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2012-06-29 – PRP Sampling and Analysis Plan for Additional Groundwater Monitoring Activities

Page 1 of 1
. ”\ Final Groundwater Monitoring SAP and Responses to Comments
_
;~-} ~:ul Rosasco
Dan Gravatt, ‘Muenks, Shawn’
06/29/20 12 03: 13 PM
Cc:
“‘Merrigan, Jessie”‘, “‘Neitzel, Charlotte”‘, “‘Warren, Victoria”‘, “‘Whitby, Kathleen”‘, “‘Golian,
Steven”‘, “‘Ward Herst”‘, “Bob Jelinek”, “‘L FITZGERALD”‘
Hide Details
From: “Paul Rosasco” Sort List…

To: Dan Gravatt/R7/USEPA/[email protected], “‘Muenks, Shawn”‘

Cc: “‘Merrigan, Jessie”‘ , “‘Neitzel, Charlotte”‘

, “‘Warren, Victoria”‘ ,

‘”Whitby, Kathleen”‘ , “‘Golian, Steven”‘

, “‘Ward Herst”‘ , “Bob Jelinek”

, “‘L FITZGERALD”‘

2 Attachments
SAP-Additional Groundwater Monitoring REVISED. pdf Responses to comments on Groundwater SAP.pdf
Dan and Shawn,
Enclosed please find a revised Sampling and Analysis Plan (SAP) for the Additional Groundwater Monitoring

activities. The document has been amended to address EPA and MDNR comments received on June 18, 2012. I am
also sending each of you a hard copy of the plan via regular mail.
Also enclosed are responses to the EPA and MDNR comments.
Once we receive your approval of the SAP, we will schedule the additional groundwater monitoring activity.

Please contact me if you have any questions or would like to discuss the additional ground_water’!’onito~ing or any
other aspect of the project.
o7/t.; 11111riifiln1~
Superfund
0/401
file:/ //C:/Users/DGRA VATTIAppData/LocaVTemp/notes6D6848/-web0307 .htm 4/29/2014
ENGINEERING MANAGEMENT SUPPORT INC.

72_20 West Jefferson Ave. Suite 406 Telephone (303) 940-3426 Lakewood, CO 80235 Telecopier (303) 940-3422
June 29, 2012
U.S. Environmental Protection Agency Region 7 SUPR I MOKS 901 N. 51h Street Kansas City, Kansas 66101
ATTENTION: Mr. Dan Gravatt
SUBJECT: Sampling and Analysis Plan -Additional Groundwater Monitoring West Lake Landfill Operable Unit 1, Bridgeton, Missouri Revised June 22, 2012
Dear Dan,
During a May 10, 2012 conference call, the U.S. Environmental Protection Agency (EPA) asked the West Lake Landfill Operable Unit-1 (OU-1) Respondents to perform an additional round ofgroundwater sampling at the West Lake Landfill. Engineering Management Support Inc. (EMSI), on behalf of Cotter Corporation (N.S.L.), Bridgeton Landfill, LLC, Rock Road Industries, Inc., and the United States Department of Energy (the OU-1 Respondents), is providing this letter to serve as the Sampling and Analysis Plan (SAP) for that additional groundwater sampling.
EPA has indicated that additional groundwater monitoring is necessary to verify that current groundwater quality is consistent with that characterized during sampling performed in 1995, 1996, and 1997 as part of the Remedial Investigation and in 2004 as part of the Feasibility Study activities for OU-1. This letter describes the relevant project planning documents, proposed monitoring locations, sample collection procedures, analyte list, laboratory analyses, quality assurance/quality control samples and procedures, investigative-derived waste management, health and safety procedures, data evaluation and management procedures, and tentative schedule for the work.
Relevant Project Documents
Prior project planning documents relevant to the proposed groundwater monitoring activities include the following:
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 2

McLaren Hart, 1994, Sampling and Analysis Plan (including Field Sampling Plan and Quality Assurance Project Plan) included as Appendix A to the EPA.approved RIIFS Work Plan, August, 1994.


EMSI, 1997, Amended Sampling and Analysis Plan, February 1997.


Herst & Associates, 2003, Letter from Ward Herst (Herst & Associates) to Dan Wall EPA re: Proposed Supplemental Groundwater Sampling, West Lake Landfill Operable Unit 2, November 5, 2003,


EMSI, 2004, Letter from Paul V. Rosasco (EMSI) to Dan Wall EPA re:
Additional Groundwater Monitoring, February 2, 2004.

Copies of the relevant Standard Operating Procedures (SOPs) used by Herst & Associates for groundwater monitoring activities are included with this submittal. A Health and Safety Plan addressing the specific tasks associated with the proposed groundwater monitoring activities is being prepared by Herst & Associates for use by the field crews.
Monitoring Locations
EPA requested that all of the available OU-1 and OU-2 monitoring wells be sampled as part of this effort.
EMSI retained Herst & Associates, Inc. (Herst) to ·conduct a site inspection and well inventory to ascertain the current number of wells at the site, conditions affecting access to the wells, the condition of the surface portions (protective casing, locks, etc.) of the wells, and the depth to water, total depth and down hole conditions as best as could be determined during collection of depth to water and total depth measurements. The inspection did not include checking whether a pump or other sampling device could be lowered into the wells. Many of the wells are routinely checked by Herst for water levels as part ofongoing groundwater monitoring associated with post-closure care of the permitted solid waste landfill and thus did not need to be re-inspected as part of this effort.
Review of site documents indicated that approximately 115 wells have previously been present at the West Lake site. Figure 1 displays the locations of the various monitoring wells that historically were present at the West Lake Landfill. Table 1 summarizes the current status of the various monitoring wells at the West Lake Landfill. Sixty-eight wells could be located, accessed and appear to be in a condition that is suitable for sampling. Based on the results ofthe well inspection and review of information obtained during prior sampling activities, it was determined that 35 wells have been abandoned, destroyed, are damaged in a manner that would prevent collection of groundwater samples, or were previously reported as missing. Many (14) of these unavailable wells
Additional Groundwater Sampling West Lake Landfill OU-1
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Page 3
were located on property no longer owned by the landfill and subsequently developed by others. The remaining 21 wells were previously reported to have been abandoned, destroyed or lost. The areas around five of the wells that were previously reported to have been abandoned or destroyed were inspected as part of the development of this SAP; however, these inspections failed to locate these wells or any indication that these wells may still exist. Five of the wells were reported (McLaren Hart, 1994) to have been abandoned in October 1992, prior to performance of the Remedial Investigation/ Feasibility Study for OU-1 and OU-2. The areas around three of these wells were inspected and these inspections confirmed that these wells no longer exist. Eight additional wells were previously reported to have been abandoned or destroyed. The areas around these well locations were not inspected. In conjunction with performance of the groundwater sampling, the areas around these wells, and any other wells that were previously reported to have been abandoned/destroyed that were not previously inspected {Table 2), will be inspected to verify that these wells no longer exist. Three wells that were located (S-75, D-87 and MW-103) were determined to have casings that are damaged or obstructed. These three wells will be re-inspected and to the extent practical will be repaired as part of the groundwater sampling effort. The status of the remaining
12 wells could not be determined because the wells could not be located or their locations could not be accessed due to heavy vegetative growth or fencing that restricted access to offsite properties.
Based on the results of the well inspection, it is anticipated that approximately 80 or more wells (68 wells that were inspected and found to be in a condition potentially suitable for sampling plus the additional 12 wells ofunknown status plus the three wells found to have damaged casings) listed in Table 3 are proposed for additional groundwater sampling. The locations of these wells are shown on Figure 2.
Prior to conducting the groundwater sampling effort, vegetation must be cleared to allow for access to these wells. Vegetation clearing will be conducted using a skid steer with a ‘brush hog” attachment and/or manually using toppers or a chain saw as necessary.
Although this SAP anticipates that up to 83 groundwater monitoring wells may be sampled, it is possible that additional wells may be located. Alternatively, it is likely that some of the wells may not be located or may not be susceptible to sampling because of constrictions in or damage to the monitoring well casing resulting in a lesser number of wells for sampling. If such constrictions or damage are present in the above grade, or shallow, subsurface portions of the casing, an attempt will be made by the field crew to repair such damage so as to allow for collection of groundwater samples. In addition to the 83 wells listed on Table 2 and shown on Figure 2, any additional wells that can be located during the groundwater monitoring activities and that are found to be, or that can be made to be suitable for groundwater sampling will also be sampled. In any case, the field crew will endeavor to locate and sample as many of the site monitoring wells as possible.
Additional Groundwater Sampling West Lake Landfill OU-1
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Sample Collection
Samples will be collected from as many ofthe 83 wells listed in Table 3 that can be accessed and from which samples can be collected. Prior to sample collection, the depth to water and total depth of each well to be sampled will be measured to calculate the volume of standing water iil the well casings (casing volume).
A dedicated Waterra (or equivalent) inertial pump (http://www.waterra.com/index.html) consisting of a Waterra D-25, 2-inch diameter, acetal theimoplastic, standard flow (flow rate up to 1 gallon per minute) foot valve connected to high-density, polyethylene tubing will be installed in each monitoring well that does not already possess a bladder or other type of sampling pump. A Waterra compatible surge block (e.g., Waterra SBD-25), or equivalent, may be added to the foot valve to assist with re-development ofwells that have not been sampled in many years.
The Waterra pump will be used to purge the standing water from the well prior to sample collection. An automatic actuator may be used to produce the oscillating motion required by the Waterra pump. The volume of water removed from each well will be recorded. Purge water will be containerized at each well during well development activities and subsequently transported to and placed into a polyethylene tank(s).
Field parameters including, at a minimum, temperature, pH, and specific conductance, will be monitored using an in-line flow-through chamber during well purging at a minimum of intervals equivalent to one-half of a well casing volume. Well purging will continue until three successive sets of field parameter readings, obtained at intervals equivalent to successive one-half of a well casing volume, indicate stable water quality: specifically three successive temperature readings within 1 degree C, three successive pH readings within 0.2 pH unit, and three successive specific conductance readings within 10% of each other. A sample for laboratory analysis will then be collected regardless of the number of casing volumes removed. In the event that well stabilization cannot be achieved through continued well purging (e.g., field parameters have not stabilized after removal of five casing volumes), a field decision will be made regarding the need for continued well purging versus collection of a sample.
In the case ofmonitoring wells, if any, that are dewatered during well purging, the water level in the subject well will be allowed to recover for 24 hours at which time a sample will be collected. In the event that the water level in a well does not recover sufficiently within 24 hours, the well will continue to be checked periodically during the groundwater sampling activities for the presence of water. If the water level recovers sufficiently to allow for sample collection prior to completion of the groundwater monitoring activities, a sample will be collected from that well. In order to insure that the most important sample fractions are obtained, the order of sample fraction collection will be prioritized as follows: total radio-isotopes sample containers first, dissolved radio-isotopes sample containers second, volatile organic compound (VOC) sample containers third, total trace
Additional Groundwater Sampling West Lake Landfill OU-1
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Page 5
metal sample containers fourth, and dissolved metal sample containers fifth. In the event that a low producing well is selected by EPA and/or MDNR for collection of split samples, the same priority for sample fraction collection will be used with the additional criteria that the radio-isotope sample bottles for the investigative samples to be obtained by Herst & Associates on behalf of EMSI will be filled first followed by the radio-isotope bottles for the split samples to be obtained by EPA or MDNR. Collection of samples for additional analytical fractions (e.g., VOCs) will subsequently be conducted using the same prioritization.
Upon completion of sample collection, the well tubing will be pushed down inside the well and trimmed as necessary to allow for placement of the well cap and securing of the protective casing. If necessary to facilitate subsequent access to the pump tubing, a short length of rope may be secured to the top of the pump tubing with the other end of the rope secured around the inner casing, to the well cap or to the outer casing as determined by the field crew.
Groundwater samples collected for laboratory analysis will placed in the appropriate pre.preserved bottles provided by the analytical laboratories. Samples to be analyzed for dissolved trace metals and radionuclides will be subjected to field filtering prior to placement in the pre-preserved sample bottles.
Chain-of-custody forms will be completed in the field by the sampling crew to document the names of the samplers, the actual samples collected by the sampling crew, the date and time of sample collection, the number and types of sample containers obtained from each well sampled, the type ofpreservation performed on each sample container, and the requested laboratory analyses. Chain-of-custody forms will be completed for each analytical laboratory used for the groundwater monitoring effort.
Laboratory Analyses
The collected samples will be analyzed for uranium (U-238, U-235 and U-234), radium (Ra-226 and Ra-228) and thorium (Th-232, Th-230 and Th-228) isotopes, EPA Target Compund List (TCL) trace metals, TCL volatile organic compounds (VOCs), and TCL semivolatile organic compounds (SVOCs) (please see http://www.epa.gov/superfund/programs/clp/target.htm for a list ofTCL parameters). Radionuclide and trace metal samples will be analyzed for both dissolved (field filtered samples) and total (unfiltered samples) concentrations.
Radio nuclide analyses will be performed by Eberline Laboratory of Oak Ridge, Tennessee. All other analyses will be performed by Test America, either at its Earth City, Missouri laboratory or one of the other Test America laboratories depending upon laboratory capabilities and schedules at the time of sample delivery. Samples to be analyzed by Eberline will be shipped via overnight courier to the Eberline Laboratory in Oak Ridge, Tennessee. Samples to be analyzed by Test America will be delivered
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 6
directly to Test America’s Earth City laboratory for analysis there or shipment via overnight courier to another Test America laboratory, if necessary.
The samples will be analyzed using the following laboratory methods:
Analytes
Thorium isotopes
Uranium isotopes
Radium-226
Radium-228
Trace metals
Volatile organic compounds
Semi-volatile organic compounds
Quality Assurance/Quality Control Analytical Method EML Th-01 EML U-02 EPA 903.0 (Modified to Alpha
Spectroscopy) EPA 904.0 SW-846 6020 SW-846 8260B SW-846 8270C
The following quality assurance/quality control samples will be obtained in the field:

Field duplicate samples -one duplicate sample per every ten investigative samples (duplicate samples will include duplicate sample bottles for all sample analytical fractions);


VQC trip blanks-one sample per every sample container (e.g., cooler) delivered to the laboratory that contains samples for VOC analyses; and


VOC, SVOC and trace metal matrix spike and matrix spike duplicate samples.one of each for every twenty investigative samples.

Additional quality assurance/quality control samples such as method blank samples, laboratory duplicate samples, laboratory control samples, surrogate spike samples, matrix spike and matrix spike duplicate samples will be prepared and analyzed by the analytical laboratories in accordance with the requirements of the analytical methods listed above and the laboratory’s standard operating procedures.
Investigative Derived Materials
Purge water from each monitoring well will be containerized and subsequently transported to and placed into a polyethylene tank(s). Upon completion of the
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 7
groundwater sampling activities, a sample(s) will be obtained from the tank(s) and analyzed for the same analyses as used for the investigative samples plus any additional parameters required by the anticipated disposal facility(ies). It is anticipated that subject to the results of the analyses, the purge water will be collected and disposed by Heritage Environmental Services and/or discharge to the sewer system if approved by the Metropolitan Sewer District (MSD).
Solid waste generated during the sampling activities, including but not limited to well tubing remnants, paper towels, and used gloves will be disposed of at the solid waste transfer facility on site.
Health and Safety
Brush clearing and groundwater sampling activities will be performed by Herst & Associates personnel that have been trained in health and safety procedures for Hazardous Waste Operations and Emergency Response (HAZWOPER). Herst & Associates will prepare a Health and Safety Plan (HSP) that addresses the specific activities to be conducted in conjunction with the groundwater monitoring effort. A copy of the HSP will be provided for information purposes only to all personnel that are present on site in conjunction with the groundwater sampling activities; however, each organization will be responsible for developing and implementing the health and safety procedures necessary for its own personnel. Herst & Associates and EMSI will not be responsible for the health and safety of any personnel other than their own employees.
Data Evaluation and Management
The analytical data will be subject to data validation in accordance with the requirements of the most recent EPA data validation procedure for each analyte group. All of the data will be subject to a Level III data validation plus checks on the laboratory instrument calibration, continuing calibration verification, and internal standards. Based on the results of the data validation effort, additional data qualifiers beyond those applied by the laboratories may be required for the analytical data. A data validation report will be prepared documenting the results of the data validation effort.
The results of the additional groundwater monitoring will be tabulated separately and in conjunction with the results obtained during the RI sampling conducted in 1995, 1996 and 1997 and the FS sampling conducted in 2004. A brief report describing the sampling activities will be prepared and will include the analytical data summary tables described above, the well sampling and purging forms, chain of custody reports, the analytical laboratory reports, and the data validation reports.
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 8
Anticipated Schedule of Activities
One round of groundwater sampling will be performed. Brush clearing activities to provide physical access to the monitoring wells will be scheduled upon receipt of EPA approval of this SAP. Allowing for scheduling and mobilization of vegetation clearing crew, it is anticipated that it will take one to two weeks to complete the brush clearing activities. Groundwater sampling will be initiated within one week of completion of the brush clearing activities. Based on an assumed sample collection rate of five samples per day, it is anticipated that it will take three to four weeks to collect groundwater samples from the approximately 80 wells to be sampled as part of this effort. It is anticipated that it will take approximately three to four weeks for laboratory analyses of the samples. Data validation will take approximately four weeks and data evaluation and report preparation will take another two weeks. Consequently, the total estimated duration of the activities from EPA approval of this SAP until submittal of a sampling report is estimated to be approximately fourteen to seventeen weeks.
If you have any questions or desire additional information related to this SAP or any other aspect of the project, please do not hesitate to contact me.
Sincerely,
ENGINEERING MANAGEMENT SUPPORT, Inc.

ifg::
Paul V. Rosasco, ..
Attachments:

Table 1 -List of Existing and Abandoned Monitoring Wells Table 2 -Reported Abandoned/Destroyed Monitoring Wells to be Inspected Table 3 -List of Monitoring Wells Potentially Available for Sampling
Figure 1 -Current and Prior Groundwater Monitoring Wells Figure 2-Groundwater Monitoring Wells Potentially Suitable for Additional Groundwater Sampling
Herst & Associates Standard Operating Procedures
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 9
Distribution:

Shawn Muenks-Missouri Department of Natural Resources Jessica Merrigan-Lathrop & Gage Kate Whitby-Spencer Fane Britt & Browne Victoria Warren-Republic Services, Inc. Charlotte Neitzel-Bryan Cave HRO Steve Golian -U. S. Department of Energy Ward Herst-Herst & Associates, Inc.
TABLES

Table 1: List of Existing and Abandoned Monitoring Wells by Well Number, West Lake Landfill OU-1 and OU-2
Well Number General Location
S-1 Radiological Area 2
S-5 Radiological Area 1
S-8 Radiological Area 2
S-10 Radiological Area 2
S-51 Closed Leachate Pond
S-52 Closed Leachate Pond
S-53 Closed Leachate Pond
S-54 Inactive Landfill
S-61 Radiological Area 2
S-75 Inactive Landfill
S-76 Inactive Landfill
S-80 Upgradient
S-82 Radiological Area 2
S-84 Radiological Area 1
S-88 Inactive Landfill
1-2 Radiological Area 2
1-4 Radiological Area 1
1-7 Radiological Area 2
1-9 Radiological Area 2
1-11 Radiological Area 2
1-50 Upgradient
1-56 Inactive Landfill
1-58 Inactive Landfill
1-59 Radiological Area 2
1-62 Radiological Area 2
1-65 Radiological Area 2
1-66 Radiological Area 2
1-67 Closed Demolition Landfill
1-68 Radiological Area 1
1-72 Concrete/ Asphalt Plants
1-73 Concrete/ Asphalt Plants
D-3 Radiological Area 1
D-6 Radiological Area 2
D-12 Radiological Area 2
D-13 Radiological Area 2
D-14 Radiological Area 1
D-81 Inactive Landfill
D-83 Radiological Area 2
D-85 Radiological Area 1
D-87 Closed Demolition Landfill
D-89 Inactive Landfill
D-90 Upgradient
D-91 Upgradient
D-92 Closed Demolition Landfill
D-93 Radiological Area 2

Inspected?
No-area overgrown
Yes
No-area overgrown
Yes
No
No
Np
No
Yes
Yes
No
No
Yes
Yes
Yes
No-area overgrown
Yes
No-area overgrown
Yes
Yes
No
Yes
Yes
Yes
No-area overgrown
No-area overgrown
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No-area overgrown
No-area overgrown
Yes
Yes
No
No
No
Yes
Yes
Condition
Unknown
Okay
Unknown
Okay
Destroyed/Abandoned
Destroyed/Abandoned
Destroyed/ Abandoned
Abandoned 10/92
Okay
Casing damaged/obstructed
Abandoned 10/92
Destroyed/ Abandoned
Okay
Okay
Destroyed/Abandoned
Unknown-unable to locate previously
Okay
Unknown
Okay -may be incorrectly labelled
Okay
Destroyed/ Abandoned
Abandoned 10/92
Abandoned 10/92
Abandoned 10/92
Unknown
Unknown
Okay
Okay
Okay
Destroyed/ Abandoned
Okay
Okay
Okay
Okay
Okay
Destroyed/ Abandoned
Unknown
Unknown
Okay
Casing obstructed
Destroyed/Abandoned
Reported as missing in 1994
Reported as missing in 1994
Destroyed/ Abandoned
Okay-may be incorrectly labelled
Page 1 of 3

Table 1: List of Existing and Abandoned Monitoring Wells by Well Number, West Lake Landfill OU-1 and OU-2
Well Number General Location
D-94 Radiological Area 2
LR-100 Inactive Landfill
LR-101 Inactive Landfill
LR-102 Inactive Landfill
LR-103 Inactive Landfill
LR-104 Concrete/ Asphalt Plants
LR-105 Inactive Landfill
MW-101 Radiological Area 2
MW-102 Radiological Area 2
MW-103 Inactive Landfill
MW-104 Inactive Landfill
MW-105 Earth City
MW-106 Upgradient
MW-107 Upgradient
MW-1204 South Quarry
MW-1205 unknown
MW-1206 unknown
MW-FlD North Quarry
MW-FlS North Quarry
MW-F2 Inactive Landfill
MW-F3 Radiological Area 2
PZ-100-SD* North Quarry
PZ-100-SS* North Quarry
PZ-100-KS North Quarry
PZ-101-SS North Quarry
PZ-102-SS North Quarry
PZ-102R-SS North Quarry
PZ-103-SS South Quarry
PZ-104-SD* South Quarry
PZ-104-SS* South Quarry
PZ-104-KS South Quarry
PZ-105-SS* South Quarry
PZ-106-SD* South Quarry
PZ-106-SS* South Quarry
PZ-106-KS South Quarry
PZ-107-SS Inactive Landfill
PZ-108-SS* South Quarry
PZ-109-SS* South Quarry
PZ-110-SS* North Quarry
PZ-111-SD* North Quarry
PZ-111-KS North Quarry
PZ-112-AS Radiological Area 1
PZ-113-AD Closed Demolition Landfill
PZ-113-AS Closed Demolition Landfill
PZ-113-SS Closed Demolition Landfill

Inspected?
No-area overgrown
Yes
Yes
Yes
Yes
Yes
Yes
No-area overgrown
Yes
Yes
Yes
No
No
No
Yes
No
No
No
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Condition Unknown -previous report-damaged Destroyed/ Abandoned Destroyed/ Abandoned Unknown-beneath soil stockpile Okay Okay Okay Unknown Okay Casing damaged/obstructed Okay Destroyed/ Abandoned
De~royed/Abandoned
Destroyed/ Abandoned Okay Abandoned/decomissioned Abandoned/decomissioned Destroyed/ Abandoned Destroyed/ Abandoned
De~royed/Abandoned
Destroyed/ Abandoned Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay
Page 2 of 3

Table 1: List of Existing and Abandoned Monitoring Wells by Well Number, West Lake Landfill OU-1 and OU-2
Well Number General Location Inspected? Condition
PZ-114-AS* North Quarry Yes Okay
PZ-115-SS* North Quarry Yes Okay
PZ-116-SS South Quarry Yes Okay
PZ-200-SS North Quarry Yes Okay
PZ-201A-SS* South Quarry Yes Okay
PZ-202-SS South Quarry Yes Okay
PZ-203-SS South Quarry Yes Okay
PZ-204-SS South Quarry Yes Okay
PZ-204A-SS South Quarry Yes Okay
PZ-205-AS South Quarry Yes Okay
PZ-205-SS* South Quarry Yes Okay
PZ-206-SS Concrete/Asphalt Plants Yes Okay
PZ-207-AS Closed Demolition Landfill Yes Okay
PZ-208-SS North Quarry Yes Okay
PZ-300-AS Upgradient No Destroyed/Abandoned
PZ-300-AD Upgradient No Destroyed/Abandoned
PZ-300-SS Upgradient No Destroyed/Abandoned
PZ-301-SS Upgradient No Destroyed/Abandoned
PZ-302-AI Inactive Landfill Yes Okay
PZ-302-AS Inactive Landfill Yes Okay
PZ-303-AS Inactive Landfill Yes Okay
PZ-304-AI Inactive Landfill Yes Okay
PZ-304-AS Inactive Landfill Yes Okay
PZ-305-AI Concrete/Asphalt Plants Yes Okay
PZ-1201-SS South Quarry Yes Unknown-location buried beneath soil
* Included in monitoring program for the permitted solid waste landfill.

Page 3 of 3

Table 2: Reported Abandoned/Destroyed Monitoring Wells to be Inspected, West Lake Landfill OU-1 and OU-2
Well Number General Location
S-1 Radiological Area 2
S-51 Closed Leachate Pond
S-52 Closed Leachate Pond
S-53 Closed Leachate Pond
S-54 Inactive Landfill
S-76 Inactive Landfill
S-8 Radiological Area 2
S-80 Upgradient
S-88 Inactive Landfill
1-2 Radiological Area 2
1-50 Upgradient
1-56 Inactive Landfill
1-58 Inactive Landfill
1-59 Radiological Area 2
1-62 Radiological Area 2
1-65 Radiological Area 2
1-7 Radiological Area 2
1-72 Concrete/ Asphalt Plants
D-14 Radiological Area 1
D-81 Inactive La!’ldfill
D-83 Radiological Area 2
D-89 Inactive Landfill
D-90 Upgradient
D-91 Upgradient
D-92 Closed Demolition Landfill
D-94 Radiological Area 2
LR-100 Inactive Landfill
LR-101 Inactive Landfill
LR-102 Inactive Landfill
MW-101 Radiological Area 2
MW-105 Earth City
MW-106 Upgradient
MW-107 Upgradient
MW-1205 unknown
MW-1206 unknown
MW-FlD North Quarry
MW-FlS North Quarry
MW-F2 Inactive Landfill
MW-F3 Radiological Area 2
PZ-1201-SS South Quarry
PZ-300-AD Upgradient
PZ-300-AS Upgradient
PZ-300-SS Upgradient
PZ-301-SS Upgradient

Inspected?
No-area overgrown
No
No
No
No
No
No-area overgrown
No
Yes No-area overgrown No
Yes
Yes
Yes No-area overgrown No-area overgrown
No-area overgrown
No
No
No-area overgrown
No-area overgrown
No
No
No
Yes
No-area overgrown
Yes
Yes
Yes
No-area overgrown
No
No
No
No
No
No
No
Yes
No
Yes
No
No
No
No

Condition Unknown-need to clear vegetation Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Abandoned 10/92 Abandoned 10/92 Unknown-need to clear vegetation Destroyed/ Abandoned Destroyed/Abandoned Unknown-unable to locate previously Destroyed/ Abandoned Abandoned 10/92 Abandoned 10/92 Abandoned 10/92 Unknown-need to clear vegetation Unknown-need to clear vegetation Unknown-need to clear vegetation Destroyed/Abandoned Destroyed/ Abandoned Unknown-need to clear vegetation Unknown-need to clear vegetation Destroyed/ Abandoned Reported as missing in 1994 Reported as missing in 1994 Destroyed/ Abandoned Unknown-previous report-damaged Destroyed/ Abandoned Destroyed/ Abandoned Unknown-beneath soil stockpile Unknown-need to clear vegetation Destroyed/Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Abandoned/decomissioned Abandoned/decomissioned Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Unknown-location buried beneath soil Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned
Page 1 of 1

Table 3: List of Monitoring Wells Potentially Available for Sampling, West Lake Landfill OU-1 and OU-2
Well Number General Location
D-12 Radiological Area 2
D-13 Radiological Area 2
D-3 Radiological Area 1
D-6 Radiological Area 2
D-85 Radiological Area 1
1-11 Radiological Area 2
1-4 Radiological Area 1
1-66 Radiological Area 2
1-67 Closed Demolition Landfill
1-68 Radiological Area 1
1-73 Concrete/Asphalt Plants
LR-103 Inactive Landfill
LR-104 Concrete/Asphalt Plants
LR-105 Inactive Landfill
MW-102 Radiological Area 2
MW-104 Inactive Landfill
MW-1204 South Quarry
PZ-100-KS North Quarry
PZ-100-SD* North Quarry
PZ-100-SS* North Quarry
PZ-101-SS North Quarry
PZ-102R-SS North Quarry
PZ-102-SS North Quarry
PZ-103-SS South Quarry
PZ-104-KS South Quarry
PZ-104-SD* South Quarry
PZ-104-SS* South Quarry
PZ-105-SS* South Quarry
PZ-106-KS South Quarry
PZ-106-SD* South Quarry
PZ-106-SS* South Quarry
PZ-107-SS Inactive Landfill
PZ-108-SS* South Quarry
PZ-109-SS* South Quarry
PZ-110-SS* North Quarry
PZ-111-KS North Quarry
PZ-111-SD* North Quarry
PZ-112-AS Radiological Area 1
PZ-113-AD Closed Demolition Landfill
PZ-113-AS Closed Demolition Landfill
PZ-113-SS Closed Demolition Landfill
PZ-114-AS* North Quarry
PZ-115-SS* North Quarry
PZ-116-SS South Quarry
PZ-200-SS North Quarry

Inspected?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Condition
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay

Page 1 of 2

Table 3: List of Monitoring Wells Potentially Available for Sampling, West Lake Landfill OU-1 and OU-2
Well Number General Location
PZ-201A-SS* South Quarry
PZ-202-SS South Quarry
PZ-203-SS South Quarry
PZ-204A-SS South Quarry
PZ-204-SS South Quarry
PZ-205-AS. South Quarry
PZ-205-SS* South Quarry
PZ-206-SS Concrete/ Asphalt Plants
PZ-207-AS Closed Demolition Landfill
PZ-208-SS North Quarry
PZ-302-AI Inactive Landfill
PZ-302-AS Inactive Landfill
PZ-303-AS Inactive Landfill
PZ-304-AI Inactive Landfill
PZ-304-AS Inactive Landfill
PZ-305-AI Concrete/Asphalt Plants
S-10 Radiological Area 2
S-5 Radiological Area 1
S-61 Radiological Area 2
S-82 Radiological Area 2
S-84 Radiological Area 1
D-93 Radiological Area 2
1-9 Radiological Area 2
D-81 Inactive Landfill
D-83 Radiological Area 2
1-62 Radiological Area 2
1-65 Radiological Area 2
1-7 Radiological Area 2
MW-101 Radiological Area 2
S-1 Radiological Area 2
S-8 Radiological Area 2
LR-102 Inactive Landfill
PZ-1201-SS South Quarry
D-94 Radiological Area 2
1-2 Radiological Area 2
S-75 Inactive Landfill
D-87 Closed Demolition Landfill
MW-103 Inactive Landfill

Inspected?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No-area overgrown
No -area overgrown
No-area overgrown
No-area overgrown
No-area overgrown
No-area overgrown
No-area overgrown
No-area overgrown
Yes
Yes
No -area overgrown
No -area overgrown
Yes
Yes
Yes
Condition
Okay
Okay
Okay
Okay
Okay
Okay

Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay -may be incorrectly labelled
Okay -may be incorrectly labelled
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown-beneath soil stockpile
Unknown-buried beneath soil
Unknown-previous report-damaged
Unknown-unable to locate previously
Casing damaged/obstructed
Casing obstructed
Casing damaged/obstructed
* Included in monitoring program for the permitted solid waste landfill.
Page 2 of 2

FIGURES

STANDARD OPERATING PROCEDURES

Standard Operating
Procedures for Groundwater
Sample Collection

Herst & Associates, Inc.
SOP-GW
Revision 4.2

Revised
June 25, 2012

/_ c-[v

~ERST & ASSOCIATES, INC.·l!’
‘.

4631 North St. Peters Parkway St. Charles, Missouri 63304 Telephone: (636) 939-9111 Facsimile: (636) 939-9757
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25.2012 Paqei
TABLE OF CONTENTS

1.0 INTRODUCTION ……………………………………………………………………………………………….. 1

2.0 STATIC GROUNDWATER LEVEL, MONITORING WELL DEPTH, AND MONITORING WELL VOLUME 1
I I I I I I I I!!!!!!!!! I I I I I I I I !IllIll I I I I I I I I I I I I I !Ill I I I I I I I I I IIIII I I I I I I I I I I I II !Ill I I I I I I
2.1 Facility-Wide Depth to Groundwater Measurements …………………………………………… 1

2.2 Monitoring Well Casing Volume Determination ………………………………………………….. 2

3.0 MONITORING WELL PURGING …………………………………………………………………………. 2

3.1 Low Flow Purging ……………………………………………………………………………………………. 3

3.2 Pump Purging …………………………………………………………………………………………………. 3

3.3 Bailer Purging …………………………………………………………………………………………………. 3

4.0 GROUNDWATER SAMPLE COLLECTION …………………………………………………………. 4

5.0 EQUIPMENT CLEANING …………………………………………………………………………………… 5

5.1 Electronic Water Level Indicator Decontamination ……………………………………………… 5

5.2 Non-Dedicated Submersible Impeller Pump Decontamination …………………………….. 5

5.3 Non-Dedicated Submersible Bladder Pump Decontamination …………………………….. 5

6.0 SAMPLE HANDLING …………………………………………………………………………………………. 6

7.0 SAMPLE DOCUMENTATION AND CHAIN-OF-CUSTODY ………………………………….. 6

8.0 FIELD QUALITY CONTROL (QC) SAMPLES ………………………………………………………. 7

8.1 Trip Blank Samples …………………………………………………………………………………………. 7

8.2 Field Blank Samples ………………………………………………………………………………………… 7

8.3 Equipment Blank Samples ……………………………………………………………………………….. 7

8.4 Field Duplicate Samples ………………………………………………………………………………….. 7

8.5 Matrix Spike I Matrix Spike Duplicate Samples …………………………………………………… 8

9.0 FIELD SHEETS I FIELD LOG BOOKS ………………………………………………………………… 8

LIST OF APPENDICES
Appendix A Example Groundwater Elevation Measurements Form Appendix B Example Monitoring Well Condition Report Appendix C Example Field Information Log
Standard Operating Procedures for Groundwater Sample Collection Herst &Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Page1

1.0 INTRODUCTION

The following guidelines describe groundwater sample collection and handling procedures for the Herst & Associates, Inc. personnel. The intent of the Standard Operating Procedures described herein is to provide procedures designed to yield representative and comparable analytical data from each site during each sampiing event.
There are three (3) principal steps in collecting groundwater samples from monitoring wells:
.,. Measuring static groundwater levels;
.,. Evacuating or purging well casings; and
;.. Collecting and preserving samples.
These steps are discussed more completely below.

2.0 STATIC GROUNDWATER LEVEL, MONITORING WELL DEPTH, AND MONITORING WELL VOLUME
2.1 Facility-Wide Depth to Groundwater Measurements
Static depths to groundwater and total depths will be measured at applicable facility monitoring wells and piezometers on the same day, if possible, and prior to purging and sampling of monitoring wells during each monitoring event. Depths to static groundwater levels will be measured from the surveyed mark at the top of the inner casing of each monitoring well. If there is no surveyed mark available at the top of the inner casing, the measurement will be performed on the same side as of the well as the lock on the exterior protective casing. Measurements of depth to groundwater and measurements of total monitoring well depth will be performed with an electronic water level indicator that is graduated in increments of one one-hundredth (1/100) of a foot and provides an audible and visual indication of water contact. Each measurement for depth to groundwater and each measurement for total depth will be performed twice (double-checked) to minimize the potential for false readings. Parts of water level measuring devices that contact groundwater will be thoroughly washed with a non-phosphate detergent (e.g. LiquiNox® or equivalent) followed by a rinse with deionized water or distilled water immediately after each use to minimize the potential for cross-contamination of monitoring wells.
Results of the facility-wide measurements of depth to groundwater will subsequently be used for generation of a potentiometric surface map for the monitoring event. The groundwater elevation in each monitoring well will be determined by subtracting the measured depth to groundwater from the top-of-inner-casing elevation. Appendix A presents an example Groundwater Elevation Measurements form. Additionally, while measuring facility-wide static groundwater depths, Herst & Associates, Inc. personnel will perform an evaluation of each monitoring well and piezometer and record the results of each evaluation on a Monitoring Well Condition Report. Appendix B presents an example Monitoring Well Condition Report.
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Paqe2

2.2 Monitoring Well Casing Volume Determination
The depth to groundwater will be measured immediately prior to monitoring well purging in order to calculate each well’s initial groundwater volume. The difference between the measured total monitoring well depth and depth to static groundwater level is the stabilized height of the groundwater column in the monitoring well. These measurements, taken from the same location on the inner casing described in Section 2.1 during each sampling event, will be used to determine the static monitoring well volume (in gallons) of groundwater in each well per the two (2)-step method described below.
1) The height (H) of the groundwater column is determined by measuring the total depth (TD) of the well and subtracting the measured depth to static water level (MSD).
H (feet) = TD (feet)-MSD (feet)
2) Use the following formula to calculate the static well volume of groundwater:
V =5.875 X 02 X H
Where:
V =Well volume (gallons);
D = Inside well diameter (feet); and
H = Height of groundwater column (feet).

3.0 MONITORING WELL PURGING

Purging monitoring wells prior to sample collection is necessary to remove stagnant groundwater, which may not be representative of in-situ conditions.
Purge parameters including pH, temperature, and specific conductance are monitored I recorded via either flow through cell or via field meters while purging. These purge parameters are measured periodically until purge parameter stabilization is attained according to the following guidelines:
Purge Parameter Stabilization Criteria
pH ± 0.2 standard pH units for 3 successive readings
Specific Conductance + 1 0% for 3 successive readings
Temperature ± 1.0 degree Celsius for 3 successive readings

Additionally, field turbidity will be measured during purging for informational purposes. If non.dedicated pumping equipment is used, the non-dedicated equipment will be cleaned (see Section 5.0, Equipment Cleaning) between use at each monitoring well.
In the event low-flow purging is impractical (limited availability of equipment, etc.), three (3) to five (5) well casing volumes will be purged (if possible) using either pumps or disposable
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Page3
bailers per the procedures described below. Purge parameters will be monitored I recorded similarty to the method described previously. If a monitoring well purges to a point precluding practical sampling (little or no available groundwater), the monitoring well will be completely evacuated of groundwater and allowed to recover for up to twenty-four (24) hours prior to sampling.
If containerization of purged groundwater is not required, then purged groundwater will be discharged to the ground at least fifteen (15) feet away and downslope of the monitoring well. If containerization of purged groundwater is required, then purged groundwater and spent equipment decontamination water (Section 5.0) will be containerized for disposal.
3.1 Low Flow Purging

Low-flow purging (also known as micropurging) is a purging method that has become widely utilized and may be applicable to purging of monitoring wells. This method involves using a pneumatic pump capable of low pumping rates (approximately one (1) liter per minute or less). Low flow purging eliminates the requirement for multiple well casing volume evacuation. Pump discharge rates are regulated and I or controlled to prevent turbulent flow (sample aeration), prevent damage to monitoring well components, and to minimize introduction of sediments into the monitoring well. Monitoring wells purged using low flow purging techniques will be purged as follows:
)or Record pH, specific conductance, and temperature.
)or Periodically monitor the change in groundwater depth in the well and maintain I adjust the pumping rate to minimize drawdown in the well, to the extent practical.
)or Continue pumping at a rate of approximately one ( 1) liter per minute or less until field parameters have stabilized as described in Section 3.0.

3.2 Pump Purging

When a non-dedicated pump is used to either purge three (3) to five (5) well casing volumes from a well or to evacuate the well of groundwater prior to sampling, purging with non.dedicated pumps will proceed as follows:
~ Continue purging groundwater from the well until a minimum of three (3) well casing volumes have been removed and field parameters stabilize.
~ Record the actual volume of groundwater removed.
~ Continue pumping low-recharge wells until at least one (1) well casing volume has been removed and field parameters have stabilized as described in Section 3.0, or until the well is dry.

3.3 Bailer Purging

When a bailer is used to purge a well, disposable polyethylene bailers will be used along with clean rope (nylon I polyester blend or equivalent). Wells will be purged with bailers as follows:
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Page 4
~ Slowly lower the bailer through the water column until the top of the bailer is below the groundwater surface.
).> Retrieve the bailer slowly up the water column and out of the well.
~ Continue removing groundwater from the well until a minimum of three (3) well casing volumes are purged and field parameters stabilize.
~ Record the actual volume of groundwater removed.
).-Continue bailing low-recharge wells until at least one well ( 1) casing volume has been removed and field parameters have stabilized as described in Section 3.0, or until the well is dry.
~ If bailing is selected as the purging and sampling method, one (1) disposable bailer will be used per monitoring well.
4.0 GROUNDWATER SAMPLE COLLECTION

Groundwater monitoring wells will be purged and sampled during each monitoring event by purging and sampling the least impacted well first, followed by the next least impacted well, and proceeding until the most impacted well is sampled last. Determination of which monitoring wells are impacted will be based upon recent historical analytical results for each monitoring well and will be performed prior to Herst &Associates, Inc. mobilization to the site.
For low-flow sampling, samples will be collected after achieving stabilization. For pump sampling and bailer sampling, samples will be collected at monitoring wells that yield three (3) to five (5) casing volumes after achieving stabilization. For a monitoring well that purges dry, samples will be collected as soon as the monitoring well has recharged sufficiently and within 24 hours after the monitoring well has been purged. Regardless of sampling methodology employed (bailers or pumps), care will be taken to avoid sample disturbance and to minimize aeration of samples or groundwater in the wellbore (casing and annulus). Bailers will be retrieved slowly through the water column and carefully emptied directly into the appropriate sample container(s).
Entrained air in sample containers or vials will be eliminated when collecting samples for analyses of Volatile Organic Compounds (VOCs).
Samples are collected in pre-preserved containers provided by the analytical laboratory in order of decreasing sensitivity of each analyte to volatilization. The recommended order of sample collection is listed below.
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Paqe5
Relative Sensitivity
Of Typical Groundwater Quality Constituents

Sample Container Preparation Example Analytes
Hydrochloric Acid Preserved* Decreasing sensitivity VOCs
Nitric Acid Preserved Metals
Sulfuric Acid Preserved 1 Chemical Oxygen Demand
Non-preserved Nutrients

* Samples to be analyzed for VOCs can be collected in unpreserved containers, but doing so reduces the laboratory holding time from fourteen (14) days to seven (7) days.
Collected samples will be immediately placed in insulated coolers with ice. Samples will be maintained with ice until delivered to the analytical laboratory.
5.0 EQUIPMENT CLEANING

The electronic water level indicator will be decontaminated between each monitoring well. Additionally, if utilized, non-dedicated, non-disposable purging and sampling equipment, including bailers and pumps, will be cleaned between wells.
5.1 Electronic Water Level Indicator Decontamination
The electronic water level indicator described in Section 2.0 will be decontaminated between monitoring wells by thoroughly wiping the graduated tape and water-sensing probe tip with a paper towel wetted with a solution of deionized or distilled water mixed with LiquiNox® (or equivalent) followed by thoroughly wiping the graduated tape and water-sensing probe tip with a paper towel wetted with deionized or distilled water. Wiping the water level indicator will be accomplished during removal of the graduated tape and probe tip assembly from the monitoring well.

5.2 Non-Dedicated Submersible Impeller Pump Decontamination
If a non-dedicated submersible impeller-style pump (e.g. Grundfos Redi-flo 2 or equivalent) is used for purging and sampling, the pump body, pump support cable, and sealed electrical wiring will be decontaminated using a three (3) step wash. The first wash will consist of a vessel containing a solution of deionized or distilled water mixed with LiquiNox® (or equivalent). The second and third washes will consist of vessels containing only deionized or distilled water (e.g. first rinse and second rinse). New, disposable polyethylene groundwater discharge tubing for the impeller-style pump will be used to purge and sample each monitoring well. Groundwater discharge tubing will not be decontaminated or reused.

5.3 Non-Dedicated Submersible Bladder Pump Decontamination
If a non-dedicated submersible bladder pump is used for purging and sampling, the pump body and pump support cable will be decontaminated using a three (3) step wash as
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Page6
described above. A new, disposable polyethylene bladder, downhole compressed air conveyance tubing, and groundwater discharge tubing will be used to purge and sample each monitoring well. Disposable bladders, downhole compressed air conveyance tubing, and groundwater discharge tubing will not be decontaminated or reused.

6.0 SAMPLE HANDLING

Sample handling and preservation techniques depend on the parameters to be analyzed. Groundwater samples will be collected, preserved and containerized in their order of sensitivity to volatilization (most sensitive to least sensitive). The purpose of sample preservation is to stabilize parameters of concern by retarding chemical or biological changes. Methods of preservation are generally limited to pH adjustment, chemical addition, and cooling. The order of sample collection is as follows: Volatile Organic Compounds (VOCs), samples preserved with nitric acid (metals), samples preserved with sulfuric acid (Chemical Oxygen Demand) and non-preserved samples (nutrients). Proper preservation will help ensure that samples are representative of the groundwater conditions. Field measurements for indicator parameters (pH, temperature, and specific conductance) will be performed on a portion of the sample that has been placed in a separate container, and not submitted for analyses of other parameters. This procedure avoids cross-contamination of laboratory samples by field instrumentation.
Collected groundwater samples will be maintained on ice in insulated coolers until shipment via courier (e.g. Federal Express) or until direct delivery to the laboratory. Chain-of-custody documentation (described in Section 7.0) will be shipped inside a cooler (if multiple coolers are shipped) to the laboratory. Each cooler shipped or directly delivered to the laboratory will be sealed with a Custody Seal (to verify no sample tampering has occurred) over the cooler opening and enclosed by clear packing tape wrapped several times around the cooler.
7.0 SAMPLE DOCUMENTATION AND CHAIN-OF-CUSTODY
Documentation that accompanies groundwater samples to the analytical laboratory generally includes the following:
~ Chain-of-Custodv lCOC) Records: COC records document in a legally defensible.
manner the history of collection, transport, and transfer of each sample. The
individual who is responsible for the samples from the time of collection to the time of
sample receipt by the laboratory will be documented in the Chain-of-Custody record.
Chain-of-Custody records allow documented tracing of the possession and handling
of individual samples from the time of field collection through laboratory analysis.
Chain-of-Custody documentation will present collected samples in chronological
order.
~ Sample Labels -Prevent misidentification of samples. Sample labels will include the
site name, sampler’s name, well designation, date and time of sample collection,
preservative added, and analysis requested.

In addition, field sheets and/or a field log book are used to document information concerning the collection of each sample from each monitoring point in the groundwater monitoring program. Information in the field sheets and/or field log book, described in Section 9.0,
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Paqe7
include dates and times of sample collection, well development methods used, weather conditions at the time of sample collection, condition of the wells, and remarks noting any unusual circumstances encountered.
8.0 FIELD QUALITY CONTROL (QC) SAMPLES

Field Quality Control (QC) samples will be collected to verify that sample collection and handling procedures were properly performed and that the procedures have not affected the quality of the groundwater samples. Field QC samples will consist of Trip Blank samples, Field (atmospheric) Blank samples, Equipment Blank samples, Field Duplicate samples, and potentially Matrix Spike I Matrix Spike Duplicate samples.
8.1 Trip Blank Samples

Trip blanks will be analyzed for VOCs only and consist of deionized water samples prepared in appropriate containers by the laboratory and received prior to mobilizing to the site. The trip blank samples then accompany the groundwater samples back to the laboratory for analysis. Preparation and analysis of trip blanks for VOCs indicates if site samples have been affected by transport-induced contamination, and can also be used to assess potential laboratory contamination. One ( 1) trip blank will be included for analysis with each sample shipment containing samples for VOC analysis during each monitoring event.
8.2 Field Blank Samples

Field (atmospheric) blank samples consist of deionized water samples collected in containers at the site during the sampling event and under the same environmental conditions as the monitoring well samples. The analysis of field blank samples can detect the influence of ambient site conditions that may bias the sample suite. One ( 1) field blank sample will be collected per twenty (20) or fewer collected groundwater samples (minimum 5% sample coverage) during each monitoring event.
8.3 Equipment Blank Samples

If non-dedicated, non-disposable purging and sampling equipment is used, the effectiveness of cleaning and decontamination procedures will be verified by the collection and analysis of equipment blank samples. After equipment decontamination is performed, an equipment blank sample is prepared by filling the purging and sampling device(s) with deionized water, followed by collection of the water into sample containers. Equipment blanks will be handled and analyzed in the same manner as collected groundwater samples. Equipment blank samples are not required if either dedicated purging and sampling equipment is used or disposable equipment (e.g. disposable bailers) is used. If non-dedicated purging and sampling equipment (e.g. non-dedicated pump) is used, one (1) equipment blank will be collected per twenty (20) or fewer collected groundwater samples (minimum 5% sample coverage) during each monitoring event.
8.4 Field Duplicate Samples

A field duplicate sample is collected from a monitoring well concurrently with collection of the primary groundwater sample from that well, and in an identical fashion. Analysis of field
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 PageS
duplicate samples provides an indication of the variability in analytical results associated with sample collection procedures and laboratory procedures. One ( 1 ) field duplicate sample will be collected per twenty (20) or fewer collected groundwater samples (minimum 5% sample coverage) during each monitoring event:
8.5 Matrix Spike I Matrix Spike Duplicate Samples
Matrix Spike I Matrix Spike Duplicate (MS I MSD) samples are collected from a monitoring well concurrently with collection of the primary groundwater sample from that well, and in an identical fashion. Alternatively, the analytical laboratory may elect to split a received primary groundwater sample into multiple portions and perform MS I MSD analysis on a separate portion of the sample. Once received by the analytical laboratory, a known quantity of target analyte is added to the MS I MSD samples by the laboratory analyst prior to analysis. Analysis of MS I MSD samples provides an indication of the effects of the groundwater matrix on analytical results. One (1) MS I MSD sample pair will be collected per twenty (20) or fewer collected groundwater samples (minimum 5% sample coverage) during each monitoring event.

9.0 FIELD SHEETS I FIELD LOG BOOKS

Field sheets (also called Field Information Logs) and I or field log books will be maintained during each groundwater sampling event. Field Information Logs I field log books will include field observations and well developing, well purging, and well sampling details. Additionally, the following information will be documented on Field Information Logs I field log books:
.,. Site name;
);. Site well designation;
, Sample collector’s name and affiliation (i.e., landfill, laboratory, or contract personnel);
J;> Weather conditions encountered during sampling (such as rain) that could affect
sample quality;
.,_ Pre-purging depth to water, measured from top of inner casing;
.,_ Total depth of well installation, measured from top of inner casing;
J;> Wetted casing or borehole volume;
);. Starting and ending times for well purging;
};> Purging rate (if low-flow purging or pump purging);
.,_ Depth to water measurement after sample collection; and,
.,_ Sample collection date and time.

A blank example field sheet is provided as Appendix C.

Global Presence Personal Attention
·~RST & ASSOCIATES, INC.
GROUNDWATER ELEVATION MEASUREMENTS
Site:
Personnel:

Page of
Herst & Associates, Inc. 4630 South Highway 94 -North Outer Road, St. Charles, MO 63304 (636) 939-9111 (636) 939-9757 fax

Global Presence
Personal Attention

#,_RST & ASSOCIATES, INC.’

GROUND WATER MONITORING WELL CONDITION REPORT

Field Certification:_….,…—-“~–:———-“””””:;~——-‘———-=–:——-.Signed Title Date
Herst & Associates, Inc. 4630 South Highway 94-North Outer Road, St. Char1es, MO 63304 (636) 939-9111 (636) 939-9757 fax

Global Presence Personal Attention
~RST& ASSOCIATES, INC’

FIELD INFORMATION LOG Part 1
Sample Point ID:
Facility: —————-.Location: Sampler(s): Sample Matrix: Top of Casing (ft, msl)
PURGE INFORMATION:
Method of Well Purge: Dedicated Equipment: Yes ___ No ___
DatefTime Initiated: Casing Diameter (inches):
Initial Water Level (feet): One Casing Volume (gal):
Initial Water Level Previous Event (feet): _______ One Casing Volume Previous Event (gal):
Ground Water Elevation (ft, msl): Total Yolume Purged (mL):
Ground Water Elevation Previous Event (ft, msl): —-Purged Dry?: Yes ___ No
Well Total Depth (feet): Water Level after Purge (feet):
Well Total Depth Previous Event (feet): DatefTime Completed:
PURGE DATA:
Time !-‘urge Kate (Hz/gpm) cumu1at1ve Volume (!lall Temp c·c> pH (std units) conductlvJty

Post

2012-07-24 – EPA request for conference call to discuss upcoming activities and community outreach

Re: Conference Call Request Hattie Thomas to: Huckstep, Ramona 07/24/201211:19AM “Doster Branden” “Zamarripa Ruben” “Muenks Shawn” Debbie
Cc· ‘ ‘ ‘ ‘ ‘ ‘
· Kring, Dan Gravatt, DeAndre Singletary
Good morning-Thanks for the email and voice mails. Debbie Kring and I will touch base with you once she returns from site travel. Thanks -HL T
Hattie L. Thomas
Deputy Director
Office of Public Affairs EPA Region 7
901 N. Fifth Street Kansas City, KS 66101 Ph: 913-551-7762, Fax: 913-551-7066
“Huckstep, Ramona” I was just following up from our telephone con … 07/24/2012 09:39:52 AM
From: “Huckstep, Ramona”
To: Hattie Thomas/R7/USEPAIUS@EPA
Cc: “Muenks, Shawn” , “Zamarripa, Ruben” , “Doster, Branden”
Date: 07/24/2012 09:39AM
Subject: Conference Call Request
I was just following up from our telephone conversation last week regarding West Lake Landfill and our request to have a conference call with you and your team regarding upcoming activities at the site and how these may include community outreach.
These activities include:
1.
Groundwater sampling at the landfill starting August 6th -As a Community Involvement Coordinator I will be touring the site

2.
Missouri Coalition for the Environment Public Meeting focusing on West Lake Landfill

3.
Upcoming potential presentation by EPA to the Bridgton City Council

4.
Updates to our MDNR website -per a request from Kay Drey, we have posted the Sampling and Analysis Plan for Groundwater Sampling .http://dnr.mo.gov/env/hwp/fedfac/westlakelandfill-ffs.htm

We would appreciate the opportunity to coordinate with your team on these items and
any other items you would like to discuss. We were hoping to speak with you and your team before the August 6th sampling event begins, if possible. Thank you for your time and consideration of these topics.
Ramona Huckstep, M.S., M.P.A. Community Involvement Coordinator
Hazardous Waste Program Missouri Department of Natural Resources
0711 1M1iiiiimm1 :1 v
Superfund
OliO!
573-522-1540 ramona.huckstep@dnr.mo.gov

Post

2012-01-09 – Bridgeton December 2011 Monthly Progress Report

Page 1 of2
FW: Bridgeton December 2011 Monthly Progress Report iana Howarth
Dan Gravatt
01/09/2012 11:32 AM
Cc:
“Victoria Wan-en”, “Paul Rosasco”, “Randal Bodnar”, “Shawn Muenks”, “Dave Vasbinder”,
“Jessica Merrigan”
Hide Details
From: “Diana Howarth” Sort List…

To: Dan Gravatt/R7/USEPA/US@EPA

Cc: “Victoria Warren” , “Paul Rosasco”

, “Randal Bodnar” , “Shawn

Muenks” , “Dave Vasbinder”

, “Jessica Merrigan”

1 Attachment
• ” . “ffi
•.’to.]
01-09-12 Bridgeton – December 2011 Monthly Progress Report.pdf
I apologize for the wording in the original email, it is an email form that I use and I didn’t edit it properly.
This is the Bridgeton Monthly Progress Report for Decernber 2011
Please let me know if you have any questions or comments.

Thanks, Diana
From: Diana Howarth [mailto:dhowarth(g)herstassociates.coml Sent: Monday, January 09, 2012 11:30 AM To: Dan Gravatt (Gravatt.Dan@epamail.epa.gov) Cc: Victoria Warren (vwarren@hrtc.net); Paul.Rosasco (paulrosasco@emsidenver.com); Randal Bodnar
(rbodnar@cecinc.com); Shawn Muenks (shawn.muenks@drir.mo.gov); Dave Vasbinder
(dvasbinder@republicservices.com); Jessica Merrigan (JMerrigan@LathropGage.com)
Subject: Bridgeton December 2011 Monthly Progress Report:
40359761
Norfolk Monthly Report Final email distribution . Eric Ballenger. i lli il l
II I i IIII 11 I I I IIIII

Superfund file://C:\Documents and Settings\DGRAVATT\Local Settings\Temp\notes87944B\~webl 1… 1/9/2012
Page 2 of 2
Attached is the MONTH YEAR Norfolk Monthly Progress Report.
Please contact Ward Herst of our office ifyou have any questions or comments regarding this report.

Attached is the December 2011 Bridgeton Monthly Progress Report.
Please contact Ward Herst of our office if you have any questions or comments regarding this report.

Thank you,
Diana Howarth
Herst & Associates, Inc.

(636)939-9111
Information contained in this communication is CONFIDENTIAL and intended for the use ofthe addressee only. Ifyou havereceived this communication in error, please notify the sender, [f you are not the intended recipient of this communication, be advised that disclosure, copying, use or dissemination ofthe contents of this communication is prohibited.
file://C:\Documents and Settings\DGRAVATT\Local Settings\Temp\notes87944B\~webl 1… 1/9/2012
Global Presence Personal A ttention HERST & ASSOCIATES, INC.
Mr. Dan Gravatt
U. S. Environmental Protection Agency Region VH 901N5″‘Sl Kansas City, Kansas 66115
.January 9, 2012
Dear Mr. Gravatt:
Monthly Progress Report – December 2011,
West Lake (Bridgeton) LandfUl, Operable Unit 2 Remedial Design

On behalf of Respondent Bridgeton Landfill, LLC (Bridgeton), successor in interest to Laidlaw Waste Systems (Bridgeton), Inc., Herst & Associates, Inc. lias prepared the foUowing progress report in accordance wili Section XID, Paragraph 39 ofthe Administrative Order on Consent (Consent Order), EPA Docket No. vn-94-F-0025 as modified by the Third Amendment to Settlement Agreement and Order oh Consent dated October 16, 2008, and as indicated in Section VI ofthe Statement of Work .Remedial Design. The progress repoit describes activities conducted in December.
I. ACTIONS TAKEN TO COMPLY WITH THE CONSENT ORDER
A monthly progress report was submitted on December 8,2011.
U. WORK PLANNED DURING JANUARY AND FEBRUARY 2012
Responses to MDNR and EPA comments on the Remedial Design Work Plan are anticipated to be prepared upon receipt offinal comments.
IU. MATERIAL PROBLEMS ENCOUNTERED OR ANTICIPATED MATERIAL DELAYS
No material problems or delays were encountered in December and none are anticipated for Januaiy or February 2012.
4631 North Sl. Peters Parkway Telephone (636) 939-9111 St. Charles, IWissouri 63304 Fax (636) 939-9757
Mr. Dan Gravatt Januarv9.2Q12 ] Page 2
If you have any questioiis or comments, please contact Ms. Victoria Warren, the Respondent’s designated Project Coordinator, or the undersignai.
Sincerely,
HERST & ASSOCIATES, INC.
Ward E. Herst, CPHG, CEM Managing Partner
cc: Jessica Merrigan – Lathrop & Gage, LLP Victoria Warren – Republic Services, Inc. David Vasbinder – Bridgeton Landfill, LLC. Shawn Muenks – Missouri Department of Natural Resources Paul Rosasco – Engineering Management Support, Inc. Randal Bodnar – Civil & Environmental Consultants, Inc.

Post

2012-07-06 – MDNR requests special consideration given to fugitive dust control

Page 1 of2
_” -~~ ;ai ) ~~~~:’s~:~:dwater Monitoring SAP and Responses to Comments
\p;;”_::J ~~~ul Rosasco’
07/06/2012 12:00 PM
Cc:
“Doster, Branden”, Dan Gravatt
Hide Details
From: “Muenks, Shawn”

To: “‘Paul Rosasco”‘ Cc: “Doster, Branden” , Dan Gravatt/R7/USEPAIUS@EPA
Paul,
MDNR asks that special consideration be given to fugitive dust control during vegetation clearing and any other vehicular traffic on OU-1 during this sampling event given the extremely dry conditions we are experiencing this summer. Please respond with your plans to address this issue.
Thanks,
Shawn Muenks, P.E.
071 ~ IMIWiiDiiiiYil~lil
Missouri Department of Natural Resources Superfund
P.O. Box 176, Jefferson City, MO 65102-0176 Ph: (573)751-3107 OI.A 0 I email: shawn.muenks@dnr.mo.gov
From: Paul Rosasco [mailto:paulrosasco@emsidenver.com]
Sent: Friday, June 29, 2012 3:13PM
To: ‘Dan Gravatt’; Muenks, Shawn
Cc: ‘Merrigan, Jessie’; ‘Neitzel, Charlotte’; ‘Warren, Victoria’; ‘Whitby, Kathleen’; ‘Golian, Steven’; ‘Ward Herst’;
Bob Jelinek; ‘L FmGERALD’
Subject: Final Groundwater Monitoring SAP and Responses to Comments

Dan and Shawn,

Enclosed please find a revised Sampling and Analysis Plan (SAP) for the Additional Groundwater Monitoring
activities. The document has been amended to address EPA and MDNR comments received on June 18, 2012.
am also sending each of you a hard copy of the plan via regular mail.

Also enclosed are responses to the EPA and MDNR comments.

file:/1/C:/Users/DGRAVATT/AppData/Local/Temp/notes6D6848/~web4719.htm 5/6/2014
Page 2 of2
Once we receive your approval of the SAP, we will schedule the additional groundwater monitoring activity.
Please contact me if you have any questions or would like to discuss the additional groundwater monitoring or any other aspect of the project.
file:///C:!Users/DGRA VATT/AppData/Local!Temp/notes6D6848/~web4719.htm 5/6/2014

Post

2012-07-31 – West Lake Landfill groundwater sampling prep

Page 1 of 3
w\ RE: West Lake Landfill groundwater samplingprep
ffe ‘ ‘S Pau’ Rosasco

WT to: ‘Muenks, Shawn’ 07/31/2012 10:29 PM Cc: Dan Gravatt, “‘Ward Herst'” Hide Details From: “Paul Rosasco” To: “‘Muenks, Shawn'”
Cc: Dan Gravatt/R7/USEPA/US@EPA, “‘Ward Herst'”
Shawn,
Sorry I was out visiting my father. The initial vegetation clearing has been completed. See you next week.
From: Muenks, Shawn fmailto:shawn.muenks@dnr.mo.aovl Sent: Wednesday, July 25, 2012 3:22 PM To: ‘Paul Rosasco’ Cc: ‘Dan Gravatt’; Ward Herst Subject: RE: West Lake Landfill groundwater sampling prep
Paul,
I am planning to be on site August 6 and 7. We can try to locate the well(s) we were interested in during that time (namely D-14). I do not plan to take any splits on the days that EPA will be taking them. I will save our splits for another time (probably sometime during the week of August 13). I am also interested in the schedule for the vegetation clearing. Has this been done already? Please provide dates for clearing activities.
Thanks,
Shawn Muenks, P.E.
iniiiiii ^
Missouri Department of Natural Resources SuperfundP.O. Box 176, Jefferson City, MO 65102-0176
Ph: (573)751-3107
DW!
email: shawn.muenks@dnr.mo.gov From: Paul Rosasco fmailto:paulrosasco@emsidenver.coml Sent: Tuesday, July 17, 2012 1:10 PM
file:///C:/Users/DGRAVATT/AppData/Local/Temp/n’otes6D6848/~web5425.htm 5/9/2014
Page 2 of 3
To: Muenks, Shawn
Cc: ‘Dan Gravatt’; Ward Herst
Subject: RE: West Lake Landfill groundwater sampling prep

Shawn,

With respect to dust suppression, we will use our best efforts to minimize dust generation such as adjustment of
the height of the deck of the brush hog to reduce dust generation to the extent possible while still achieving our
objective of clearing paths to and the immediate areas around the wells to be sampled or the immediate areas
of missing/abandoned wells that need to be further inspected. We only expect to spend a couple of days cutting
brush so overall we don’t anticipate generating a lot of dust.

With respect to damaged wells, the field crew went out and inspected the wells and determined that some of
the damage was located at relatively shallow depths. Consequently, they are out there this week digging out
around the damaged wells that they can access and repairing/replacing the upper portions of the pipe. For wells
that are damaged at deeper intervals, we will attempt to install the Waterra tubing in these wells. If we cannot
snake the tubing down through the wells, we will not obtain samples from the wells. We are not planning on
using a downhole camera to inspect the wells. Although a downhole camera could tell us the exact depth and
possible nature or cause of damage, repair of any damage below the first few feet below the ground surface
would require mobilizing and using a drill rig which is beyond the scope of this activity. Therefore, we did not
see any value in performing downhole television logging at this time.

We will attempt to locate, and if we can find it, obtain a sample from well D-14. I intend to do this when you are

out at the site. Right now, we anticipate starting groundwater sampling sometime the week of July 30th. The
first activity will be to collect a set of synoptitc water levels. They will then start with sampling of the wells
included in the landfill permit. To the extent possible, we will hold off beginning to sample the OU-1 wells until
Dan and you are on site. Dan Gravatt and I spoke this morning and we are planning on being there beginning on

Monday August 6th. It would be great if you could be there then as well. I would like to set up and obtain most
of the split samples during that early part of that week if possible. Dan has indicated that he would like to
obtain splits from D-3 and D-6 and approximately another 10-12 unspecfied wells. Besides D-14, please let me
know if there are any other wells you are interested in obtaining split samples so I can schedule them
accordingly.

Thanks, Paul

From: Muenks, Shawn I”mailto:shawn.muenks@dnr.mo.qov1
Sent: Tuesday, July 17, 2012 11:43 AM
To: Rosasco, Paul fpaulrosasco@emsidenver.com’)
Subject: West Lake Landfill groundwater sampling prep

Paul,

I have some questions regarding preparation for the upcoming groundwater sampling. I previously inquired
about dust suppression associated with clearing activities. I would also like to know if you were able to obtain a
down-hole camera for inspection of possible plugged wells.

Let me know when would be a good time for me to call and discuss these details, thanks.

Shawn Muenks, P.E.
Missouri Department of Natural Resources

P.O. Box 176, Jefferson City, MO 65102-0176
file:///C:/Users/DGRAVATT/AppData/Local/Ternp/notes6D6848/~web5425.htm
5/9/2014

Post
Post

2012-01-04 – MDNR questions about public interviews regarding West Lake Landfill

·-,
/(_:.
. \ ‘ RE: West Lake Landfill: possible interivews related to the revised CIP
\,.__,-J• …1
\. -~”””C7 Muenk.s, Shawn to: Dan Gravatt, Debbie Kring 01/04/2012 04:31 PM Cc: “Doster, Branden”
1”1 orn: “Muenks, Shawn”
To: Dan Gravatt/R7/USEPA/US@EPA, Debbie Kring/R7/USEPA/US@EPA
Cc: “Doster, Branden”
Dan & Debbie,
It was our understanding that the purpose of the public interviews would be to
gauge concerns and expectations of nearby communities regarding West Lake
Landfill and how they want to be interacted with during the public comment
period. The interviews should be done prior to the public comment period and
information gathered included in the CIP. The interviews would not
necessarily be used to determine which remedy the public supports. We were
also under the impression from our discussion at the last site tour that EPA
was committed to conducting these interviews. I think a call to discuss this
issue is warranted. Please advise of availability. We are available Thursday
or Friday morning this week and Monday or Tuesday of next week.

Thanks,
Shawn Muenks, P.E.
Missouri Department of Natural Resources

P.O. Box 176, Jefferson City, MO 65102-0176 Ph: (573) 751-3107 email: shawn.muenks@dnr.mo.gov —–Original Message—-.From: Dan Gravatt [mailto:Gravatt.Dan@epamail.epa.gov] Sent: Wednesday, January 04, 2012 3:53 PM To: Muenks, Shawn; Doster, Branden Cc: Debbie Kring Subject: West Lake Landfill: possible tnterivews related to the revised CIP
Shawn, Branden,
Following up on the question you posed in yesterday’s biweekly conference call, I spoke with Debbie Kring yesterday on the issue of conducting public interviews as part of the revised CIP. Debbie stated that it has not been decided whether EPA will conduct these interviews, but if our Office of Public affairs decides to do so, they will be conducted in the spring. OPA intends to treat these interviews separately from public comment periods and/or public meetings associated with any decision documents.
If you have any other questions on this issue, please contact Debbie directly at 913-551-7725.
Sincerely, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063
Principles and integrity are expensive, but they are among the very few things worth having.
[) 7/ (~/ 40440122
llllllllllllllllllllllllllllllllllllllllllllllllll
Superfund
:1 .’

‘0 -~
.Jl …<_I :.•• ) / ,r. /.-, r' .._..,.-v

Post

2015-03-03 – EPA – West Lake Landfill – One and a half thousand billion picoCuries of Thorium 230 in West Lake Landfill

Site ID: 0714BE01
Mr. Paul V. Rosasco
Project Coordinator
Engineering Management Support, Inc.
7220 West Jefferson Avenue, Suite 406
Lakewood, Colorado 80235
Dear Mr. Rosasco:
The U.S. Environmental Protection Agency (EPA) is providing comments for the reviewed
document submittal titled “Bridgeton Landfill Thermal Isolation Barrier Investigation Phase 1 Report,
Bridgeton, St. Louis County, Missouri” prepared by Feezor Engineering, Inc. and P. J. Carey &
Associates, in conjunction with Engineering Management Support, Inc. and Auxier and Associates, Inc.
The cover letter on the document was dated December 19, 2014 and submitted to EPA in accordance
with the Administrative Order on Consent, EPA Docket No. VII-93-F-0005, paragraph 51 to complete
characterization of radiologically impacted material (RIM) at OU 1, Area 1.
Majority of the general comments enclosed were previously discussed at our joint technical
meeting held on January 23, 2015 and agreed upon by the responsible parties in their response letter to
the EPA, dated January 27,2015. Other additional comments are also provided, which are either general
in context or document specific per the EPA’s complete review of the December draft report. All
comments should be directly addressed through written correspondence to the EPA and can be discussed
by teleconference or email if needed to expedite response. Once approved, the Agency will request a
revised work plan submittal for review and approval. If the comments submitted by the EPA today
cannot be timely addressed before the next iteration of the draft work plan is submitted for Agency
review (i.e., they cross paths), it is understood that they will be addressed, and where applicable,
incorporated prior to submission of a revised final work plan. The EPA also reserves the right to submit
further comments on the pending iteration of draft work plan submittal.
Based on our February 18 and March 2, 2015 follow up teleconferences and as discussed above,
comments that are relevant to the next phase of soil characterization and fieldwork activities should be
incorporated into the revised work plan. Once the EPA approves the revised document, the responsible
parties will proceed in accordance with the work plan schedule to complete this additional work. At the
completion of fieldwork activities this summer, any enclosed EPA comments related to reporting data
results should be incorporated within a comprehensive report that contains data from every phase of
RIM characterization fieldwork performed to date and following the conclusion of the final phase this
year.
If you have any questions regarding this document, EPA’s comments or would like to discuss
other issues, please email or contact me at (913) 551-7611.
Sincerely,
WLLFOIA4312- 001 – 0050546
End:
cc: Shawn Muenks, MDNR
Robyn Kiefer, USACE
Brad Vann
Remedial Project Manager
Missouri/Kansas Remedial Branch
Superfund Division
WLLFOIA4312- 001 – 0050547
General Comments:
I. All field notes and photos should be attached to the comprehensive report or added as
appendices.
2. The Data Quality Objectives in the pending revised work plan must differentiate the
radiological contaminants from a radioactively impacted material (RIM) source versus a
non-RIM/naturally occurring or other sources. Please revise the DQOs accordingly.
3. The upcoming investigation is dependent on the historical photographs to determine
sampling locations. It is EPA understanding from our last teleconference that an aerial
survey of the landfill was taken in I973 and available, and was verbally requested during
our last telephone conference. Therefore, please provide copies of this photograph and/or
stereographic pairs, along with any other relevant or referenced historical information to
EPA for supporting the rationale behind sample locations and or historical placement of
RIM. This may be provided with the revised work plan or as a separate submittal to EPA.
4. The comprehensive final report must include a conclusion and recommendations section.
In addition, document figures warrant revision that accurately depict and incorporate
relevant site information both historical and based on recent sampling results around
OUI, Area I, as some of the historical RI boundaries are now obsolete.
5. Supplemental sampling needs to identify a clear process in the work plan, or reference an
existing one, for decision making while in the field and further investigation if
concentrations of RIM are found in the pending expanded investigation locations without
requiring another mobilization.
6. All work related documents (e.g., work plans, reports, deliverables, etc.) from this point
forward must include a schedule of primary tasks/activities/milestones with along
projected dates for their start/completion and where applicable identification of any
critical path items.
7. It is EPA’s intention to collect split samples during the next round of fieldwork for
submission of TCLP standard and/or pyrolysis analysis. Soils identified as containing
RIM associated with the radionuclides historically dispose of at OUI Area I, need to be
made available to EPA personnel or their field representatives. This would include and is
not limited to existing RIM soils samples collected during the prior round of
characterization that are currently maintained onsite.
8. Per the technical conference with EPA personnel on January 23, 20I5 and consistent with
the January I5, 20I5 letter sent by EPA, RPs need to perform additional bounding
sampling near elevated locations to determine whether or not contamination extends
outside these areas. This includes establishing a no RIM boundary and performing
additional sampling southward towards the North Quarry area and west of the original
boundary of Area I to determine the extent of RIM in this area. Ideally samples could be
placed per that discussion to ensure best coverage, support the existing data, and in
WLLFOIA4312- 001 – 0050548
accordance with risk-based statistic, given the heterogeneity of how RIM was placed in
the landfill. As previously discussed, there’s a lot of value in using historic imagery to try
to identify areas of potential concern. Where historic imagery is utilized it must be cited
to help support sampling locations, and where available copies provided in reports to
justify sampling locations (see General Comment 3).
9. For reporting purposes and work after the investigation, EPA recommends the RPs revisit
some assumptions of the Baseline Risk Assessment using this new data and any future
collected data as part of the RIM characterization to ensure site conditions are still similar
to what has been previously assessed. It’s possible to calculate the total amount of
Thorium-230 disposed of in 8,700 tons of waste material, this value is ~1.5E15 pCi.
Using the UCL95 values provided in the BLRA you arrive at a total accounted for
activity of 1.3E15, or about 90% of the material is accounted for, which is probably a
pretty good estimate.
Conversely, if the average value is used, you arrive at an accounted for activity of only
7.5E14, which is roughly 50% of the material…
With this new data the material present appears to be in a larger area, at least at Area 1,
and present in thicker layers, and/or is present at higher activities than what was assumed
in the BLRA. Therefore, this information will need to be reevaluated in the revised BRA
prior to amending the Supplemental Feasibility Study.
Specific Comments:
1. Section 1, pg. 7, Paragraph: Report states, “Although these criteria identify levels that
would allow for unrestricted use of the site, these criteria have no relationship to riskbased
criteria for a solid waste landfill or levels that would be protective if an SSE were
to occur in these materials.” The final report needs to state that risk-based criteria for this
site has not been determined, therefore, comparison to unrestricted use criteria is being
used.
2. Section 1.1.2.2, Page 8, Paragraph 4: Report states that monthly groundwater levels
measured in 2000 and 2005 indicated that groundwater generally occurs only in the
underlying alluvium at or below the base of the landfill material. As such, recent
groundwater levels need to be reviewed and also cited in the final report to indicate
whether current data shows the groundwater level is still at or below the depth of waste;
or could reference section 7.2 to indicate that 2013 investigation results confirm that
current conditions still indicate fluid levels at or below the base of the landfill material,
which is consistent with the 2000 and 2005 groundwater levels.
3. Section 1.1.3, Page 9: This paragraph references the proposed thermal isolation barrier
location. Two alignment alternatives have been proposed. The final report will need to
include a figure or figures to indicate which IB location is being referred.
WLLFOIA4312- 001 – 0050549
4. Section 1.1.3.2, Page 9, Paragraph 2: Report states laboratory analysis of surface soil
samples (the upper 6 inches) detected radionuclides at levels above 5 pCi/g above
background at boring locations WL-106 and WL-114. Figure 2 only shows WL-106B. In
the final report, please clarify if this is the same well as WL-1 06 or not and correct if
needed.
5. Section 3.2.5, Page 17, Paragraph 2: In this paragraph, and at several other locations in
the document, it is stated that a screening value of 200-250 cps was used to identify
potentially elevated gamma readings. Be sure to include an explanation on how that
screening level was determined in the final report.
6. Section 4.2.1, Page 24, Paragraph 2: Last sentence states, “Samples were then
geologically logged, photographed, scanned for radiation, and samples for radiological
analyses were selected.” Expand this section in the final report to indicate how the
samples for radiological analyses were selected and how the number of samples selected
were determined or reference section 4.4 where further discussion is provided.
7. Section 4.2.2, Page 25: Section identifies sonic borehole locations selected if GCPT data
indicated the potential for RIM (1-2, 2-2, 5-3, 1C-6). Also states 8-1 and WL-119 were
selected to further understand slightly elevated GCPT sounding results. Clarify whether
the “if” needs to be changed to “because”, as “if” implies the borings were pre-selected,
then amend the text in the final report accordingly. Also, there is no mention of why
sonic boreholes 12-5, 13-3, 13-6, 14-2, 14-4, 14-5, 14-7, 15-2 (& 2A), 16-3, and 16-6
were drilled, which warrants addressing in the final report.
8. Section 4.4, Page 27, Paragraph 1: States “Intervals with elevated gamma readings were
selected for offsite laboratory analysis.” Additional text is needed in the final report to
clarify what constitutes an “elevated gamma reading”. Also, clarify if the samples taken
from the interval were from locations that exhibited the highest 2 gamma reading in each
interval. Additional text also needs to discuss if samples taken where there were no
elevated gamma readings, and if an attempt was made to collect samples above and
below the elevated readings to identify if the vertical extent of RIM had been identified at
those locations.
9. Section 5.3.5, Page 32: This section does not provide narrative summary of results of four
gas monitoring as the other sections do. A results summary statement needs to be
included in this section within the final report, and backup data provided and referenced
in an appendix.
10. Section 5.3.8.1, Page 33: A statement must be included in the final report how alpha
readings above 20 dpm/1 00cm2 and beta-gamma readings above 1000 dpm/1 00 cm2
were determined to be contaminated. This comment also applies to sections 5.3.8.2 and
5.3.8.3, which use this same reference level.
11. Section 6, Page 34, Paragraph 1: States ” … based upon review of historic images, it was
determined during the investigation that a deeper quarry existed in the southeast portion
of OU 1 Area 1 that could be problematic to the barrier design.” The final report must
WLLFOIA4312- 001 – 0050550
clarify where you are referring to Bridgeton Sanitary LF North Quarry, and if so, should
also state that it doesn’t appear to be some newly identified feature.
12. Appendix C3 & Figure 6: Sonic downhole borehole log and core scan shows columns for
samples collected and shipped. Figure 6, sonic boring 1-2 shows a sample was collected
at depths of 8-9′, 18-19′, 20-21′, 22-23′, 24-25′, 28-29′, 33-34′, 38-39′, 39-40′, and 40-41′
and results were provided. However, the sample shipped box on the log was only
checked for samples 28-29′ and 39-40′. This discrepancy warrants documenting in the
final report and demonstrates the absolute need for boring logs to be rechecked,
especially in the field, for accuracy to ensure they are complete and correctly reported.
13. Figures General Comment 1: The final report needs to include another set of figures that
contain all results, including past sample results and recent sample for each radionuclide
to facilitate a better understanding of RIM distribution in Area 1. Historically
interpolated boundaries also merit updating from these additional figures as they have
been disproven.
14. Figures General Comment 2: If the data is available, it needs to plot the results of
samples below the depth of contamination, or the CPT gamma results plotted for the
interval below the highest results. For example, it’s helpful at location Sonic 1-2 to see
that the interval immediately below the high sample was non-detect, whereas at Sonic 1 C-
6 it’s not immediately clear if a “clean” sample was ever identified. It would also help to
color code or otherwise identify borings where elevated material is found. While the
posting plots are useful, it’s hard to get a good visual summary of the data as presented,
and needs to be revised accordingly in the final report.
15. Figure 2: Figure references “elevated” and “non-elevated” historical boundaries. All
figures in the final report need to be changed to quantify the “elevated” levels, and areas
of surface RIM be clearly identified.
16. Figure 14: The profile shows GCPT-12 hit alluvium at elevation 442. However, on the
1971 aerial it appears the elevation at this location is ~432 along the edge of what
appears to be a lagoon and is where the 1C-12 is located. In a 1973 aerial it appears the
lagoon is essentially filled in, which means it is possible that what is being classified as
alluvium is actually spoils from the quarrying operation or some other type of fill.
Review this information accordingly, clarify and if necessary revise in the final report.
17. Cross Sections: Revision showing the lab results for sonic borings in each cross section at
each depth a sample was collected would significantly improve clarity and avoid possible
reviewer error. Cross referencing between logs, downhole scans, and lab reports is
confusing and time-consuming and can lead to error; thus, having as much of the
pertinent data at one glance would aid in understanding the contaminant distribution.
Please revise accordingly, in the final report.
WLLFOIA4312- 001 – 0050551

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