planned actions, as described in the following sections of this document, will include:

Preliminary response actions focused on assessing currently monitored data to determine when and where subsurface temperature and settlement conditions in the South Quarry may have improved such that LCS installation/operation may be feasible under more favorable health and safety circumstances than current conditions provide,

Follow-up response actions to verify preliminary indications of sufficiently lowered subsurface temperatures, and

Design, installation, and operation of new LCSs that will facilitate compliance with Condition 6D.

Designs of new South Quarry LCSs and Temperature Monitoring Probes (TMPs) that would be installed per this Plan are briefly described herein and have been based on general installation and construction technologies previously utilized at Bridgeton Landfill. Detailed design, construction, and equipment specifications would be submitted to MDNR for review and approval once improved subsurface conditions in the South Quarry were confirmed and TMP/LCS installation was warranted. 1.2 General Facility Health and Safety, Site Control, and PPE Requirements Bridgeton Landfill provides health and safety training for its employees and contractors engaged in work at the facility. During field activities associated with this Work Plan, workers will demonstrate competency in their relevant skills and activities, will follow the designated health and safety procedures as presented in the training provided by the facility, will be alert to the potential hazards associated with their work, and will exercise reasonable caution at all times. Workers will maintain certifications that they have received HAZWOPER training applicable to their duties. Much of the work associated with the installation of TMPs and LCSs (discussed in later sections of this Plan) will involve encountering waste, and field activities may involve the potential for exposures to various health hazards, i.e. heat/cold stress, uneven surfaces, high-temperature vapors or liquids, etc. All project workers and visitors who enter a work area will be provided the personal protective equipment (PPE) and information necessary for their protection from the work area’s


identified potential hazards. Bridgeton Landfill will provide workers with health and safety guidelines that represent minimum standard procedures for reducing potential risks associated with this project and the Bridgeton Landfill in general. The guidelines will include, but not be limited to, methods of communication, first aid, work area prohibitions, exposure awareness, PPE use, etc. Also, site control will require workers and authorized visitors/guests to access the Bridgeton Landfill via the main facility entrance off of St. Charles Rock Road (FEI, 2016).

The PPE requirements for all project workers will at a minimum consist of Level D equipment/materials: hard hat, normal work clothing, safety glasses, steel- or composite-toed boots, and high-visibility outerwear. For intrusive work or other activities that may involve leachate and/or landfill gas, use of a 4-gas meter to monitor the area for concentrations of methane (% LEL), oxygen (%), carbon monoxide (ppm CO), and hydrogen sulfide (ppm H2S), will be required. Work will be suspended and subject to the re-evaluation and follow-up procedures specified in Bridgeton Landfill’s Health and Safety Plan (HASP) if monitoring indicates gas concentrations exceed the limits stated in the HASP.

2.0 RESPONSE ACTIONS – SOUTH QUARRY SUBSURFACE ASSESSMENT

Although current subsurface conditions associated with the reaction in the South Quarry do not automatically preclude TMP installations, they would likely impart a higher degree of potential risk to human health during the work. Due to this current potential for increased risks to workers during installation, and the anticipated short-lived structural integrity of a new South Quarry subsurface component, Bridgeton Landfill believes that the subsurface conditions must improve before the installation of new TMPs is appropriate. The following sections describe on-going and planned monitoring efforts that will be evaluated to determine when TMP and subsequent LCS installation activities can be performed in a safe, pragmatic manner.

2.1 Evaluation of Continuing Assessment Indicators

Bridgeton Landfill submits reports to MDNR in accordance with Section 33 of the Final Consent Judgment. Each report includes comments on various landfill monitoring information, including landfill gas flow information, gas quality data, and South Quarry settlement data. Summaries cover topics related to the facility’s gas collection and control system (GCCS), the heat extraction system (HES) installed in the northern portion of the South Quarry (Neck Area), the site’s leachate management system (including operations at the leachate pre-treatment plant), and other specific projects as needed. Other attachments to the reports include flare data, tabulations of gas well analytical data and the associated laboratory reports, gas wellfield data, and leachate characterization, production, and discharge data (per Sections VIII and IX of the judgment).

For purposes of this Plan, South Quarry topographic surface changes (settlement) and landfill gas data collected from gas extraction wells and other existing infrastructure located in the South Quarry are the primary assessment indicators to be evaluated. Criteria specific to these data will serve as milestones for subsequent actions designed to achieve compliance with Condition 6D of the facility’s Operating Permit.


2.1.1 South Quarry Topographic Surface Changes Currently, changes in the topographic surface of the South Quarry at Bridgeton Landfill are determined on a monthly basis. Procedures rely on a surveyor, using GPS technology, to measure the elevation, in feet above mean sea level, at nearly 300 points across the expanse of the South Quarry in one day’s time every month. Changes in the elevation values at each point that occur month to month are used to construct a settlement front map that depicts the described changes across the South Quarry topographic surface. A brief summary of the maximum settlement rate observed during the reporting period is included in each report. 2.1.2 South Quarry Landfill Gas Temperature Monitoring Data Currently, Bridgeton Landfill personnel perform comprehensive wellfield investigations on a daily basis in an ongoing aggressive program designed to optimize landfill gas collection and control at the facility. Wells that exhibit downhole integrity issues (obstructions, dangerous conditions, etc.) that prevent them from being utilized for landfill gas and leachate collection are designated for abandonment (if obstructed) or temporarily decommissioned to await improved conditions and a return to service. Wellfield-related activities at the site (well installation, abandonment, decommissioning, and return-to-service events) are reported to MDNR in Landfill Gas Corrective Action Updates. Currently, the South Quarry gas extraction network of extraction wells (GEWs), LCSs, and gas interceptor wells (GIWs) account for approximately 78% of the landfill gas volume collected at the facility. A flexible membrane liner (EVOH) is in place in the South Quarry that acts to prevent atmospheric intrusion into the waste mass (FEI, 2018). Site personnel perform measurements of gas temperature at each GEW wellhead. These temperature data are tabulated and temperature excursions are investigated by Bridgeton Landfill. Gas composition anomalies in carbon monoxide concentration or oxygen content are also investigated. 2.1.3 Evaluation Responses The following criteria will be used as preliminary indicators that subsurface conditions in a given South Quarry area (section) may have improved to the point where a TMP installation in that section will be undertaken to verify such conditions:

The rate of settlement/subsidence of the South Quarry topographic surface does not exceed 0.5% of the waste column height per year at the proposed TMP location; and

Wellhead gas temperatures nearest the proposed TMP location continue to exhibit stability (90 continuous days of less than 180° F).

The rate and magnitude of landfill settlement varies with many factors, including the time that has elapsed since filling and closure, the final thickness of the waste and its composition, leachate levels in the waste, etc. Waste materials typically exhibit heterogeneous engineering properties that vary widely throughout a landfill and change over time (Mehta, et al, 2002). Studies have suggested


that landfill settlement rates in older landfills may be as low as 1.2 feet per year (Rae Lee, et al, 1999), which for a waste thickness of approximately 200 feet would roughly equate to the 0.5% per year value noted in the first criterion. The decision to proceed with a final TMP design and installation in a given section will be based on satisfying both of the stated criteria. 2.2 Temperature Monitoring Probe (TMP) Installations Following the determination that subsurface conditions within a given South Quarry section will allow for the safe and efficient installation and operation of a TMP in that section, such installation activities will be initiated in accordance with this Plan. MDNR will be notified of the work to be undertaken and more detailed documentation associated with the planned TMP will be submitted. Documentation regarding design and construction/equipment specifications would be provided to the agency in the form of a follow-up South Quarry TMP Work Plan submitted within 60 days of verifying that the Section 2.1.3 criteria have been met. Coordination and scheduling of the type of drilling rig to be used, and coordination of support services (support labor, equipment operators, subcontractors, etc.) would take place during the lead time for ordered materials/supplies. Drilling pad construction activities would be performed once TMP materials/supplies had been ordered. An engineering consultant would observe and document South Quarry TMP installation activities and would perform visual screenings for the presence of asbestos-containing materials (ACM) during drilling (if waste were extracted from the borehole by the chosen drilling technology). An example of an Asbestos Inspector certification issued by MDNR is included in Appendix A. The engineering consultant’s documentation of the work would include reviews of material specifications, completion of field summary reports and photographic records, and development of a final report including an as-built drawing of each constructed TMP. A TMP is comprised of a series of thermocouples spaced vertically along a length of rigid support material (i.e. fiberglass rod) and inserted into a borehole. The strand of thermocouples may be encased in a thermally protective covering. Once the strand of thermocouples is lowered into the borehole, the borehole annular space is backfilled with an approved grout that encases the strand, providing both the structural support needed within the waste column and the conductive properties needed for representative temperature monitoring. Wire leads from each thermocouple are routed up the strand to monitoring circuitry mounted aboveground. Figure 2 is a general schematic of the construction of a TMP based on previous installations at Bridgeton Landfill. Changes to the basic TMP design shown may include multiple empty conduits installed in a single borehole to allow for strand/thermocouple replacement without re-drilling and/or the use of remote telemetry circuitry for data collection. For the South Quarry, TMPs may require the use of subsurface materials that are more tolerable of a high-temperature environment and chemically more durable. TMP installations in the context of this Plan would be implemented as a program designed to confirm indications from the subsurface assessment activities (Section 2.1) that the conditions at specific locations in the South Quarry had improved such that the installation/operation of a new


LCS could be performed safely. TMP data would provide verification that conditions at the location for a proposed LCS would be similar to those encountered during installation of LCS-5B in the North Quarry (FEI, 2017b). 2.2.1 Additional Health & Safety Considerations MDNR and the St. Louis County Department of Health will be notified of pending TMP drilling activities, as will the City of St. Louis and Lambert International Airport in accordance with Bridgeton Landfill’s Bird Hazard Monitoring and Mitigation Plan (CEC, 2014). MDNR and the St. Louis County Department of Health require that a state-certified asbestos inspector observe the work and examine any waste exhumed for the presence of ACM. If ACM was exhumed during drilling or other TMP construction activities, the following protocols would be implemented at the direction of the licensed inspector:

Identify and mark-off an exclusion zone consisting of a 25-ft x 25-ft area centered around the borehole.

If work was to continue, all workers within the exclusion zone would wear protective clothing and don half-face respirators with HEPA filters if trained, fit-tested, and authorized to do so in accordance with their employer’s Respiratory Protection Program. Those not so authorized would leave the exclusion zone immediately.

If drilling activities were to continue, a ½-inch stream of water would be added to the borehole continuously during the drilling process.

Plastic sheeting would be placed on the ground near the borehole and debris (if any) exhumed from the hole would be placed on it. An 18-in high berm would be erected on three sides of the plastic sheeting. Debris placed on the plastic would be dampened and maintained wet, and relocated into a durable container and covered prior to the end of the day’s work.

All used PPE and debris would be disposed of in accordance with site procedures. All equipment coming into contact with ACM would be pressure washed at a designated area before leaving the site.

In addition to the 4-gas monitoring described in Section 1.2, intrusive activities would also require at least one instrument in the work area to be used to monitor for volatile organic compounds (VOCs) pursuant to Bridgeton Landfill’s HASP. VOC concentrations exceeding the limits specified in the HASP will result in work area reassessment procedures. 2.2.2 TMP Location Determinations Once conditions have indicated their feasibility, Bridgeton Landfill proposes to install four (4) TMPs in the South Quarry, with depths to be proposed in the subsequent Final TMP Work Plan. The proposed locations of the TMPs will be determined after review of the data provided by monitoring of changes (settlement) in the South Quarry topographic surface and headspace temperatures in existing South Quarry landfill gas extraction wells that indicate improved subsurface conditions. The four new TMPs may be installed at different times depending on when


the evaluation data (Section 2.1.3) support TMP installation in a given section. The four TMPs will be located within the boundaries of the four South Quarry sections (I, II, III, and IV) identified on Figure 1. 2.2.3 TMP Drilling/Installation Equipment and Construction Materials The design of the new TMPs will be based on using thermocouples with Teflon© coated wire leads as sensors for measuring temperature. The principle behind thermocouple temperature measurement relies on passage of an electrical current between connections of wires made of dissimilar metal. A measurable voltage is produced when a change in temperature occurs at a connection, and the voltage is converted to a temperature measurement. Thermocouples can provide temperature measurements over a wide range of temperatures. Thermocouples are available in different combinations of metals and calibrations/configurations. The thermocouples to be used for the South Quarry TMPs should support a temperature range of between -350° F and 675° F. The chosen units should have reported standard limits of error of 0.75%. Previous Bridgeton Landfill TMPs were installed within 4-inch diameter boreholes advanced with a rotosonic drill rig. Sonic drilling offers the benefits of producing only negligible amounts of drill cuttings and efficient penetration of subsurface materials due to vibration of the drill string. Vibration is provided by an oscillator that directs high-frequency resonant energy down the drill string and, combined with rotational movement, reduces friction and torsional forces on the tooling. The driller fine tunes the vibration to optimize downward drilling pressures. Vibration also allows for less effort to remove the drill string from the subsurface and hinders development of annular backfill bridging when using the equipment to install casings. Pressurized water is typically circulated within the sonic drill string to reduce operational temperatures and to prevent drilled materials from entering the drill string as it advances downward. Utilizing a chilled water/glycol solution may be included in the design of a South Quarry TMP installation regardless of the drilling technology ultimately selected. The final design of the South Quarry TMPs will include procedures for collecting temperature readings from the thermocouples beginning approximately one week after installation to ensure that the TMP has equilibrated and that readings are representative of waste temperatures. The final designed depths of the new South Quarry TMPs will be proposed in the follow-up TMP Work Plan to be submitted to MDNR as described in this Plan. It is anticipated that thermocouple vertical spacing along a new TMP strand will not exceed 20 feet. 2.2.4 Occupational Monitoring and Odor Management Occupational monitoring during work associated with the proposed TMP installation and monitoring activities in the South Quarry will include the use of a 4-gas meter to monitor each work area for concentrations of oxygen, methane, carbon monoxide, and hydrogen sulfide, and a photoionization detector to monitor for VOCs.


Odor management represents an integral part of operations at the Bridgeton Landfill and is implemented daily in an on-going effort to identify and resolve potential odor issues that may arise. Odor management during TMP installation work will consist of temporary measures employed during any work activity that may have the potential to generate odors. Odor management actions employed during South Quarry TMP installations would be performed in accordance with the facility’s Odor Management Plan (Bridgeton Landfill, 2014). Given the minor amount of wastes expected to be generated during the South Quarry TMP installation activities, efforts needed to comply with bird/vector mitigation requirements are anticipated to be limited to the use of tarps over waste containers. Bird mitigation requirements and the expected levels of effort needed by Bridgeton Landfill to comply with them would be coordinated with Lambert International Airport. 2.2.5 Waste Handling and Decontamination Wastes generated during TMP installation activities are expected to be limited to minor amounts of disturbed landfilled material extracted from the borehole and excess grout not used as backfill around the thermocouple strand. This material, if generated during the TMP installation activities, will be collected in small waste bins or other containers provided by Bridgeton Landfill and then disposed at the facility’s direction. Containers will be covered when waste is not being placed into or removed from them. Management of potential odor emissions will be in accordance with the site’s Odor Management Plan. Following TMP installation activities and prior to the drilling contractor’s rig leaving Bridgeton Landfill, all downhole equipment will be cleaned using a power washer to remove any accumulations of mud and grit prior to being stowed for demobilization from the facility. Drill pipe and other supplies will be secured after cleaning. Rinsate from the decontamination activities will be disposed in the on-site leachate pre-treatment plant. 2.2.6 Construction Quality Assurance Construction Quality Assurance for the TMP installations will include engineering consultant inspection of the construction materials used (including flow testing of grout before use) and observation of general equipment operations, TMP construction procedures, waste handling efforts, and adherence to general and project-specific health and safety protocols. Field monitoring will include photographic documentation, maintenance of a field log, general health and safety monitoring, and documentation of any problems, delays, and remedies associated with the project. It is expected that the engineering consultant will supply 4-gas meters to drilling personnel and will provide continuous air monitoring of the work area during drilling and TMP installation activities, including monitoring for concentrations of VOCs. TMP construction materials will include a strand support structure, thermocouples and wire leads, thermally-protective sheathing (i.e. Pyrojacket®), approved grout, and miscellaneous fittings used below ground, and various electrical supplies for controls mounted aboveground. Inspection and interim operability testing of these materials will be performed as required to ensure that they are


acceptable and consistent with the final design. All materials/supplies will be new and furnished in manufacturers’ packaging where applicable. Operations of the drilling and support equipment (drilling rig, loaders, water truck, work vehicles, etc.) will be performed by qualified operators in a safe and efficient manner and in accordance with the final design plans and standard industry practices. TMP drilling activities will be performed by a properly-licensed drilling contractor with support services provided by laborers familiar with operations at the Bridgeton Landfill, facility staff, and an engineering consultant holding an applicable well installer permit (restricted, non-restricted, etc.) issued by MDNR-Missouri Geological Survey. Electrician services will be provided by an electrical contractor holding a valid Missouri license (if required). Support services are expected to include general labor during drilling and thermocouple strand installations, grout mixing and installation, and material and waste handling. 2.2.7 TMP Monitoring, Maintenance, Replacement, and Reporting Temperature readings from each of the TMPs installed in the South Quarry for this project will be collected on a monthly basis. A handheld multimeter will be used to manually obtain the temperature (°F) and resistance reading (Ω) of each thermocouple. The following data will be recorded during the reading:

Date, TMP designation, Depth of thermocouple (feet bgs), Temperature reading (°F), Resistance reading (ohms), and Comments (if any).

The readings will be recorded manually then entered into a database. Validation and quality control checks of the readings will be conducted to determine if the readings were recorded and entered correctly. The readings will be plotted on temperature vs. depth charts for each TMP. Bridgeton Landfill may elect to employ automated data collectors to reduce the manual labor required to obtain the readings. Any data collector will be compatible with the temperature sensors installed. Each South Quarry TMP will consist of a strand of thermocouples installed in a single borehole at that location. Each thermocouple will operate independently along the strand, each providing the temperature and resistance values at its installed depth. To qualify the temperature reading, the resistance (in ohms) will be compared to a baseline value based on the thermocouple’s depth and wire lead length. If a temperature reading appears anomalous, it will be rechecked and the associated resistance will be recorded. If the recorded resistance value is outside of its calculated limits, the individual thermocouple on that strand will be deemed to be compromised and the temperature reading will not be used in that month’s data set (or subsequent data sets). To further evaluate the physical condition of the thermocouple in question, conductivity testing will be performed to evaluate if physical conditions may be affecting the unit’s resistivity. The thermocouple wire to be used will be resistance-rated to 29.8 ohms per 100 feet of length. Quality


assurance / quality control (QA/QC) procedures will include regular testing of the thermocouples (as well as testing them prior to and immediately following their installation) using the aforementioned 29.8 ohms per 100-foot criterion. Before each strand is installed, each thermocouple along the strand will be tested for resistance, and deemed acceptable if the measured resistance is within +/- 20% of the estimated resistance based on the 29.8 ohms per 100-foot criterion. The South Quarry TMP thermocouples will be monitored for changes in resistance, which is an indicator that a given thermocouple may be failing. Connections and switches may corrode, which would increase resistance. During the monthly readings, any noticeable corrosion will be noted on a field form so that Bridgeton Landfill personnel may perform maintenance of the South Quarry TMPs (cleaning the connections, applying corrosion inhibitors, etc.). TMP maintenance will also include the collection of readings directly from the thermocouple wire leads when applicable, bypassing any indications of corroded connections, i.e. a resistance reading appears to be outside its normal range (+ 20% than the rated ohms/ft). TMPs installed in waste have a discrete life expectancy. When some thermocouples in a strand fail, the TMP can still be used if a general trend in the TMP can be inferred, as compared to historical records of that specific thermocouple depth. Trends for a failed thermocouple will assume that subsurface temperatures at the failed depth are generally increasing or decreasing at similar rates as those detected by the thermocouples located immediately above or below it. If it appears, upon review of plotted data, that the shape of the plotted curve suggest that a failed thermocouple depth was approaching an exceedance temperature, then monitoring of the failed thermocouple depth would be achieved by installing an adjacent (within 10 feet laterally) TMP designed to monitor just the failed depth with a single thermocouple installed at that depth. For example, if a failed thermocouple occurred at a depth of 40 feet and the temperature at that depth was inferred to be approaching an exceedance, but the thermocouples in the strand were operational above and below that interval, then a 40-foot-deep TMP with a single thermocouple could be installed next to it. Conversely, if two consecutive (or three or more total) thermocouples were to fail within one of the new South Quarry TMPs, then the entire TMP would be replaced in order to re-establish monitoring of the affected depths at that location. TMP replacement activities would be performed as soon as practicable after verification of thermocouple failure. Supplies for three TMPs are stored at the Bridgeton Landfill such that the only scheduling limitations for installation of the TMPs would be driller/rig availability and expected weather. Following quality control review, the monthly TMP readings and temperature vs. depth plotted data will be submitted to MDNR on a one-month offset basis (i.e., each month’s submittal will represent the previous month’s information). Each submittal, to be developed using only information obtained from new South Quarry TMPs (and any replacement South Quarry TMPs installed subsequently), will summarize the data, describe TMP operation and maintenance activities, and discuss any non-conforming TMP depths. The submittal format will consist of:

A cover letter summarizing the contents of the submittal and describing any unusual conditions or occurrences;

Data summaries; Notes on equipment maintenance and performance; and


Planned activities for the coming month. As-built drawings of any TMPs installed in the South Quarry in accordance with this Plan will be provided to MDNR within 30 days following completion of the work. 2.3 Criteria for Action in Response to Subsurface Assessment The following criteria will be used to indicate stable subsurface conditions in a given South Quarry section that will allow for LCS installation activities to be initiated in that section under verified, improved conditions:

The rate of settlement/subsidence of the South Quarry topographic surface does not exceed 0.5% of the waste column height per year at the proposed LCS location;

Wellhead gas temperatures nearest the proposed LCS location continue to exhibit stability (90 continuous days of less than 180° F); and

TMP readings indicate stabilized subsurface waste temperatures at the proposed LCS location of less than 185° F for 90 continuous days.

Additional criteria may be reviewed as part of the final design of the LCSs to be installed in the South Quarry, i.e. carbon monoxide concentrations in landfill gas, leachate chemistry, etc., but the decision to proceed with the LCS design and installation in a given section will be based on satisfying all three of the stated criteria. 3.0 RESPONSE ACTION – SOUTH QUARRY LCS INSTALLATIONS Following the determination that subsurface conditions within a given South Quarry section will allow for the safe and efficient installation and operation of a durable LCS in that section, such design and installation activities will be initiated in accordance with this Plan. MDNR will be notified of the work to be undertaken and more detailed documentation associated with the planned LCS will be submitted. Certain details regarding LCS design, installation, and equipment are not known at this time given continuous advancements being made by drilling companies and material vendors in addressing elevated temperature landfills. For this Plan, Bridgeton Landfill has assumed that LCS drilling and installation methods would be consistent with those used previously at the site. Documentation regarding final design and construction/equipment specifications would be provided to the agency in the form of a follow-up South Quarry LCS Work Plan submitted within 60 days of verifying that the Section 2.3 criteria have been met. Coordination and scheduling of the type of drilling rig to be used, and coordination of support services (support labor, equipment operators, subcontractors, etc.) would take place during the lead time for ordered materials/supplies. Drilling pad construction or modification activities would be performed once LCS materials/supplies had been ordered. In similar fashion to procedures associated with TMP installation, an engineering consultant would observe and document South Quarry LCS installation activities and would perform visual screenings for the presence of ACM during drilling if waste were extracted from the borehole by


the chosen drilling technology. The engineering consultant’s documentation of the work would include reviews of material specifications, completion of field summary reports and photographic records, and development of a final report including an as-built drawing of each constructed LCS. 3.1 Leachate Collection Sump (LCS) Design and Location Determinations The South Quarry is currently divided into three operational “quadrants” as described in the site’s Operation, Maintenance, and Monitoring Plan (CEC, 2018). Each of these “quadrants” contains infrastructure designed to collect and route landfill gas and leachate generated by the South Quarry waste mass. Infrastructure consists of landfill gas extraction wells connected to HDPE laterals, headers, and condensate sumps/traps, and leachate collection sumps and forcemains. Landfill gas is routed to one or more candlestick flares for combustion and leachate/condensate is routed to the leachate pre-treatment plant located on the landfill property. Note that the South Quarry “quadrants” described in the Operation, Maintenance, and Monitoring Plan have been so designated to facilitate distribution of pump maintenance/infrastructure work load for site employees. The “quadrants” are unrelated to the South Quarry areal sections (I, II, III, and IV shown on Figure 1) that are and will be referenced in this Plan and subsequent South Quarry TMP/LCS Work Plans to be submitted to MDNR. The existing LCSs in the South Quarry are constructed of HDPE and are equipped with pumps. This Plan provides a general outline of the steps to be taken by Bridgeton Landfill to install new LCSs as required to comply with Operating Permit Condition 6D. Final design of the new LCSs will incorporate aspects of the existing and original LCSs to the extent feasible; however, the actual conditions that exist at the time of installation and the functional performance requirements of each LCS will govern final design and installation details. MDNR and the St. Louis County Department of Health would be notified of pending LCS installation activities, as would the City of St. Louis and Lambert International Airport in accordance with Bridgeton Landfill’s Bird Hazard Monitoring and Mitigation Plan. As with TMP installations, MDNR and the St. Louis County Department of Health require that a state-certified asbestos inspector observe the work and examine any waste exhumed for the presence of ACM. If ACM was exhumed during LCS installation activities, the protocols described in Section 2.2.2 would be implemented. LCS installation activities would also require monitoring for VOCs as described in the aforementioned section. New LCSs may be installed in the South Quarry at different times depending on when the evaluation data (Section 2.3) support LCS installation in a given area. 3.2 LCS Drilling/Installation Equipment and Construction Materials Drilling for the new South Quarry LCSs will require significant support. Support equipment and services for LCS installation activities will likely include loaders, haul trailers, a water truck, a crane, support vehicles, and odor control equipment to address potential odor emissions from the borehole. Odor control measures will be implemented during LCS drilling activities in accordance with Bridgeton Landfill’s Odor Management Plan and will include the use of a vacuum box positioned over the borehole during bucket drilling work and the use of atomized mist equipment


and granular odor control product during all subsurface activities. Bird monitoring control efforts will be performed during LCS installation activities in accordance with the facility’s Bird Hazard Monitoring and Mitigation Plan. Borehole drilling will be performed by properly-licensed drilling contractors and overseen by an engineering consultant responsible for logging the borehole and collecting temperature readings of the waste in accordance with Bridgeton Landfill procedures. Accumulations of material extracted from the borehole, if any, will be placed into lined haul trailers for disposal. In accordance with the facility’s Odor Management Plan, waste placed in haul trailers will be covered. Loaders will be used to handle waste. Free liquids that accumulate in the haul trailers, if any, will be solidified using absorbent media. Surface casing may be required in an LCS borehole to serve as temporary borehole support in the uppermost horizons of South Quarry waste. If utilized, surface casing is proposed to consist of a single section of carbon steel pipe. Figure 3 is a general schematic of the construction of an LCS based on previous installations at Bridgeton Landfill. For the South Quarry, LCSs may require the use of subsurface materials that are more tolerable of a high-temperature environment and chemically more durable. The final designed depths of the South Quarry LCSs will be determined upon review of available information regarding leachate levels and analytical data, settlement rates, quarry elevations, waste geometry, etc. at a given LCS location. As-built drawings of any LCSs installed in the South Quarry in accordance with this Plan (and any detailed Work Plan(s) submitted subsequently) will be provided to MDNR within 30 days following completion of the work. 3.2.1 Well Development and Waste Handling The drilling contractor will perform well development activities following installation of an LCS. Well development has two primary objectives, with the common goal of maximizing liquid flow into a well. First, to address any damage to the formation in the vicinity of the borehole caused by the physical process of drilling, fluids introduced during drilling should be flushed out of the borehole and any mud cake that may have formed on the borehole wall should be removed. Second, to enhance well permeability and stability, sediment and fine material from the borehole that may cause reduced liquid flow should be evacuated from the well casing. The drilling contractor will develop the LCS by positioning the rig or well development equipment over the well casing then installing sections of drill pipe (of smaller diameter than the well casing) to the bottom of the well casing. Clean water will then be pumped through the drill string to the bottom of the well casing to flush drilling fluids and fine material out of the sump. Over the course of well development activities, the drill string will be gradually retracted from the well casing as the process of flushing and recirculating water through the screened interval continues. An engineering consultant will document the well development activities performed by the drilling contractor (including captioned photographs). Wastes generated during the drilling, installation, and development of an LCS are expected to consist primarily of materials removed during surface casing installation, unused drilling fluids,


and screened waste. Waste will be collected into appropriately sized waste containers and haul trailers. Absorbent material will be incorporated into the collected waste as needed. 3.2.2 Equipment Decontamination Following well development activities at a given LCS work site, equipment will be cleaned using a power washer to remove any accumulations of mud and grit prior to being stowed for demobilization from the facility. Drill pipe and other materials will be secured after cleaning. Rinsate from the decontamination activities will be disposed in the on-site leachate pre-treatment plant. 3.3 Occupational Monitoring and Odor Management Occupational monitoring during work associated with the proposed LCS installation activities in the South Quarry will include the use of a 4-gas meter to monitor each work area for concentrations of oxygen, methane, carbon monoxide, and hydrogen sulfide, and a photoionization detector to monitor for VOCs. As described in Section 2.2.4, odor management represents an integral part of operations at the Bridgeton Landfill. Odor management during LCS installation work will consist of temporary measures employed during any work activity that may have the potential to generate odors. Odor management actions employed during South Quarry LCS installations will be performed in accordance with the facility’s Odor Management Plan. Also, bird monitoring and control efforts during LCS work, expected to potentially be more significant than those required for TMP installations, will be performed in accordance with the facility’s Bird Hazard Monitoring and Mitigation Plan and in coordination with Lambert International Airport. 3.4 Construction Quality Assurance Construction Quality Assurance for the LCS installations will include engineering consultant inspection of the construction materials used and observation of general equipment operations, LCS construction procedures, waste handling efforts, and adherence to general and project-specific health and safety protocols. Field monitoring will include photographic documentation, maintenance of a field log, general health and safety monitoring, and documentation of any problems, delays, and remedies associated with the project. It is expected that the engineering consultant will supply 4-gas meters to drilling personnel and will provide continuous air monitoring of the work area during drilling and LCS installation activities, including monitoring for concentrations of VOCs. LCS construction materials will include well casing (riser/screen sections and caps), carbon steel surface casing, and various backfill materials. All well casing sections will be new, straight, and in conformance with specified inner diameters throughout their linear dimension, and will be furnished in lengths as specified in the final design plan. All pipe thread connections will be made with full seating achieved. All other materials/supplies will be new and furnished in manufacturers’ packaging where applicable.


Operations of the drilling and support equipment (drilling rigs, loaders, water truck, crane, support vehicles, etc.) will be performed by qualified operators in a safe and efficient manner and in accordance with the final design plans and standard industry practices. LCS drilling activities will be performed by properly-licensed drilling contractors with support services provided by laborers familiar with operations at the Bridgeton Landfill, facility staff, and an engineering consultant holding an applicable well installer permit (restricted, non-restricted, etc.) issued by MDNR-Missouri Geological Survey. Support services are expected to include general labor during drilling and sump installations, backfilling, crane activities, and material and waste handling. 3.5 LCS Liquid Handling Equipment Installation Following LCS installation and development, a pump equipped with the appropriate level transducers, controls, and check valves will be installed. At the time of this Plan, there is considerable uncertainty as to the expected leachate pumping volume, total dynamic head, and types of pumps that may be required in a South Quarry LCS, and whether such pumps are commercially available. Once subsurface conditions are favorable for LCS installation (per the Decision Tree), a pumping / liquid handling system will be selected for incorporation into the LCS design. Pump tests of the new LCS may be required for the design of the liquid handling system. All new LCSs installed in accordance with this and subsequent Plans will be connected to the leachate forcemain network. The existing network of lift stations and pumping facilities will be reviewed to ensure that the increased volumes and chemistry of the leachate to be collected by the new South Quarry LCSs will not tax the design capacities of the structures or the leachate pre-treatment plant - modifications of some conveyance structures are anticipated. 4.0 PROJECT REVIEW & REPORTING Review of the response actions described in this Plan will consist of quality control checks of documentation produced during South Quarry settlement monitoring and landfill gas data collection, and utilization of standard construction quality assurance practices during TMP and LCS installation, monitoring, and operation. Documentation produced during the project will be accurate and fully representative of the tasks performed. It is the goal of this Plan that documentation be standardized and in compatible formats (using Microsoft Office® or similar information management software) to facilitate use by regulatory staff and company management in evaluating program efficacy. All documentation produced during the project will become part of the Bridgeton Landfill Site Operating Record. In accordance with the Final Consent Judgment, correspondence, status updates, reports, and other documents associated with the work described in this Plan will be submitted to the MDNR-Solid Waste Management Program and the office of the MDNR General Counsel in electronic format. Submittals currently include (or are expected to include) this Plan and the following:


Reporting/submittal of raw data and analytical charts for all TMPs and LCSs and lists of associated work completed and work planned. Reports will be submitted as required by the Bridgeton Landfill Operation, Maintenance, and Monitoring Plan.

Reporting/submittal of gas composition data for South Quarry wells that exhibit liquid-free gas flow and that are safe for gas sampling and temperature analysis / monitoring. Reports will be submitted quarterly or as required by the Bridgeton Landfill Operation, Maintenance, and Monitoring Plan.

Final TMP and LCS Work Plans that provide detailed design and construction specifications and schedules of activities associated with the proposed new South Quarry infrastructure component. The final plans will be submitted within 60 days of verifying that the associated criteria for final design/installation have been met.

Final construction quality assurance reports describing drilling and TMP / LCS installation activities. Final reports will include narrative sections describing the equipment and procedures employed to construct, install, and operate the TMP or LCS, as-built diagrams depicting the dimensional layout of the structure installed and any ancillary equipment associated with it (pumps, hoses/fittings, filters, electrical components, etc.), and notes regarding start-up/initial operation and monitoring of the TMP/LCS and any unusual conditions encountered. The as-built diagrams will be certified/sealed by a Missouri professional engineer. Final reports will be submitted within 30 days following completion of the work.

Annual reports that provide brief summaries of South Quarry settlement data, South Quarry gas and TMP temperature data, and South Quarry TMP/LCS operational information. It is proposed that these annual reports be submitted at the end of each calendar year, independently of other reporting associated with Bridgeton Landfill. The annual reports will also provide brief descriptions of any developing technologies that may be applicable to planned activities in the South Quarry, i.e. drilling technologies for high-temperature environments, remote sensing technologies for topographic surveys (LIDAR), pumping designs for adverse environments, etc.

5.0 RESPONSE ACTION TIMELINE & COMPLIANCE SCHEDULE Following MDNR approval of this Plan, results of gas composition sampling and analysis from operating wells in the South Quarry will be made on an approved schedule. Reporting of the results of the ongoing programs of site-wide gas well temperature monitoring and the status of existing TMP and LCS operations will continue. Gas temperature and settlement data that indicate improved subsurface conditions in a given South Quarry section will undergo vigorous verification processes to determine the validity of the data before final TMP design work. More frequent confirmation checks of the data will be performed during a 90-day verification phase. MDNR will be notified of the implementation of the pre-TMP settlement/gas temperature verification work. If the data are deemed valid, steps outlined in the Decision Tree / Action Plan illustrated in Figure 4 associated with initiation of TMP final design/installation actions will be followed. South Quarry settlement and gas temperature monitoring will continue throughout the South Quarry in accordance with the site’s Operation,


Maintenance, and Monitoring Plan. If the section data cannot be verified/validated, MDNR will be notified after the 90-day review period and monitoring in that section will return to the approved schedules. Following the verification of settlement/gas temperature data and the installation of a TMP in a South Quarry section, gas temperature and settlement monitoring will continue for the entire South Quarry and monitoring of the newly installed TMP temperatures will begin. TMP temperature readings that indicate/confirm that subsurface conditions in a given section are suitable for LCS final design and installation will also undergo verification. More frequent confirmation checks of the TMP data will be performed during a 90-day verification phase. MDNR will be notified of the implementation of the pre-LCS verification work. If the TMP data are deemed valid, and routine gas temperature and settlement data in the section continue to indicate suitable subsurface conditions, steps outlined in Figure 4 associated with initiation of LCS final design/installation actions will be followed. South Quarry settlement and gas temperature monitoring will continue throughout the South Quarry in accordance with the site’s Operation, Maintenance, and Monitoring Plan. If the TMP data under review cannot be verified/validated, MDNR will be notified after the 90-day review period and TMP monitoring in that section will return to its approved schedule. TMP and LCS installation activities in a given South Quarry section would be expected to last several weeks. Components needed for construction (thermocouples, casing, pumps, etc.) would likely require extended lead times from the manufacturers, during which time contracted services would be coordinated and access to drilling locations (infrastructure relocations, drilling pad construction, etc.) would be made. Schedules of activities associated with drilling, installation, calibration/normalization, and start-up of new South Quarry TMPs and LCSs would be included in the final Work Plans submitted for the new infrastructure components. As noted in Section 4.0, final construction quality assurance reports describing TMP/LCS installations would be submitted to MDNR within 30 days following completion of the work. 6.0 PROJECT TEAM In addition to Bridgeton Landfill professional staff, management staff, and field technicians, the project team will consist of a number of contractors, consultants, and support service companies. In some cases, previous work experience at Bridgeton Landfill would be advantageous as those firms/employees may provide valuable insight into working safely and efficiently under sometimes adverse site-specific conditions at the landfill and specifically in the South Quarry. For other tasks, previous experience at the facility is less important. Regardless of the level of experience, it is imperative that all personnel involved in the tasks described in this Plan be well qualified and perform their work in a safe and professional manner. It is anticipated that a qualified engineering consulting firm will serve as Project Coordinator for the South Quarry subsurface assessment actions and TMP/LCS installations. The Project Coordinator will provide overall coordination of the work, including preparation of project plans, coordination of contractors, and interaction with MDNR. The Project Coordinator firm will also be responsible for the preparation of progress reports and coordination of the development of all final reports.


Office and field engineering services will be provided by a Project Engineer and Field Engineer from a qualified engineering firm. Office and field engineering services will include the preparation of design and record drawings, supervision and documentation of field activities, and collection/review of verification data. The Project and Field Engineers may also perform post-project data and field audits in order to identify any problematic areas associated with operation and maintenance of the TMPs and/or LCSs installed in accordance with this Plan. The Project / Field Engineer firm will also provide the MDNR-certified Asbestos Inspector and personnel who have been issued the appropriate well installer permit by MDNR-Missouri Geological Survey. Subcontracted workers will include electricians, land surveyors, analytical laboratories, service technicians, drilling companies, and construction contractors. Electricians will possess valid Missouri licenses if so required at the time of the work. Professional land surveyors will provide regular surveys of the South Quarry topographic surface and survey control prior to and following TMP and LCS installations. Surveys will be performed under the supervision of either a Missouri-licensed land surveyor or a Missouri professional engineer. Analytical laboratories holding valid Missouri accreditation will provide analytical testing services as needed. Service technicians and construction contractor employees will be utilized as support personnel during TMP and LCS installation activities. Drillers possessing the appropriate licensing for the work will provide TMP/LCS drilling and casing or other subsurface installation services, as well as LCS development services, as described in this and subsequent Work Plan(s).


7.0 REFERENCES Bridgeton Landfill, 2014. Odor Management Plan – Bridgeton Landfill, 13570 St. Charles Rock

Road, Bridgeton, Missouri. June 20, 2014. CEC, 2014. Bridgeton Landfill, LLC – Bird Hazard Monitoring and Mitigation Plan for Ongoing

Landfill Work. Prepared for Bridgeton Landfill, LLC by Civil & Environmental Consultants, Inc. June 24, 2014.

CEC, 2018. Bridgeton Landfill, LLC – Operation, Maintenance, and Monitoring Plan, Volumes

1, 2, & 3. Prepared for Bridgeton Landfill, LLC by Civil & Environmental Consultants, Inc. March 2018.

FEI, 2016. Health & Safety Plan, North Quarry and Neck Area Removal Actions – Bridgeton

Landfill, LLC / West Lake Landfill Superfund Site, Bridgeton, Missouri. Prepared for Bridgeton Landfill, LLC by Feezor Engineering, Inc. July 24, 2016.

FEI, 2017a. Construction Quality Assurance / As-Built Report – Leachate Collection Sump LCS-

5B, Bridgeton Landfill, LLC, Bridgeton, Missouri. Prepared for Bridgeton Landfill, LLC by Feezor Engineering, Inc. July 2017.

FEI, 2017b. North Quarry Subsurface Temperature Monitoring Probes (TMPs) Work Plan –

Administrative Settlement Agreement and Order on Consent for Removal Actions. Prepared for Bridgeton Landfill, LLC by Feezor Engineering, Inc. August 2017.

FEI, 2018. Bridgeton Landfill, LLC Monthly Data Submittals – Required by Section 52.E of

Agreed Order, Case No. 13SL-CC01088 Effective May 13, 2013. Feezor Engineering, Inc. June 2018.

MAGO, 2018. Final Consent Judgement, State of Missouri ex rel Attorney General Joshua D.

Hawley and Missouri Department of Natural Resources v. Republic Services, Inc., Allied Services, LLC, and Bridgeton Landfill, LLC. June 29, 2018.

MDNR, 1985. Solid Waste Disposal Area Operating Permit #118912. November 18, 1985. Mehta, et al, 2002. Refuse Decomposition in the Presence and Absence of Leachate

Recirculation. Journal of Environmental Engineering, ASCE 128, No. 3. Mehta R., M. A. Barlaz, R. Yazdani, D. Augenstein, M. Bryars, and L. Sinderson. March 2002.

Rae Lee, et al, 1999. Estimation of Municipal Solid Waste Landfill Settlement. Journal of

Geotechnical and Geo-Environmental Engineering, ASCE 125, No. 8. Rae Lee Seung, I. Park, Hyun & Babu, G & I. Ling, Hoe & Leshchinsky, Dov & Mohri, Yoshiyuki & Kawabata, Toshinori. 1999.


FIGURES

FEEZOR

FIGURE:

1APPROVED BY: JULY 2018

REVISION DATE

DRAWN BY: WJASouth Quarry Subsurface Assessment Actions & LCS Installations Work Plan

Bridgeton Landfill, LLC13570 St. Charles Rock Road

Bridgeton, Missouri 63044

PROJECT NUMBER: BT-184

Bridgeton Landfill South Quarry Site Plan

N

IV

I

II

North Quarry

Neck Area

South Quarry

LCS-1D

LCS-2D

LCS-3D

LCS-4CLCS-4B

III

BillPolygonal Line

BillPolygonal Line

BillOval

BillSticky NoteAccepted set by Bill

BillOval

BillOval

BillPolygonal Line

BillPolygonal Line

BillRectangle

BillRectangle

BillRectangle

BillRectangle

BillRectangle

BillOval

Temperature Monitoring Probe (TMP) Construction Schematic

FIGURE:

APPROVED BY:

JULY 2018

REVISION DATEPROJECT NUMBER: BT-1842


FEEZOR



Subsurface Components

ground surface

protective casing

thermally protective sheathing

specialized cement-bentonite grout

fiberglass support rod

thermocouple@ 80 ft

last thermocouple in strand

thermocouple@ 60 ft

thermocouple@ 40 ft

thermocouple@ 20 ft

Aboveground Components

(installed in 4-inch diameter borehole)

concrete base

unistrut withcross bracing fiberglass

enclosure

stainless steelconduit & fittings

conduit seal

thermocoupleselector switch box

(not to scale)

BillPolygonal Line

BillPolygonal Line

BillPolygonal Line

BillPolygonal Line

BillPolygonal Line

FEEZOR

FIGURE:

3APPROVED BY: JULY 2018

REVISION DATE




PROJECT NUMBER: BT-184

Leachate Collection Sump (LCS) Construction Schematic

(not to scale)

pilot hole

borehole

threaded end cap

refuse

stainless steellouver screen

clean non-carbonate gravel

stainless steelsolid casing riser

silica sand

bentonite chips

clean soil

top of EVOH liner

top of drilling pad

Tee fitting

Continue daily monitoring of temperatures in South Quarry gas wells

Continue monthly elevation surveys of South Quarry topographic surface

Gas well temperatures


APPENDIX


Appendix A

Work Plan - South Quarry Subsurface Assessment Actions & LCS Installations July 2018TOCList of Acronyms1.0 Introduction2.0 Response Actions - SQ Subsurface Assessment3.0 Response Action - SQ LCS Installations4.0 Project Review & Reporting5.0 Response Action Timeline & Compliance Schedule6.0 Project Team7.0 ReferencesFiguresAppendix A

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