Email Regarding Response to EPA Comments made on July …406 East Walnut Street Chatham, IL 62629 Phone (217) 483-3118 Fax (217) 483-2356 August 4, 2017 Mr. Tom Mahler On‐Scene Coordinator

406 East Walnut Street Chatham, IL 62629 Phone (217) 483-3118 Fax (217) 483-2356

August 4, 2017 Mr. Tom Mahler On‐Scene Coordinator Missouri/Kansas Remedial Branch Superfund Division United States Environmental Protection Agency Region 7 11201 Renner Boulevard Lenexa, Kansas 66219 RE: Response to EPA Comments made on July 21, 2017 to the Temperature Monitoring Probe

(TMP) Work Plan Dear Mr. Mahler: On behalf of our client, Bridgeton Landfill, LLC (hereinafter Bridgeton Landfill), Feezor Engineering, Inc. (FEI) hereby submits a revised version of the North Quarry Subsurface Temperature Monitoring Probes (TMPs) Work Plan (hereinafter referred to as the TMP Work Plan) incorporating the requested edits based upon the comments received in your July 21, 2017 letter to Mr. Paul Rosasco of Engineering Management Support, Inc. This letter briefly addresses how the comments were addressed. Comment #1: Section 1.0, page 1: “This work plan will supplement the existing temperature monitoring network and complement the Inert Gas Injection Work Plan for Hot Spot Remediation (submitted to USEPA and MDNR on May 20, 2016 an subsequently revised and resubmitted in August 2016, and September 2016 in response to comments), resulting in a comprehensive monitoring system for the North Quarry. Comment: Delete “…and complement the Inert Gas Injection Work Plan for Hot Spot Remediation (submitted to USEPA and MDNR on May 20, 2016 and subsequently revised and resubmitted in August 2016, and September 2016 in response to comments), resulting in a comprehensive monitoring system for the North Quarry.” Response #1: The statement has been deleted. Comment #2: Section 2.1 page 2: “Typically, the vertical spacing between thermocouples is no more than 20 vertical feet.” Comment: Delete this statement

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Response #2: The statement has been deleted. Comment #3: Section 2.2 page 2: “As shown on Drawing 002 and 003 (Appendix A), the identified RIM in OU-1, Area 1 is located north of the North Quarry high-wall, hear the bottom of the landfill cell.” Comment: Delete this statement. Response #3: The statement has been deleted. Comment #4: Section 2.3, page 3: “Accordingly, the lost tip method is believed to be imperative for successful TMP installation. Sampling is not possible when utilizing the lost tip method. Comment: Delete this statement. Response #4: This statement has been deleted. However, for safety considerations, the lost tip method will be used which does not allow sampling. Comment #5: Section 4, page 8: “If a TMP reading indicates a possible trigger exceedance, a verification process will be followed to ensure that the reading is a true exceedance.” Comment: Add a statement to Section 4.0, RESPONSE STEPS TO TRIGGER VALUES, stating that the verification and validation procedures will in no way interfere with the goal of executing the TMP or IGI work plans, nor with having drillers and equipment on-site to complete the necessary action within 2 weeks of initial readings indicating a trigger exceedance. Response #5: A statement was added to ensure that the verification and validation procedures will not interfere with the execution of the TMP/IGI work plan. Comment #6: Section 4, page 8: “After the exceedance is noted, all well(s) that are believe to be the cause of the exceedance will be shut down immediately. The Bridgeton Landfill will notify the USEPA and the MDNR within 24 hours of the measured or inferred exceedance.” Comment: Replace the statement with “When the exceedance is measured or when inferred to be within 5 degrees Fahrenheit of an exceedance, all well(s) that may be the cause of the exceedance will be shut down immediately. The Bridgeton Landfill will notify the USEPA and the MDNR within 24 hours of the measured or inferred exceedance.” Response #6: The suggested text edits have been incorporated. Comment #7: Section 4, page 8: “The Bridgeton Landfill will notify the USEPA and MDNR within one business day of such commencement of investigation.”

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Comment: Replace all instances of “one business day” with “within 24 hours.” Response #7: The suggested text edits have been incorporated. Comment #8: Section 4, Page 8: “Gas wells will be temporarily profiled with a downhole Resistive Thermal Device (RTD) to ascertain elevated temperature regions within the triggered well and all wells within a 300-foot radius of the triggered well.” Comment: The EPA agrees with the use of an RTD to assess downhole temperatures in gas wells: however, since there are additional field measurements and data to be collected from these types of events, additional detail is needed in this document. Specify in Section 4, the planned frequency (daily) and scope of collection and reporting field data associate with responding to trigger exceedances. A new table summarizing the planned field data collection efforts associated with trigger exceedances, including the type of monitoring, equipment to be used, and the frequency of monitoring, must be included in the revised document. Response #8: The suggested table has been added to the text. Comment #9: Section 4, page 8: “Also to be installed are three combined heat extraction/injection wells. These three wells will be installed at a minimum distance of 50 feet from the affected element, at 120-degree spacing offset 60 degrees from the newly installed TMPs.” Comment: Replace “minimum” with “maximum.” Response #9: The suggested text edits have been incorporated. Comment #10: Section 4, page 8: “The combined heat extraction/injection well will also be installed within two weeks of drill rig availability.” Comment: Replace “drill rig availability” with “trigger exceedance.” Response #10: The statement was changed, however, a footnote was added explaining the process the Bridgeton Landfill would use to procure a drill rig. If the process takes longer than two weeks, the USEPA and MDNR will be notified. Comment #11: Section 4, page 9: “Bridgeton Landfill will monitor the heat extraction system and notify the USEPA and MDNR once the condition has been controlled. The condition is controlled if there is no additional lateral migration of heat, and temperatures have fallen below the exceedance levels. If the heat extraction system is not adequate, other remedial actions will be considered based upon consultation with the USEPA and the MDNR.” Comment: Revise the statement as follows: “Bridgeton Landfill will monitor the heat extraction system, and will routinely provide data (weekly basis or more frequently as needed) and appropriate notifications to the EPA and the MDNR once the condition has been controlled. The

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condition is controlled if there is no additional lateral migration of heat, and temperature have fallen below the exceedance levels. If the data and field observations indicated that the heat extraction system is not adequately addressing the condition, other remedial actions will be considered based upon consultation with the USEPA and the MDNR.” Response #11: The suggested text edits have been incorporated. Comment #12: TMP-2, TMP-6, and TMP-9 graphs from Appendix B compared to statement from Section 3.2, (3rd paragraph): “If it appears the shape of the curve suggest that the failed thermocouple interval could be approaching a trigger exceedance, it will be replaced.” Comment: The EPA agrees failed thermocouples should be replaced; however, the plotted temperature graph(s) need to maintain the curve/trajectory of the last collected temperature reading before the thermocouple failure occurred. The EPA suggests that the trend should generally assume that the temperatures associated with a thermocouple that failed is generally increasing at similar rates as the thermocouples located above or below it. The temperature graph(s) for the affected thermocouple(s) must present the last valid reading(s) from a thermocouple that fails, to allow for an interpretation of the assume temperature trends. Response #12: A statement has been added to discuss that trends for failed thermocouple units will assume that temperatures for the failed units are generally increasing at similar rates as the thermocouples located above or below it. Appendix D: Trigger Exceedance Decision Tree Comments Comment #13: In Box 2 add “or” after the first and second criterion. Response #13: The decision tree has been revised. Comment #14: Both Box 2A and 2B must include statements for notification of regulatory entities (EPA & MDNR). Include a notification of initial exceedance to regulators. Response #14: The decision tree has been revised. Comment #15: In Box 2B include a new box in the “NO” line coming off Box 2B that provides for reporting to regulators on what actions were taken since initial exceedance and an explanation why initial exceedance was not verified. Response #15: The decision tree has been revised. Comment #16: After Box 4, all subsequent actions appear to only discuss temperature monitoring actions, and do not address procedures for CO trigger exceedances. Revise the Decision Tree to include procedures to be followed for CO trigger exceedances. Specify on the Decision Tree by

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adding new boxes and revising existing boxes to include/address the response procedures that are planned if a CO trigger is exceeded. Response #16: An initial round of summa canister sampling for the 300 foot radius (North Quarry only) has been added with monthly follow-up readings. Since CO is an indicator of a reaction, no separate process will be followed for a “CO only trigger”. The same process will be followed. Comment #17: The question posed in Box 5A does not address what the action will be if there are elevated temperatures at both depth ranges. Modify the box to include action on both sides of the decision tree if trigger values are measured at both depth ranges. Response #17: A new text box has been added to indicate that both pathways will be taken if there are trigger values measured at both depths. Comment #18: Box 15 questions should be revised to say, “Is exceedance still occurring or is rebound observed?” Response #18: The decision tree has been revised. Comment #19: The box 15 “NO” path should include a box for more frequent monitoring for a period of no less than three weeks prior to resuming normal operations. Response #19: The decision tree has been revised. Comment #20: The box 19 statement should continue by adding “...the 7 days, ensuring that temperature readings are representative of surrounding landfill temperatures.” Response #20: The decision tree has been revised. Comment #21: Revise the Box 24 statement inside the parentheses to state (“During or before the time delay, run header line and connect to cooling tower”). Response #21: The decision tree has been revised. If you have any questions, please feel free to contact me at (217) 483-3118 or Bridgeton Landfill’s Division Manager, Erin Fanning at (209) 227-9531.

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Sincerely,

Daniel R. Feezor, P.E. Feezor Engineering, Inc. [email protected]

mailto:[email protected]

NORTH QUARRY SUBSURFACE TEMPERATURE MONITORING PROBES

(TMPs) WORK PLAN

Administrative Settlement Agreement and Order on Consent for Removal Actions

Prepared for: Bridgeton Landfill, LLC

West Lake Landfill Superfund Site Bridgeton, Missouri

May 2016 Revised August 2016

Revised September 2016 Revised December 2016

Revised August 2017

Prepared by:

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

Engineering for a Better World

FE,E,ZOR ENGINEERING, INC.

North Quarry Subsurface Temperature Monitoring Probe Work Plan Bridgeton Landfill, LLC / Bridgeton Landfill – Bridgeton, Missouri i

TABLE OF CONTENTS

1.0 INTRODUCTION .......................................................................................................... 1 2.0 TEMPERATURE MONITORING PROBE SYSTEM ................................................. 1

2.1 Temperature Monitoring Technology ............................................................................ 1 2.2 Proposed TMP Locations .............................................................................................. 2 2.3 TMP Installation Method............................................................................................... 3

2.3.1 TMP Depth Determination ....................................................................................... 4 3.0 MONITORING OF TMPS ............................................................................................. 5

3.1 TMP Data Collection and Validation ............................................................................. 5 3.2 Maintenance and Replacement of TMPs ........................................................................ 7

4.0 RESPONSE STEPS TO TRIGGER VALUES .............................................................. 7 5.0 REPORTING OF DATA ................................................................................................ 9 6.0 IMPLEMENTATION SCHEDULE ............................................................................ 10 7.0 REFERENCES ............................................................................................................. 11 TABLES: Table 1 – Planned Field Data Collection Efforts Associated with Trigger Exceedances APPENDICES: Appendix A – Additional North Quarry TMP Drawings Appendix B – Current TMP readings as of May 9, 2016 and Notes Appendix C – Auxier and Associates (A&A) Radiological Scanning Procedures Appendix D - Trigger Exceedance Decision Tree

North Quarry Subsurface Temperature Monitoring Probe Work Plan Bridgeton Landfill, LLC / Bridgeton Landfill – Bridgeton, Missouri 1

1.0 INTRODUCTION This Work Plan describes the design, installation (including schedule), and operation of additional Temperature Monitoring Probes (TMPs) for the North Quarry of the Bridgeton Landfill. This work plan is being submitted to satisfy the requirement specified in Section VIII.35.e of the April 28, 2016 Administrative Settlement Agreement and Order on Consent (ASAOC) issued by Region 7 of the United States Environmental Protection Agency (USEPA). Feezor Engineering, Inc., on behalf of Bridgeton Landfill, LLC, (Bridgeton Landfill) has developed this North Quarry Subsurface TMP Work Plan for all site employees, contractors, and subcontractors who may be tasked with the installation and operation of the TMP monitoring system. Section VIII.35 e. of the ASAOC specifies that the North Quarry Subsurface TMP Work Plan shall provide for:

1) A system of TMPs capable of monitoring landfill temperatures that could be a precursor to or indicative of an SSR (subsurface reaction) in the North Quarry that could come into contact with RIM (Radiologically Impacted Materials) in OU-1, Area 1 of the West Lake Landfill.

2) Description of TMP operation, maintenance, performance metrics, and replacement procedures, including frequency.

3) Triggers to be used to indicate a need for installation of additional TMPs elsewhere in OU-1 Area 1 and/or the Bridgeton Landfill North Quarry to monitor for an SSR; including temperatures greater than 185° F or 1500 ppm of carbon monoxide in a landfill gas extraction well, or temperatures greater than 200° F in a temperature monitoring probe.

4) Provisions for ongoing regular reporting of temperature data, along with

providing raw data, to USEPA and the Missouri Department of Natural Resources (MDNR).

This work plan will supplement the existing temperature monitoring network. This work plan proposes the installation of 17 additional TMP strings which will result in a monitoring system comprised of a total of 32 gas extraction wells and 29 TMP strings (161 total buried thermocouples) in the North Quarry. In addition, two replacement TMP strings will be installed in the Neck Area (TMP 2 and TMP 11). 2.0 TEMPERATURE MONITORING PROBE SYSTEM 2.1 Temperature Monitoring Technology The temperature measuring devices proposed are type T thermocouples with 20-gauge type T, Teflon coated wire leads. A thermocouple is a sensor for measuring temperature. It consists of two dissimilar metal wires, joined at one end. When the junction of the two metals is heated or cooled a voltage is produced that can be correlated to a thermocouple thermometer or other thermocouple-capable device at the other end. When properly configured, thermocouples can provide temperature measurements over a wide range of temperatures. Thermocouples are available in different combinations of metals or calibrations. The most common are the “Base Metal” thermocouples known as Types J, K, T, E and N. The proposed thermocouple to be used is a Type T thermocouple (calibration type) that supports a temperature range between -358 degrees F and 662 degrees F.


These units have standard limits of error of 1.0 degree C (1.8 degrees F) or 0.75%, whichever is greater, and specified limits of error of 0.5 degree C (0.9 degrees F) or 0.4%, whichever is greater. A TMP comprises a series of thermocouples spaced vertically within a single borehole. The thermocouple strings are supported by a fiberglass rod during installation, and are encased in a ¾-in. diameter thermally protective covering. Once the thermocouple string is lowered in position, the TMP is encased with a specialized cement bentonite grout that provides the ultimate support for the TMP within the waste. The TMP thermocouple wires are encased in a ¾-in. CPVC Schedule 80 casing on the ground surface and are connected to a selector switch for readings. Before the wires are connected to the selector switch, they are directed through a fiberglass enclosure, where the Teflon is removed from the outer sleeve and then connected to the selector wires. The fiberglass box enclosure is connected to a draining type conduit seal. The installation drawings are included in Appendix A. Improvements to the TMP design may be incorporated before installation. Such improvements may include, for example, multiple TMP conduits in one TMP boring to allow for easier replacement, or changes in the surface feature as the proposed depth intervals are monitored to allow for automated data collection. Approval from the USEPA and the MDNR will be secured prior to any changes of the TMP design. 2.2 Proposed TMP Locations The ASAOC specifies that the TMPs be installed in the North Quarry to form a system of temperature measurements approaching the OU-1, Area 1 (which contains Radiologically Impacted Materials (RIM)). The proposed TMPs are positioned such that they augment the existing TMP locations shown on Drawing 003 in Appendix A. Nine additional TMPs will be installed in the North Quarry along a line due south of the identified RIM but within the North Quarry “muffin top” waste. The TMPs within this alignment, along with two existing TMPs (TMP-24 and TMP-26), will form a sentinel line with an approximate spacing of 81 feet between TMP units. In addition, three TMPs (TMP-33, TMP-34, and TMP-35) will be placed in areas where the North Quarry waste directly overlies the RIM. Five additional TMPs (TMP-45, TMP-46, TMP-47, TMP-48 and TMP-49) will be installed due southeast of the RIM on the lower elevations (toe of the “muffin top” waste). The estimated depths of the quarry bottom and the design vertical distribution of the thermocouple strings for all proposed TMPs are depicted on Drawing 004 in Appendix A. Per the MDNR’s additional request to replace TMP-1, -2, and -11, Bridgeton Landfill has evaluated the current performance of these respective TMPs. As part of this work plan scope, TMP-2R and -11R will be installed as replacements for TMP-2 and -11, and are depicted on Drawings 003 and 004. TMP-1 has experienced historical performance issues that were due to connections at the surface interface. These were corrected in March 2015 and monitoring data since that time has been valid and reliable. Accordingly, replacement of TMP-1 is not warranted at this time. The existing and proposed additional TMPs establish four sentinel “lines” which together form a lateral and vertical network (North Quarry TMP System) of in-situ monitoring capability. The first line consists of the original trigger line consisting of TMP-1, TMP-2R, TMP-3R and TMP-4R. The second line consists of a series of MDNR-requested TMPs: TMP-21, TMP-22, TMP-23, TMP-16, TMP-25, TMP-17, TMP-18, TMP-28, and TMP-29). The third sentinel line will be the newly installed line consisting of TMP-36, TMP-37, TMP-38, TMP-39, TMP-40, TMP-41, TMP-42, TMP-43, TMP-24, TMP-44 and TMP-26. The fourth and final sentinel line will include three TMPs directly over the RIM waste under the “muffin top” (TMP-33, TMP-34, and TMP-35), and five TMPs directly southeast of the RIM (TMP-45, TMP-46, TMP-47, TMP-48 and TMP-49).


2.3 TMP Installation Method The TMPs will be installed within 4-in. diameter boreholes advanced with a sonic drill rig. Sonic drilling is often used for geo-environmental investigative programs. Sonic drilling offers the benefit of negligible drill cuttings and reduced fluid production. The ability to cause vibration to the casing string eliminates the complication of backfill bridging that is common to other drilling methods, and also reduces the risk of casing lockup, allowing for easy casing withdrawal during grouting. Some heat generation may occur within the borehole due to the use of sonic drilling. Liquid (potable water) will be injected down the drill string to reduce potential heat generation. No liquid return to the top of the boring is anticipated. TMP installation will use the “lost tip method” where a disposable tip is temporarily welded to the lowest section of the advancing sonic casing. Once the final proposed depth of the TMP is obtained, the driller will withdraw the casing a few feet, and then the driller will insert a metal rod connected to a cable down the hollow casing and tap off the tip to be left at the bottom of the borehole. Then the strings of thermocouples encased in the abrasive sheath will be inserted inside the drill casing that is advanced to the target depths. A cement / bentonite grout mix will then be pumped into the casing via tremie pipe methods. Once the TMP thermocouple strings are installed and the grout placed, the sections of sonic casings will be carefully extracted. The vibratory oscillations of the sonic technology will allow for the extraction of the casing without displacement the grout or the thermocouple string. Other methods of installation (for example a non-lost tip method for sampling) could potentially allow the waste to push back into the open bottom and displace or catch the thermocouple wires, resulting in a TMP reading interval that is not consistent with total depth. Drilling and installation equipment in contact with soil or waste will be scanned for alpha and beta contamination with a Ludlum Model 2360 scaler/ratemeter coupled with a Model 43-93 probe (or equivalent) as described in A&A Procedure 2.7. Contamination will be sampled by swiping 100 cm2 areas on those portions of the equipment that were in contact with soil surfaces as described in A&A Procedure 3.6. These smear samples will be counted with a Ludlum Model 2929 scaler coupled to a Ludlum 43-10-1 detector. If contamination is found, the equipment will be decontaminated until it meets the standards listed in Table 1. The equipment identification and the final results will be recorded on the appropriate equipment release form from the A&A Procedures Manual and the equipment will be unconditionally released from the project site. The A&A Procedures are presented in Appendix C.


Table 1 - Final Release Survey Limits for Equipment

Parameter Acceptable Surface

Contamination Levels a Equivalent Meter Response

in the Field b

Fixed Alpha (Ra-226 & Th-230)

100 dpm/100cm2, average 300 dpm/100cm2, maximum

20 cpm Model 2360/Model 43-93 60 cpm Model 2360/Model 43-93

Fixed Beta (Unat & assoc. decay products)

5,000 dpm/100cm2, average 15,000 dpm/100cm2, maximum

750 cpm 2360/43-93 2250 cpm 2360/43-93

Removable Alpha 20 dpm/100cm2, average N/A

Removable Beta 1,000 dpm/100cm2, average N/A a From U.S. Atomic Energy Commission’s RegGuide 1.86 Termination of Operating Licenses for Nuclear Reactors,

Table 1: Acceptable Surface Contamination Levels. dpm=decays per minute b Nominal values based on default efficiencies published by Ludlum Instruments on their web site (20% α, 15% β).

Meter efficiencies may be reevaluated at the site. cpm=counts per minute

If the TMP installation process generates any Investigative Derived Waste (IDW), the IDW is collected from the drill stem cleaning process, then that IDW will be scanned for Radiologically Impacted Material using the methods discussed above. The USEPA on-scene coordinator will be notified of any detections from the scanning activities that suggest a presence of RIM. Any IDW with detections that suggest the presence of RIM will be contained and safely stored within the OU-1 Area 1 fenced location, and will be sampled for radionuclides (uranium, thorium, and radium isotopes). Once the radionuclide analytical results are obtained, proper authorized disposal will be secured. After the TMP has been installed and the grout has cured, the individual thermocouple strings will be connected to a selector switch. This switch will be housed within a fiberglass enclosure mounted to uni-strut bracing, which is in turn connected to a concrete base. This configuration comprises the surface detail that is depicted on Drawing 004 in Appendix A. Readings of the TMPs will commence after one week has elapsed to ensure that the TMP has equilibrated and that readings are representative of waste temperatures.

2.3.1 TMP Depth Determination TMP borings will be advanced to the target depth of the bottom of the proposed unit. Based on the historical TMP measurements taken within the South Quarry, the depths of the proposed additional TMPs have been determined according to the following rules:

• For total waste thickness of 80 feet or less, TMPs will be installed within 10 feet of the estimated quarry floor;

• For total waste thickness of greater than 80 feet but less than 160 feet, TMPs will be installed within 20 feet of the estimated quarry floor; and

• For total waste thickness depths greater than 160 feet, TMPs will be installed within 40 feet of the estimated quarry floor, but not exceeding 180 feet in depth.

No fewer than two thermocouples will be installed in each TMP, and thermocouple spacing will not exceed 20 feet in the vertical direction. The closest thermocouple unit to ground surface will typically be 20 feet below grade but not less than 15 feet. In the event the less than a 20-ft distance


is used, the CPVC conduit will be shortened accordingly. An anticipated depth of installation table is included on Drawing 004 in Appendix A. 3.0 MONITORING OF TMPS 3.1 TMP Data Collection and Validation The Neck Area TMPs (TMP 1, TMP 2R, TMP-3R, TMP-4R, TMP-10 TMP-11R, and TMP-14R only), the existing North Quarry TMPs, and the additional North Quarry TMPs will be read weekly. In addition, all TMPs which are extant at the time of each weekly reading will be read and documented. A handheld TMP reading device will be used to manually obtain the temperature reading at each thermocouple interval (in degrees F) on a weekly basis. The following data will be recorded during the weekly reading:

• Date,

• TMP ID,

• Depth of thermocouple,

• Temperature reading (degrees F),

• Resistance reading (ohms), and

• Comment (if any).

The readings will be recorded manually, and then entered into a database. Validation and quality control checks of the readings will be conducted weekly to determine if the readings were recorded and entered correctly. These readings will be plotted on temperature vs. depth charts for each TMP, similar to the example presented in Appendix B. As previously described, each TMP consists of multiple thermocouples in a single TMP location. Each thermocouple is independent within the individual TMP strings. For each reading event, the individual thermocouple temperature and resistance is read and recorded. To qualify the temperature reading, the resistance (in ohms) is compared to a baseline value based on the thermocouple and wire lead length. If a temperature reading is anomalous, the reading will be rechecked and the resistance in ohms will be recorded. If recorded resistance is out of limits, the individual thermocouple on the respective TMP string is deemed compromised and the temperature reading is not used in the current data set. To further evaluate the physical condition of the respective thermocouple, conductivity testing is performed on individual thermocouples to evaluate if corrections or other physical conditions may be affecting the unit’s resistivity. The thermocouple wire used at the Bridgeton Landfill is resistance rated to 29.8 ohms per 100 feet of length. This is the baseline for determination of variation. Quality assurance / quality control (QA/QC) procedures include testing of the TMPs pre- and post-placement, as well as during service using the aforementioned 29.8 ohms per 100 foot criterion. Before a TMP string is installed, the length of each thermocouple string will be tested for resistance. If the measured resistance in ohms is within +/- 20% of the estimated resistance based on the 29.8 ohms per 100 foot criterion, then the thermocouple will be considered acceptable to install. This same baseline criterion will be used for all newly installed TMPs during maintenance. In general, issues with the individual TMP thermocouples can result in readings that begin to deviate from the historical reading patterns, and in trends that are not consistent with heat


generation, rate of temperature change, or heat conduction between layers. Bridgeton Landfill has utilized two techniques to identify the above issues. The first is measurement of resistance of each thermocouple unit, which, based on the information provided by the manufacturer should be 0.298 ohms per foot of wire, when measured between the positive and negative lead of the thermocouple (a 2-ft travel length). This value represents the resistance at room temperature when the thermocouple is in a new condition. It does not include the resistance of any connections at switches and plugs, the effects of strain hardening, or elevation in temperature. The measurement of resistance will be performed routinely to establish baseline values and trends, so that when a temperature reading deviates from the anticipated ranges-plus or minus approximately 2 degrees F due to electromagnetic fluctuation impacts on the landfill generating induced voltage on the units—it can be determined if the resistance indicates a deviation in the observed trend. Deviation in resistance can be due to above-ground issues such as corrosion or broken wires at the switch box, or below ground issues such as wire chaffing, strain hardening, and strains associated with the waste deformation. Therefore, the initial step in diagnosing a deviation is to examine the above-ground conditions and determine if any of those issues are present. If so, they can be remedied and readings re-performed. In the event that no above-ground problems are identified and the resistance changes are limited to a specific unit, the following steps will be followed:

• If the resistance is infinite (open circuit) or below 24 ohms, is the unit is clearly compromised, and no further evaluation is needed.

• If the resistance is high and fluctuating or lower but deviating from the normal readings for the unit, then a connectivity test is performed to determine if the unit has been compromised due to direct connection to other thermocouples associated with a failure of insulation. In this case, all the thermocouples in the unit are tested.

• Bridgeton Landfill may also use time domain reflectometry to identify discontinuity in the wires, which achieves results similar to connectivity testing. This testing method sends a pulse down the wire and watches for the reflection of the pulse. The technique is also referred to as pulse-echo. The pulse velocity is affected by the conditions on the cable, such as leakage through the insulation, breakage, stretching or work-hardening, moisture within the insulation, and other possible impedance affecting cable conditions. The testing method identifies the velocity changes via the timing and shape of the return pulse, which indicates the condition of the wire.

Therefore, TMP resistance is a tool for helping identify issues with the thermocouple, but with the exception of very high or very low values, it does not indicate if the unit is beyond repair or reliable. A weight of evidence approach using all the available data and history is required before the disqualification of a specific thermocouple. Bridgeton Landfill may elect to employ data collectors to reduce the manual labor required to obtain the readings. Any data collector will be compatible with the temperature sensors installed. A reduction in the frequency of readings may be proposed in the future if conditions warrant. A reduction in monitoring would require approval from the USEPA and the MDNR.


3.2 Maintenance and Replacement of TMPs The TMPs will be monitored for changes in resistance, which is an indicator that the TMP may be failing. In addition, the connections to the selector switch or the selector switch itself may corrode. Corrosion may increase resistance. During the weekly readings, any noticeable corrosion will be noted on the field forms, and Bridgeton Landfill will perform monthly maintenance of the system such as cleaning the connections and applying corrosion inhibitors on the connections. Corrosion inhibitors will be used during installation of the selector switches to minimize corrosion from initiation. The resistance of the TMPs will be checked during the monthly maintenance. If a TMP resistance is determined to be beyond normal range—typically 20% higher or lower than the rated ohms per foot of the wire—the TMPs will be tested directly on the thermocouple leads. This will determine if resistance is being generated by the selector switch or other connections. This conductivity test will be performed to determine if the individual thermocouple units have become damaged via failure of insulation wire breakage, liquid accumulation at the switch, or ground penetration. If such conditions are identified, then the TMP thermocouple interval will be removed from service. TMPs installed in waste have a discrete life. When some thermocouples 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 interval. Trends for failed thermocouple units will assume that temperatures for the failed units are generally increasing at similar rates as the thermocouples located above or below it. This can be observed in the historical analysis presented in Appendix B. Upon review of the plotted data, if it appears that the shape of the curve suggest that the failed thermocouple interval could be approaching a trigger exceedance (within 5 degrees Fahrenheit of the triggered exceedance), then the TMP thermocouple will be replaced with a neighboring TMP. For example, if a thermocouple failed at 40 feet and the inferred temperature was within 5 degrees Fahrenheit of the triggered exceedance, but the rest of the thermocouples in that TMP string were operational above and below that interval, then a 40-foot-deep TMP could be installed within 10 horizontal feet of that TMP rather than the entire depth. If two consecutive (or three or more total) thermocouples fail within a given TMP, then the entire TMP will be replaced in order to re-establish monitoring of the affected intervals. If the total number of failed thermocouples in the North Quarry TMP System (as described in Section 2.2 of this Work Plan) exceeds 20%, then Bridgeton Landfill will submit a work plan to the USEPA and MNDR describing the current conditions of the North Quarry TMP System, and which TMP strings will be replaced to remedy the condition. If the 20% failed criterion is met, then the Bridgeton Landfill will replace all failed TMPs, unless given approval for a modification from the USEPA and MDNR. For the sentinel line of TMPs, consisting of TMP-33 through TMP-49, there will be replacement when either (1) two thermocouples within an individual TMP fail (regardless of their vertical position within the TMP) or (2) 20% of the thermocouples fail within an individual TMP. Any thermocouple or TMP that needs to be replaced, will be done so within two weeks of the determination of thermocouple unacceptability.1 4.0 RESPONSE STEPS TO TRIGGER VALUES In accordance with the North Quarry ASAOC, the defined triggers will be used to indicate the need for the installation of additional TMPs. The proposed triggers are: 1 Bridgeton Landfill has a relationship with Frontz Drilling, Inc. and will be using them dependent on availability. If Frontz is unavailable, then another reliable drilling company will be procured. If this does not happen within two weeks, Bridgeton Landfill will notify the USEPA and MDNR.


Temperatures greater than 185° F or carbon monoxide concentrations greater than 1500

ppm in a gas extraction well; or

Temperatures greater than 200° F in a TMP.

If a TMP reading indicates a possible trigger exceedance, a verification process will be followed to ensure that the reading is a true exceedance. Additional readings will be taken to verify the exceedance. The conductance of the thermocouple string will also be checked if the exceedance is within a TMP. These confirmation checks will occur within 24 hours of the trigger finding. In addition, data associated with readings that approach trigger exceedance (within 5 degrees Fahrenheit) will also be verified and quality control checks performed within 24 hours of initial collection. The USEPA and MDNR will be notified while the initial verification process is ongoing. If a trigger is exceeded the plan defined in the Trigger Exceedance Decision Tree (Appendix D) will be followed. If the exceedance was not a true exceedance, then monitoring will continue as normal, with notification to the USEPA and MDNR. Verification and validation procedures will in no way interfere with the goal of executing the TMP or IGI work plans, nor with having drillers and equipment onsite to complete the necessary action within two weeks of initial readings indicating a trigger exceedance. When the exceedance is measured or when inferred to be within 5 degrees Fahrenheit of an exceedance, all well(s) that may be the cause of the exceedance will be shut down immediately. The Bridgeton Landfill will notify the USEPA and MDNR within 24 hours of the measured of inferred exceedance. The Bridgeton Landfill will also contact/secure drill rigs, installers and any other third-party contractors that may be needed, after the initial trigger exceedance. Gas wells will be temporarily profiled with a downhole Resistive Thermal Device (RTD) to ascertain elevated temperature regions within the triggered well and all wells within a 300-foot radius of the triggered well. These same gas wells will also be sampled monthly with a summa canister, to ascertain the CO levels. Table 1 – Planned Field Data Collection Efforts Associated with Trigger Exceedances details the planned field collection efforts associated with trigger exceedances, including the type of monitoring equipment to be used, and the frequency of the monitoring. If any of the North Quarry wells within this 300-foot radius exhibit elevated temperatures, they will also be immediately shut down. If the maximum temperature is less than 40 feet deep, the “Inert Gas Injection Work Plan for Hot Spot Remediation” will be followed. If the maximum temperature is greater than 40 feet deep, U-tube heat extraction units will be installed in all gas wells within 200 feet of the trigger location, within seven business days. These U-tube heat extraction units will be used as an initial cooling effort. These will either be installed by the Bridgeton Landfill or a previously contacted installer. Three additional TMPs will be installed around the triggered TMP or gas well at a maximum distance of 50 feet from the affected element and at a 120-degree spacing, in order to initially ascertain horizontal orientation of the elevated temperature readings. The new TMPs will be installed to a depth equal to 20 feet below the suspected elevated interval. Supplies for three TMPs will be stored at the Bridgeton Landfill (assuming a depth of 180 feet and a spacing of 20 vertical feet between thermocouples), such that the only scheduling limitation for installation of the TMPs should be driller availability. However, it is anticipated that the three additional TMPs could be installed within two weeks of a trigger exceedance, subject to drill rig availability2. If the sonic drill rig is not available within the two week time frame, other methods may be considered.

2 Bridgeton Landfill has a relationship with Frontz Drilling, Inc. and will be using them dependent on availability. If Frontz is unavailable, then another reliable drilling company will be procured. If this does not happen within two weeks, Bridgeton Landfill will notify the USEPA and MDNR.


However, the location and depth of the additional TMPs will also need to be considered. If it is best to use the sonic drill rig and it cannot be procured within two weeks, Bridgeton Landfill will seek an extension of time from the USEPA and MDNR. As-built documentation of the newly installed TMPs will be submitted to the USEPA/MDNR within 30 days of installation. Also to be installed are three combined heat extraction/injection wells. These three wells will be installed at a maximum distance of 50 feet from the affected element, at 120-degree spacing offset 60 degrees from the newly installed TMPs. The injection points will be installed above the leachate level. (Leachate level will be predetermined by performing depth to leachate measurement). The combined heat extraction/injection wells will allow inert gas to be injected at no greater pressure than 0.4 psi/vertical foot. Temperature and pressure ports will be installed in the combined heat extraction/injection wells in order to ascertain pressure and temperature at the wellhead of the newly installed unit. A perforated venting pipe will also be installed to relieve excess inert gas pressure and thereby preventing fracturing of the waste confining layer. After a time delay based on temperature readings, the activation of a cooling element will take place. The combined heat extraction/injection well will also be installed within two weeks of a trigger exceedance, subject to drill rig availability.3 Bridgeton Landfill will monitor the heat extraction system, and routinely provide data (weekly basis or more frequently as needed) and appropriate notifications to the USEPA and MDNR once the condition has been controlled. The condition is controlled if there is no additional lateral migration of heat, and temperatures have fallen below the exceedance levels. If the data and field observations indicate that the heat extraction system is not adequately addressing the condition, other remedial actions will be considered based upon consultation with the USEPA and MDNR. As-built documentation of the newly installed combined heat extraction/injection wells will be submitted to the USEPA/MDNR within 30 days of installation. Once the spatial orientation and temperature profile of the affected area is determined, remedial and/or management plans and schedules will be submitted to the USEPA and the MDNR in the form of a work plan. This work plan will provide for the design and installation of additional heat extraction units after the initial three TMPs and three combined heat extraction/injection wells are installed and monitored for a period of one month. It is envisioned that the heat extraction unit locations and depths will be based upon the information provided by the installed TMPs. Thermal modeling may be used to help develop an understanding of the thermal gradients and heat extraction unit efficacy. Criteria for expanding, modifying, or terminating heat extraction devices will be contained in the work plan. 5.0 REPORTING OF DATA Following quality control review, the weekly TMP data and temperature vs. depth graphs will be submitted to the USEPA and MDNR weekly on a one week offset (i.e., each week the previous week’s data will be submitted). An example of this submittal with the latest available TMP readings for the North Quarry TMPs (May 9, 2016) is presented in Appendix B. Each weekly report will be prepared describing the existing North Quarry TMPs and the newly proposed North Quarry TMPs. This report will summarize the data, describe TMP operation and maintenance, and discuss any non-conforming TMP intervals. The report format will consist of:

3 Bridgeton Landfill has a relationship with Frontz Drilling, Inc. and will be using them dependent on availability. If Frontz is unavailable, then another reliable drilling company will be procured. If this does not happen within two weeks, Bridgeton Landfill will notify the USEPA and MDNR.


• Cover letter that summarizes the report contents and explains any unusual conditions or occurrences;

• Data summaries;

• Electronic deliverable of data in accordance with ASAOC paragraph 38b;

• Equipment maintenance and performance; and

• Results and proposed future activity.

The weekly report will be due the Friday of the following week and uploaded to the Bridgeton data portal shared with the USEPA and the MDNR. 6.0 IMPLEMENTATION SCHEDULE Once the North Quarry Subsurface TMP Work Plan is approved by the USEPA, the 17 additional North Quarry TMPs and the two additional Neck Area TMPs will be installed based upon the schedule presented below. (As of revision 4 submitted August 4, 2017, the 17 additional North Quarry TMPs and the two additional Neck Area TMPs have been installed.) The thermocouple and the surface measuring infrastructure parts require a lead time of approximately eight weeks for delivery. During that time, drilling can be coordinated and drilling pads constructed. The schedule presented below is highly dependent upon the availability of a drilling team with prior history of TMP installation:

• USEPA approval of North Quarry Subsurface TMP Work Plan – start construction phase. To be integrated with installation of Heat Extraction Barrier project construction.

• Order thermocouple and surface measuring infrastructure – approximately 8 weeks

• Build drilling pads – approximately 4 weeks (can be completed concurrently with part order)

• Driller availability – to be determined based upon the date of USEPA approval

• TMP Installation (drilling and surface termination completion) – approximately 4 weeks.

• TMP calibration and normalization – 1 week

It is strongly suggested that installation of the initial TMPs be completed before any additional EVOH capping in the TMP work areas.


7.0 REFERENCES Omega, 2016, Revised Thermocouple Reference Tables Type T

http://www.omega.com/temperature/Z/pdf/z223.pdf Omega, 2016, Thermocouples – Using Thermocouples to Measure Temperature

http://www.omega.com/prodinfo/thermocouples.html SCS Engineers, 2016, Inert Gas Injection Plan for Hot Spot Remediation, Revised May 20 USEPA, 2016. Administrative Settlement Agreement and Order on Consent for Removal Actions

– West Lake Landfill Superfund Site. CERCLA Docket No. 07-2016-0005. United States Environmental Protection Agency. April.

http://www.omega.com/temperature/Z/pdf/z223.pdf

http://www.omega.com/prodinfo/thermocouples.html

Table 1 Planned Field Collection Efforts Associated with Trigger Exceedances

Table 1 – Planned Field Data Collection Efforts Associated with Trigger Exceedances

*Monitoring will be conducted within 300 feet of affected trigger well/TMP in the North Quarry

Type of Monitoring Equipment to be used Frequency of Monitoring

Downhole Temperature Profile (°F)

EPG Resistive Thermal Device (RTD) or equivalent

Weekly

Initial Wellhead Temperature (°F)

Elkins Earthwork Envision meter or equivalent

Daily

Initial Flow (SCFs) Elkins Earthwork Envision meter or equivalent

Daily

Methane (% vol) Elkins Earthwork Envision meter or equivalent

Daily

Oxygen (% vol) Elkins Earthwork Envision meter or equivalent

Daily

Carbon Dioxide (% vol) Elkins Earthwork Envision meter or equivalent

Daily

Balance Gas (% vol) Elkins Earthwork Envision meter or equivalent

Daily

Appendix A Additional North Quarry TMP Drawings

INDEX OF DRAWINGS

TITLE PAGE001

003 TMP ALIGNMENT PLAN VIEW

004

DETAILS

SEPTEMBER 2016

PREPARED FOR:

BRIDGETON LANDFILL, LLC.

DESIGN DRAWINGS FOR

SEVENTEEN ADDITIONAL

AND TWO REPLACEMENT

TEMPERATURE

MONITORING PROBE

INSTALLATION IN

NORTH QUARRY

BRIDGETON LANDFILL

BRIDGETON, ST. LOUIS COUNTY, MISSOURI

3377 HOLLENBERG DRIVE

BRIDGETON, MO 63044

TEL. (217) 836-8842

FULL SITE PLAN VIEW002

005

TMP ALIGNMENT PROFILE VIEW

Engineering for a Better World

FEEZOR ENGINEERING, INC.

LEGEND

OU2

OU2

OU2

OU2

OU2

OU2

OU2

OU2OU2OU2

OU2

X

X

X

X

X

X

X

X

X

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X

X

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X

X

X

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X

X

X

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X

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X

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X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

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X

X

XX

X

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X

X

X

X

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X

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X

X

X

X

X

X

X

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X

X

X

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X

X

X

XX

X

X

X

X

X

X

X

X

X

X

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X

X

X

X

X

X

X

X

OU1

OU1

OU1

OU1

OU1

OU1

OU1

OU1

OU1

Q

Q

Q

Q

QQ

Q

N 1,068,500

E 516,000

E 516,500

E 517,000

E 517,500

E 518,000

N 1,069,000

N 1,069,500

N 1,070,000

N 1,070,500

N 1,071,000

N 1,071,500

N 1,065,500

N 1,066,000

N 1,066,500

N 1,067,000

N 1,067,500

N 1,068,000

E 514,000

E 514,500

E 515,000

E 515,500

N 1,068,500

N 1,069,000

N 1,069,500

N 1,070,000

N 1,070,500

N 1,071,000

N 1,071,500

N 1,065,500

N 1,066,000

N 1,066,500

N 1,067,000

N 1,067,500

N 1,068,000

E 516,000

E 514,000

E 514,500

E 515,000

E 515,500

E 516,500

E 517,000

E 517,500

BRIDGETON LANDFILL, LLC

13570 ST. CHARLES ROCK ROAD

BRIDGETON, MISSOURI 63044

BRIDGETON LANDFILL

NORTH QUARRY AOC

NEW TEMPERATURE

MONITORING PROBES

DRAWING NO.:

APPROVED BY: DRF

SEPTEMBER 2016

REVISION DATEPROJECT NUMBER: BT-121 FILE PATH:

FEEZOR

FULL SITE PLAN VIEW

E:\Dropbox (Feezor Engineering)\Bridgeton\BT-113 task - action plan figure 1\Additional TMP drawings\working\Draft Drawings\BT-113-002 (Site Plan).dwg

002

DESIGNED BY: IN

Feet

0 200 400

CLOSED

DEMOLITION

LANDFILL

WEST

LAKE

OU1(2)

WEST LAKE OU2

SOUTH

QUARRY

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DEMOLITION LANDFILL AREA

- - - -

Engineering for a Better World ---+---I

003

TMP ALIGNMENT PLAN VIEW

D:\Dropbox\BT-113 Task - Action Plan Figure 3\Additional TMP Drawings\working\Draft Drawings\BT-113-003 (TMP Alignment And Profile View).dwg

DESIGNED BY: IN

500

LEGEND

Feet

0 50 100

NOTES:

AERIAL TOPOGRAPHY PROVIDED BY COOPER AERIAL SURVEYS, INC. AND IS DATED FEBRUARY 27, 2016.

LOCATIONS OF THE PROPOSED TMPS MAY BE MODIFIED TO AVOID CONFLICT WITH NORTH QUARRY

INFRASTRUCTURE. ALL FIELD MODIFICATIONS WILL HAVE APPROVAL FROM THE EPA'S ON-SCENE COORDINATOR

BEFORE TMP INSTALLATION OCCURS




BRIDGETON LANDFILL

NORTH QUARRY AOC

NEW TEMPERATURE

MONITORING PROBES

DRAWING NO.:

APPROVED BY: DRF

SEPTEMBER 2016


FEEZOR

C]

13A

GEW-162

T P-3 TMP-5-5S

GIW-6

GEW-15

'D GEW-108

TMP-7R ffi GEW-37

EW-107

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' ffiGEW-49

.6. LCS-6B

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0

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GC~-~,, G

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- - - - - QUARRY HIGHWALL

-$- TMP-33

@TMP-6

BASE TOPOGRAPHY (2' CONTOUR)

BASE TOPOGRAPHY (10' CONTOUR)

APPROXIMATE ESTIMATE OF RIM EXTENT

NEW TEMPERATURE MONITORING PROBE (TMP)

EXISTING TEMPERATURE MONITORING PROBE (]MP)

'.I) GEW-6 EXISTING LFG EXTRACTION WELL (GEW)

~ GEW-15 REPLACED LFG EXTRACTION WELL (GEW)

~ GEW-17 PROPOSED LFG EXTRACTION WELL (GEW)

• GIW-17 EXISTING GAS INTERCEPTOR WELL (GIW)

/l LCS-6B EXISTING LEACHATE COLLECTION SUMP (LCS-5 AND 6)

18) GCPT 14-2 AREA 1 SOIL BORING

Enginearing for a Beiter World --+---<

Profile View of Alignment A Vertical Exaggeration x2

290

300

310

320

330

340

350

360

370

380

390

400

410

420

430

440

450

460

470

480

490

500

510

520

530

540

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560

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580

590

290

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400

410

420

430

440

450

460

470

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490

500

510

520

530

540

550

560

570

580

590

-0+50 0+00 1+00 2+00 3+00 4+00 5+00 6+00 7+00 8+00 9+00 10+00 11+00 11+50

TM

P-36

TM

P-37

TM

P-38

TM

P-39

TM

P-40

TM

P-41

TM

P-42

TM

P-43

TM

P-44

Profile View of Alignment B Vertical Exaggeration x2

370

380

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400

410

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440

450

460

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510

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580

-0+50 0+00 1+00 2+00 3+00 4+00 5+00 6+00 7+00 8+00 9+00 10+00 11+00 12+00 13+00 14+00 14+50

TM

P-36

TM

P-37

TM

P-38

TM

P-39

TM

P-40

TM

P-41

TM

P-42

TM

P-43

TM

P-45

TM

P-46

TM

P-47

TM

P-48

TM

P-49

004

TMP ALIGNMENT AND PROFILE VIEW

E:\Dropbox (Feezor Engineering)\Bridgeton\BT-113 Task - Action Plan Figure 1\Additional TMP Drawings\working\Draft Drawings\BT-113-003 (TMP Alignment And Profile View).dwg

DESIGNED BY: IN

500

LEGEND

NOTES:

AERIAL TOPOGRAPHY PROVIDED BY COOPER AERIAL SURVEYS, INC. AND IS DATED FEBRUARY 27, 2016.

LOCATIONS OF THE PROPOSED TMPS MAY BE MODIFIED TO AVOID CONFLICT WITH NORTH QUARRY

INFRASTRUCTURE. ALL FIELD MODIFICATIONS WILL HAVE APPROVAL FROM THE EPA'S ON-SCENE COORDINATOR

BEFORE TMP INSTALLATION OCCURS




BRIDGETON LANDFILL

NORTH QUARRY AOC

NEW TEMPERATURE

MONITORING PROBES

DRAWING NO.:

APPROVED BY: DRF

SEPTEMBER 2016


FEEZOR

Feet

0 100 200

' ' ' ' ' '

+

+

:~

+

+ /

:~ ~

./ _,,,,,, +

+

:~

+

+

+

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+

+

' ' ' ' ' '

TMP Northing Easting Surface Bottom Qua rry Approx. waste number Elevation Elevation thickness (feet)

33 1,068,657.31 516,084.47 497.02 424.92 72.09 34 1,068,678.62 516,168.34 512.03 424.94 87. 10 35 1,068,769.67 516,259.38 518.72 424.82 93.90 --

36 1,068,558. 13 516,040.68 476.36 442.81 33.55 --

37 1,068,552.43 516,122.18 497.01 440.80 56.21 38 1,068,550.51 516,203.86 515.89 436.57 79.31

I

/ --

39 1,068,574.58 516,281.93 520.60 436.03 84.57 ./' 40 1,068,638.81 516,333.44 522.07 437.71 84.35 -- /' 41 1,068,703.87 516,381.51 533.60 433.81 99.79 -

42 1,068,774.67 516,422.28 517.91 438.10 79.81 -- "' ./

43 1,068,799.39 516,493.23 514.07 404.54 109.52 --

44 1,068,760.03 516,640.22 510.55 315.62 194.94 ~

45 1,068,969. 12 516,538.14 479.16 431.70 47.46 --

46 1,069,024.86 516,608.81 477.73 415.47 62.25 --

47 1,069,081.54 516,678.70 476.00 414.38 61.62 48 1,069,137.87 516,748.86 473.15 399.94 73.21 --

49 1,069,192.39 516,820.47 470.47 401.35 69. 12 2R 1,067,913.00 516,343.00 493.25 240.00 253.25 --

' ' ' ' ' '

11R 1,067,909.37 516,261.40 468.00 340.00 128.00 ' ' ' ' ' '

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-- - EXISTING SOLID WASTE PERMIT BOUNDARY

- - - - - QUARRY HIGHWALL

---- EXISTING EVOH CAP BOUDARY

• - - - • NORTH QUARRY EVOH COVER LIMITS - PHASE 1A CAP

• - - - • NORTHQUARRYEVOHCOVERLIMITS-PHASE1BCAP

• - - - • NORTH QUARRY EVOH COVER LIMITS - PHASE 2 CAP

• - - - • NORTH QUARRY EVOH COVER LIMITS - PHASE 3 CAP

---- BASE TOPOGRAPHY (2 CONTOUR)

-- BASE TOPOGRAPHY (10' CONTOUR)

APPROXIMATE ESTIMATE OF RIM EXTENT

-$- TMP-33 NEW TEMPERATURE MONITORING PROBE (TMP)

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+

+

' / +

/ / +

I I "fl;;; / + ...

I -...... I_/\ • - + -

+ ' ' ' ' ' ' ' '

Enginearing for a Beiter World ----+---<

NTS

TEMPERATURE MONITORING PROBE (TMP)

005

1

FIBERGLASS SUPPORT ROD

3/4" CPVC UNDERGROUND PROTECTIVE CASING

(SCHEDULE 80, 20' LENGTH BELOW GROUND)

4" DIA.

BOREHOLE

3/4" ID PYROJACKET ABRASIVE SHEATH

(STOPS APPROXIMATELY 20' BELOW GROUND SURFACE)

THERMOCOUPLES TYPE T

20 GAUGE TEFLON COATED WIRE WITH

HERMETICALLY SEALED TIPS

CEMENT BENTONITE GROUT

ELECTRICAL TIES @ 10' C-C

3/4" 316 SS BARBED HOSE FITTING X NTP MALE PIPE W/

316 SS LOW-PROFILE HOSE CLAMP

NOTES:

1.) SWITCH BOX IS SAGINAW CONTROL & ENGINEERING ENCLOSURE 1210ELJ - PANEL IS

SCE-12P10J WITH JIC SWING OUT PANEL KIT - MOUNTED WITH HINGE ON RIGHT.

2.) HOLE FOR ROTARY SWITCH TO ACCOMODATE SW142G-12-B

3.) ALL PERFORATIONS AND CLAMPS NEMA 4 RATED

SUBSURFACE DETAIL

GROUND SURFACE - Gz

THERMOCOUPLE SWITCH BOX

ATTACH TO STRUT CHANNEL USING 3/8" x 1" CAP

SCREWS AND UNISTRUT NUTS W/ SPRINGS

CONDUIT SEAL

DRAINING TYPE EYD2 (3/4" FPT X 3/4" MPT

W/ CHICO SEAL COMPOUND OR EQUAL

3/4" x 6" LONG/12" LONG 316 SS

PIPE NIPPLE W/ SEAL AT BOX PENETRATION

CROUSE-HINDS FIBERGLASS ENCLOSURE

PART NUMBER FSJS100804

2'x3'x4" CONCRETE BASE W/ 3" HOLE IN CENTER

W/ POST BASES FOR STRUT

CHANNEL ANCHORED WITH 1/4" x 2 1/2" RED HEAD

WEDGE ANCHORS

UNI-STRUT CROSS BRACE TO MOUNT

FIBERGLASS ENCLOSURE

GROUND SURFACE

3/4" CPVC SCH 80 CASING W/

SEAL AT BOX PENETRATION

REMOVE OUTER TEFLON SLEEVE FROM THERMOCOUPLE

WIRE INSIDE FIBERGLASS ENCLOSURE. RUN INTERNAL THERMOCOUPLE

WIRES W/ SLEEVE TO CORRESPONDING CONNECTION ON SELECTOR SWITCH

INSTALL EVOH LINER BOOT W/

316 SS LOW-PROFILE CLAMP

(TMP-16 ONLY)

SURFACE DETAIL

VARIES

SEE SURFACE DETAIL

ZERO LINE - Zz

t/c 1

t/c 2

t/c 3

t/c 4

t/c 12

1/4" WEEP HOLE

(TO VENT)

005

DETAILS

DESIGNED BY: IN




BRIDGETON LANDFILL

NORTH QUARRY AOC

NEW TEMPERATURE

MONITORING PROBES

DRAWING NO.:

APPROVED BY: DRF

SEPTEMBER 2016


FEEZOR

- I I I ,,-11-111-11- - 1 11-

s

'

TMP T/C 1 Depth T/C 2 Depth T/C 3 Depth T/C 4 Depth number (feet) (feet) (feet) (feet)

33 20 40 53 34 20 40 50 63 35 20 40 60 70 36 15 20 30 37 20 40 50 38 20 40 60 70 39 20 40 60 80 40 20 40 60 80 41 20 40 60 80 42 20 40 60 78 43 20 40 60 80 44 20 40 60 80 45 15 30 45 46 20 40 60 47 20 40 60 48 20 40 60 72 49 20 40 60 2R 20 40 60 80 11 R 20 40 60 80

I I

T/C 5 Depth T/C 6 Depth T/C 7 Depth T/C 8 Depth (feet) (feet) (feet) (feet)

98

100 100 120 140 160

100 120 140 160 100 120

T/C 9 Depth (feet)

180

180

---~

----- -~r-------111 Ill Ill Ill Ill Ill Ill II Ill Ill Ill ----- -~,----7--111 I Ill

----- -~,---- --

Ill ' Ill Ill ,, Ill ' Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill 111 ~-----111

-,_ Ill '-,,,, 111

Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill ,;' Ill Ill '-' Ill ' I

Enginearing for a Beiter World ---------0

Appendix B Current TMP Readings as of May 9, 2016 and Notes

60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATIO

N(F

T) LEGEND11/26/1204/12/1604/18/1604/26/1605/02/1605/09/16

TEMPERATURE VS DEPTHBRIDGETON LANDFILL

Notes for TMPs are summarized at the end of the TMP figures.

60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATIO

N(F

T) LEGEND11/26/1204/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATIO

N(F

T) LEGEND11/26/1204/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND02/11/1504/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND11/26/201204/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND02/11/1504/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATIO

N(F

T) LEGEND11/26/1204/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND11/26/201204/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND4/6/1304/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND4/6/1304/12/1604/18/1604/26/1605/02/1605/09/16



0 20 40 60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND9/19/1404/12/1604/18/1604/26/1605/02/1605/09/16


60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND8/31/1404/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND8/31/1404/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND8/31/1404/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND01/28/1504/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND01/28/1504/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND01/28/1504/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND01/28/1504/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND01/28/1504/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND01/28/1504/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND01/28/1504/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND01/28/1504/12/1604/18/1604/26/1605/02/1605/09/16



60 80 100 120 140 160 180 200 220 240 260 280 300TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGEND01/28/1504/12/1604/18/1604/26/1605/02/1605/09/16




60 80 100 120 140 160 180 200 220 240 260 280 300 320TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

LATI

ON

(FT)

LEGENDTMP-1TMP-2TMP-3TMP-3RTMP-4TMP-4RTMP-6TMP-9TMP-10TMP-11TMP-14R


TEMPERATURE VS ELEVATIONBRIDGETON LANDFILL

60 80 100 120 140 160 180 200 220 240 260 280 300 320TEMPERATURE (oF)

240

260

280

300

320

340

360

380

400

420

440

460

480

500

ELE

VA

TIO

N (M

SL

- FT)

240

260

280

300

320

340

360

380

400

420

440

460

480

500

ELE

VA

TIO

N (M

SL,

FT)

LEGENDTMP-1TMP-2TMP-3TMP-3RTMP-4TMP-4RTMP-6TMP-9TMP-10TMP-11TMP-14R



60 80 100 120 140 160 180 200 220 240 260 280 300 320TEMPERATURE (oF)

260

240

220

200

180

160

140

120

100

80

60

40

20

0

DE

PTH

AT

INS

TALL

ATI

ON

(FT)

LEGENDTMP-16TMP-17TMP-18TMP-21TMP-22TMP-23TMP-24TMP-25TMP-26TMP-27TMP-28TMP-29


TEMPERATURE VS ELEVATIONBRIDGETON LANDFILL

60 80 100 120 140 160 180 200 220 240 260 280 300 320TEMPERATURE (oF)

240

260

280

300

320

340

360

380

400

420

440

460

480

500

ELE

VA

TIO

N (M

SL

- FT)

240

260

280

300

320

340

360

380

400

420

440

460

480

500

ELE

VA

TIO

N (M

SL,

FT)

LEGENDTMP-16TMP-17TMP-18TMP-21TMP-22TMP-23TMP-24TMP-25TMP-26TMP-27TMP-28TMP-29


Reading Date 5/9/16 Bridgeton TMP Notes Page 1 of 5

TMP BRIDGETON LANDFILL NOTES

TMP‐1:

1. No reliable temperature readings at 138 ft depth from 8/1/2014 to 3/24/2015. 2. No reliable temperature readings at 78 ft depth from 8/13/2014 to 3/24/2015. 3. No reliable temperature readings at 38 ft depth from 8/2/2014 to 3/24/2015.

TMP‐2:

1. Unit at 180 ft depth had resistance reading above allowable and is no longer working. No reliable reading has been obtained since 11/26/2012.

2. The resistance reading was high and no temperature readings were obtained at 160 ft depth since 6/19/2014.

3. Unit at 120 ft depth had high resistance readings that were fluctuating on 10/22/14 & from 11/5‐12/6/2014 and on 12/16/2014.

4. Unit at 60 ft depth had fluctuating high resistance readings from 11/12/14 – 12/6/14 and no resistance reading between 2/11/2015 and 2/25/15, therefore the temperatures are unreliable during those dates.

5. The conductivity tests on 3/19/15 conducted by Feezor Engineering showed that units at 20’, 40’, 80’, 100’, 140’ are no longer reliable.

TMP‐3:

1. No reliable temperature readings have been obtained at 170' depth since 1/29/2014, except on 3/13/2014.

2. The conductivity tests on 4/11/14 conducted by CEC showed that units at 10', 90', 130’, 210' and 250' are no longer reliable.

3. No reliable temperature readings were obtained at 230' depth from 8/01/2014 – 12/6/14 and 2/11/15 – 2/25/15.

4. No reliable temperature readings were obtained at 190' depth from 9/12 to 10/17/14, from 11/5 to 11/26/14 and on 12/16/14.

5. The conductivity tests on 10/28/14 conducted by Feezor Engineering showed that units at 10', 90', 110', 130', 210' and 250' are not reliable.

6. The unit at 150' no temperature or unreliable readings between 9/12/14 and 3/3/15. 7. The unit at 230' had unreliable or no readings from 10/22/‐12/6/2014, between 2/11/15 –

2/25/15. 8. The unit at 190' had unreliable or no readings from 12/16/14 – 2/17/15.

TMP‐3R: NONE

TMP‐4:

1. The conductivity tests on 4/11/14 conducted by CEC showed that the unit at 48' depth is no longer reliable.


TMP‐4R: NONE

TMP‐5: TMP NO LONGER IN SERVICE– Verified by Conductivity testing by Feezor Engineering in March 2015.

TMP‐6:

1. Unit at 195 ft depth had a resistance reading above acceptable on 11/20/2013. 2. Unit at 155 and depth had resistance readings above acceptable since 3/19/2014. No

temperature readings were obtained. 3. Units at 195 ft depths had resistance readings above acceptable and no temperature readings

obtained from 3/19/2014 to 4/11/2014. 4. The conductivity tests on 4/11/14 conducted by CEC showed that units at 35', 55', 75', 155',

175', and 195' depths are no longer reliable. 5. No reliable temperature readings were obtained at the unit at 95' on 5/13/14, 5/28‐7/2/14,

10/1‐10/8/14, 10/22/14, 11/12‐12/6/14, 1/14/15 & 2/4/15–4/7/15. The temperatures between 12/16/14‐1/8/15 are questionable due to high/fluctuating resistivity.

6. No reliable temperature readings were obtained at the 15' unit on 5/28‐6/13/14, 6/25/14, 8/1‐9/2/14, 10/1‐10/8/14, 11/19‐12/6/14, 1/2/15, & between 1/28/15 – 3/18/15. The temperature obtained on 12/16/14 is questionable due to high resistivity.

7. No reliable temperature readings were obtained at the unit at 215' since 6/13/14.

TMP‐7R: TMP NO LONGER IN SERVICE

TMP‐8:

1. Lines connecting data over distance of > 40' are to identify the data set and should not be used for temperature estimation.

2. The presented TMP readings represent the thermocouples that were operational on those dates.

3. No acceptable readings were obtained between 7/25/13 to 10/10/13. 4. Acceptable readings were obtained resuming on 10/16/13 from 20' to 80' depths. 5. Resistance of the unit at 80' indicates the reading is not reliable since 12/04/13. 6. The conductivity tests on 10/28/14 conducted by Feezor Engineering showed that units at 40'

and 60' are not reliable. 7. A conductivity test conducted by Feezor Engineering showed that the unit at 20’ is not reliable

on 9/9/15.

TMP‐9:

1. All units had resistivity readings higher than acceptable levels on 7/3, 7/18, 7/25, 8/14, 8/20, 8/27, and 9/3/2013. Values shown on and between those dates are for informational purposes and should not be considered reliable. Resistivity readings since 9/11/2013 were acceptable for all units except 100'.


2. Unit at 100' depth had an inaccurate temperature reading on 8/1/2013 and no reading since 8/6/2013.

3. Unit at 80' depth had a high resistivity and no temperature readings on 4/1/2014. 4. The conductivity tests on 4/11/14 conducted by CEC showed that units at 20', 60', 80', and 100'

depths are no longer reliable. 5. Unit at 40' depth had a resistance lower than credible on 11/12/14. The unit requires

assessment. 6. Unit at 40' depth had a resistance which is fluctuating from week to week between 11/19 &

11/26/14. The readings are considered unreliable during that time.

TMP‐10:

1. Resistance readings for 7/18 and 7/25/2013 were acceptable; however the temperature readings appear inaccurate. This issue appears to be resolved as of the 8/1/2013 readings.

2. No reliable temperature reading was obtained at 113’ depth between 3/3/15 and 3/18/15.

TMP‐11:

1. None of the units had acceptable resistivity readings on 7/3/2013. The units at TMP‐11 were subsequently re‐read on 7/8/2013. Resistance readings for 7/8/2013 were acceptable.

2. All units had resistivity readings higher than acceptable levels on 7/18/2013. Values shown for that date are for informational purposes and should not be considered reliable.

3. All units had acceptable resistance readings starting on 7/25/13, except a high resistance reading at 116' depth since 10/30/13.

4. No temperature reading was obtained at 176' since 1/17/2014. 5. The unit at 156' depth had high or questionable resistance since 1/17/14. No temperatures

were obtained between 1/17/14 and 5/13/14, on 6/19/14, between 8/13/14 and 10/17/2014, and since 2/11/15. Readings were either not obtained or deemed unreliable between 8/13/14 and 3/31/15, except for on 10/22/14 and 12/10/14.

6. The unit at 56' depth had a high resistance reading since 3/19/14 & no temperatures were obtained.

7. The conductivity tests on 4/11/14 conducted by CEC showed that units at 56', 116', and 176' depths are no longer reliable.

8. No temperature was obtained on 6/25/14 at 216' depth. 9. The conductivity tests on 10/28/14 conducted by Feezor Engineering showed that units at 56',

116' and 176' are not reliable. 10. The Unit at 76' depth had either no readings or unreasonable readings between 11/12 &

12/6/14, 12/24/14, on 1/14/15, on 2/17/15 and from 3/10/15 – 3/31/15. 11. The Unit at 16' depth had either no readings or unreasonable readings between 11/19 &

12/6/14 and 12/16/14 – 1/28/15. 12. The Units at 196’ and 216’ had high resistance readings since 4/26/16 and the temperature was

unreliable.


TMP‐12:

1. All units were verified by Conductivity testing by Feezor Engineering in October 2015 to be unreliable.

TMP‐13: TMP NO LONGER IN SERVICE

TMP‐14:

1. All units were verified by Conductivity testing by Feezor Engineering in March 2016 to be unreliable.

TMP‐14R:

1. Due to the Conductivity test results by Feezor Engineering on TMP‐14 (see note above), TMP‐14R is added to this reporting data set as of 3/7/16.

TMP‐15: TMP WAS NEVER IN SERVICE

TMP‐16:

1. A conductivity test conducted by Feezor Engineering showed that the units on TMP‐16 may not be reliable since 9/9/15. Further testing at the end of September 2015 showed possible connectivity on some of the units. The resistivity and temperatures will continue to be monitored.

2. The unit at 153 ft depth had a low resistance reading and unreliable temperature since 12/21/15.

TMP‐17: NONE

TMP‐18: NONE

TMP‐19: NOT PART OF THIS SUBMITTAL (HEAT EXTRACTION TMP)

TMP‐20: NOT PART OF THIS SUBMITTAL (HEAT EXTRACTION TMP)

TMP‐21: NONE

TMP‐22: NONE

TMP‐23: NONE

TMP‐24: NONE

TMP‐25: NONE

TMP‐26: NONE

TMP‐27: NONE


TMP‐28:

1. The unit at 217 ft depth has had no resistance or temperature readings since installation.

TMP‐29: NONE

TMP vs DEPTH and TMP vs ELEVATION (for 5/9/16):

1. There were no reliable temperature readings for TMP‐13 since 3/19/2014. 2. There were no reliable temperature readings for TMP‐7R, as determined by the conductivity

test on 4/11/14. 3. There were no reliable temperature readings for TMP‐5 from 7/17‐9/2/2014 and since

11/5/14. 4. There were no reliable temperature readings for TMP‐9 from 11/19 ‐ 12/26/2014. 5. There were no reliable temperature readings for TMP‐12 from 11/19/2014 – 3/31/15, except

2/4/15. There were no reliable temperature readings for TMP‐12 since 9/28/15. 6. There were no reliable temperature readings for TMP‐8 since 9/9/15. 7. There were no reliable temperature readings for TMP‐14, confirmed since 3/7/16.

Appendix C Auxier and Associates (A&A) Radiological Scanning Procedures

Procedure 2.7 Effective Date: 03/02/98 Revision No: 1 Page 1 of 3

PROCEDURE 2.7

MONITORING PERSONNEL AND EQUIPMENT FOR RADIOACTIVE CONTAMINATION

1.0 PURPOSE

1.1 To describe the general approach for monitoring personnel and equipment for radioactive contamination.

2.0 RESPONSIBILITIES

2.1 The Site Survey Manager is responsible for assuring that this procedure is implemented.

2.2 Survey team members are responsible for following this procedure.

3.0 PROCEDURE

3.1 Upon exiting potentially contaminated areas, monitoring of clothing and exposed skin surfaces will be performed. Equipment and materials will also be monitored and shown to be free of contamination before release for use without radiological restrictions or controls.

3.2 Equipment

3.2.1 Ratemeter-scaler: Model 3 or Model 2221, Ludlum Measurements, Inc.;

or equivalent, equipped with audible speaker or headphones.

3.2.2 Detector: Selected detectors are indicated below. Equivalent detectors are also acceptable.

Activity

Detector Type

Model

Alpha

ZnS scintillator

Ludlum 43-1 or 43-5, Eberline AC3-7 or AC3-8

Gas proportional

Ludlum 43-68, Ludlum 239-1

Beta

Gas proportional

Ludlum 43-68, Ludlum 239-1

Geiger-Mueller

Ludlum 44-9, Eberline HP-260


3.2.3 Instrument cables

3.2.4 Check sources

3.2.5 Record Forms and/or field logbook

3.3 Quality Control Check

Assemble instrument, turn on, check battery, and adjust high voltage and

threshold, if necessary. Check background and source responses following Procedure 2.1.

3.4 Surface Scanning

3.4.1 Headphones or other audible signal operating modes are used for scanning.

3.4.2 Set the instrument response for "FAST", response where possible.

3.4.3 Pass the detector slowly over the surface. The detector should be kept as

close to the surface as conditions allow. The speed of detector movement will vary depending upon the radionuclide of concern and the experience of the surveyor. While scanning for alpha or beta activity, the detector is typically moved about one detector width per second.

3.4.3 Note increases in count rate as indicated by the audible meter output.

Identifiable increases in the audible response suggest possible contamination and should be resurveyed at a slower rate to confirm findings.

3.5 Personnel Monitoring

3.5.1 When monitoring for skin or clothing contamination, give particular attention to the hands, shoes, pant and shirt cuffs, knees, and other surfaces which have a high likelihood of contamination.

3.5.2 If there is detectable contamination, it should be removed as directed by

the Health and Safety Committee (HSC) Chairperson. Decontamination guidance will be provided in the Survey Work Plan. The Site Safety Officer will implement decontamination or other contamination control actions at the project site.

3.6 Equipment Monitoring


3.6.1 For equipment surveys, attention should be given to monitoring cracks,

openings, joints, and other areas where contamination might accumulate.

3.6.2 Measure levels of total and removable surface contamination (see Procedures 2.3 and 3.6) at locations of elevated direct radiation identified by the scan and at additional representative surface locations.

3.6.3 Acceptable surface contamination levels will be established on a project-

specific basis, with details, including decontamination instructions, provided in the Survey Work Plan.

3.7 Document results of contamination surveys in field records

Procedure 2.3Effective Date: 03/02/98Revision No: 1Page 1 of 3

PROCEDURE 2.3DIRECT RADIATION MEASUREMENT

1.0 PURPOSE

1.1 To describe the method for measuring total alpha and beta radiation levels on equipment and building surfaces.


2.1 The Site Survey Manager is responsible for assuring that this procedure is implemented.


3.0 PROCEDURE

3.1 Equipment

3.1.1 Ratemeter-scaler: Model 3, Model 2220 or 2221, Ludlum Instrument Corporation; or equivalent

3.1.2 Detector: Selected detectors are listed below: Equivalent detectors are also acceptable

Activity Detector Type Model

alpha ZnS scintillator Ludlum 43-1 or 43-5, Eberline AC3-7 or AC3-8

gas proportional Ludlum 43-68

beta Geiger-Mueller Ludlum 44-9, Eberline HP-260

gas proportional Ludlum 43-68

3.1.3 Cables

3.1.4 Check source

3.1.5 Record forms


3.2 Quality Control Check

3.2.1 Assemble instrument, turn on, check battery, and adjust high voltage and threshold, if necessary. Check background and check source responses. Follow the procedures described in Procedure 2.1.

3.3 Direct Measurement

3.3.1 When applicable, team members performing instrument checks will calculate the average and maximum "field action levels" for instrument combination based on the specific site criteria and background.

Action level (cpm) = [site criteria (dpm/100 cm2) x E x G x T] + B

T = count time (minutes)E = operating efficiency (counts/disintegration)G = geometry (total detector area (cm2)/100)

Total Area Active Area43-5 detector area = 80 cm2 60 cm2

43-1 detector area = 80 cm2 50 cm2

43-68 detector area = 126 cm2 100 cm2

44-9 detector area = 20 cm2 15.5 cm2

HP-260 detector area = 20 cm2 15.5 cm2

B = background (cpm)

A field count at or above this value indicates that further investigation in this location is necessary.

NOTE: For a particular site, the action level may be established as any activity exceeding background.

3.3.2 Select an appropriate counting time. A counting time is desired which will achieve a minimum detectable activity (see Procedure 4.2) value less than 50% of the applicable criteria. For most radionuclides a 1-minute count, using the instruments listed above, is adequate to achieve this sensitivity. For radionuclides having guidelines of 5000 dpm/100 cm2, average and 15,000 dpm/100 cm2, maximum, 0.5 minute counting times may be acceptable.


3.3.3 Place the detector face in contact with the surface to be surveyed. The detector face is typically constructed of a very thin and fragile material, so care must be exercised to avoid damage by rough surfaces or sharp objects. (Scans should have been performed, prior to this point, to identify representative locations and locations of elevated direct surface radiation for measurement.)

3.3.4 Set the meter timer switch, press the count-reset button, and accumulate the count events until the meter display indicates that the count cycle is complete.

3.3.5 Record the count and time on the appropriate record form.

3.3.6 If the location has a surface activity level above background, the area around the measurement locations should be scanned to determine the homogeneity of the measured activity level in the area. Dimensions and activity levels of inhomogeneities should be documented on the appropriate record form.

3.3.7 The surface activity may be calculated according to Procedure 4.3.

Procedure 3.6Effective Date: 12/01/94 Revision No: 0Page 1 of 2

PROCEDURE 3.6REMOVABLE ACTIVITY SAMPLING

1.0 PURPOSE

1.1 To provide guidelines for measuring removable alpha and beta radioactivity on equipment and building surfaces.


2.1 The Site Survey Manager is responsible for assuring this procedure is implemented.


3.0 PROCEDURE

3.1 Equipment and Materials

3.1.1 Smears, Mazlin wipes, filter papers (like Whatman 47 mm dia. glass fiber)or equivalent

3.1.2 Glassine or paper envelopes

3.1.3 Record forms

3.1.4 Counting equipment

3.2 Sample Collection

NOTE: Direct measurements will be completed before a smear sample is taken.

3.2.1 Grasp the smear (filter) paper by the edge, between the thumb and index finger.

3.2.2 Applying moderate pressure with two or three fingers, wipe the numbered side of the paper over approximately 100 cm2 of the surface.

3.2.3 Place the filter in an envelope.

Procedure 3.6Effective Date: 12/01/94 Revision No: 0Page 2 of 2

3.2.4. Record the smear number, site, date, location of the smear, and name of sample collector on the envelope.

3.2.5 Label and secure in accordance with Procedures 3.7 and 3.8. Record pertinent information on the Chain-of-Custody Form.

3.2.6 If the direct measurement was elevated, the smear should be monitored (procedures 2.2 and 2.3) to determine whether contaminated material was transferred to the smear. If an activity level greater than 250 cpm is detected, the smear envelope should be marked as such.

NOTE: Smears having activity levels greater than 2500 cpm should be counted using field instrumentation. Decisions regarding further analyses and method of disposal of contaminated smears will be made by the PM and SSM on a case-by-case basis.

3.3 Field Sample Measurement

3.3.1 If the object of the survey is to determine if radon or thoron daughter products or other short half-life radionuclides are present, the smears should be counted within 1-2 hours before significant decay of short-lived radionuclides has occurred.

3.3.2 If necessary, smears can be counted in the field using portable instrumentation (see Procedure 2.3).

3.3.3 Record count and counting time data on the appropriate record form.

3.3.4 Subtract the background count (determined by counting blank or unused smear) and convert net count to dpm/100 cm2, using proper time and detector efficiency values.

RSIYINGFACTOOTHERMODIF*TIONDISINTEGRA

COUNT*EFFICIENCY*)TIME(

NETCOUNT=CM100

DPM2

MIN

Appendix D

Trigger Exceedance Decision Tree

Trigger

185ºF wellhead gas temp or

1500 ppm CO in

200ºF in

Perform regular monitoring of gas wells

for temperature and CO and the TMPs

for temperature

Figure 1: Trigger Exceedance Decision Tree

Take additional readings to verify trigger exceedance within one

calendar day, while notifying the EPA/MDNR of initial exceedance.

Notify within 24 hours:

• Advance RTD Probe into all gas wells with 300’ radius of trigger location to

determine approximate temperature profile within two business days.

• Take daily field measurements as defined in Table 1 of the TMP Work Plan.

• Collect SUMMA samples on any gas wells within 300’ radius of trigger

location to determine CO levels within two business days and monthly

thereafter.

• Immediately shutdown any well(s) within 300’ radius that have elevated

temperature profiles based on RTD Probe.

Find the maximum temperature

above 40 feet and below 40 feet.

Is the overall maximum

temperature greater than 40 feet

deep?

Monitor heat extraction system and

terminate once condition is controlled

based upon consultation with the U.S.

EPA and the MDNR.

TMP Installation

• Install up to 3 TMPs 120°/ 50’ radius around

the triggered TMP/gas well

Corrective Action to Complete within 7 Days

A.) The Bridgeton Landfill will install U-Tube heat extraction

units in gas wells within 200’ of trigger location.

B.) Connect heat exchangers to cooling tower and start heat

extraction.

C.) Resume gas extraction at wells that had been shutdown.

Evaluate performance of initial corrective

actions for the remainder of the 7 days,

ensuring that temperature readings are

representative of surrounding landfill

temperatures.

Corrective Action to Continue After Initial 7 Day Response Period

Combined Heat Extraction/Injection Wells

• Obtain depth to leachate levels

• Drill 3 combined heat extraction/injection

wells 120°/50’ radius around triggered TMP/

gas well. (Install injection points above the

leachate level.)

Inject inert gas in the combined injection well

above the leachate level with no greater

pressure than 0.4 psi/vertical foot

After a time delay based upon temperature readings,

activate the cooling element in the combine heat

extraction/injection well (During or before the time delay,

run header line and connect to cooling tower)

Monitor TMP Array weekly, and Settlement and Gas Quality Data monthly.

Is the newly installed heat extraction network adequate to mitigate heat?

Corrective Action to Complete within 7 Days

A.) Schedule previously contracted driller/installer and confirm supplies

per ASAOC.

B.) Cap or repair any item identified during the physical inspection that

may be contributing to oxygen intrusion

C.) Carefully add additional cover to area that show cap integrity

issues if necessary.

D.) Subject to direct push rig availability, insert injection points into area

of SSO evidence based upon visual observations

E.) Mobilize contracted CO2 vendor.

Corrective Action to Continue after Initial 7 Day Response

Period

Evaluate performance of initial

corrective actions for the remainder of

the 7 days.

If there is no additional exceedance,

resume (continue) normal operation of

Gas Extraction System

If 4th round of gas

injection is not successful, explore

other remedial

approaches

Determine the extent of affected area

Continue to observe for visual

symptoms

and/or

Install and monitor shallow TMP

network

Install network of injection points

Inject inert gas

Injection monitoring

Performance monitoring

Is exceedance still occurring or is rebound observed?

Initial inert gas injection

• Immediately shutdown well(s) that are believed to be

the cause of the exceedance.

Additional remedial approaches will

be explored based upon consultation

with the U.S. EPA and the MDNR.

Contact/Secure within 24 hours:

Drill Rigs

Installers

Other 3rd party contractors and suppliers

YES

NO

YES

Key of acronyms

• TMPs: Temperature Monitoring Probes

• CO: Carbon Monoxide

• ASAOC: Administrative Settlement

Agreement and Order on Consent

• MDNR: Missouri Department of Natural

Resources

• USEPA: United States Environmental

Protection Agency

• RTD: Resistive Thermal Device

• CO2:: Carbon Dioxide

• PSI: Pounds per square inch

Is the exceedance verified?

• If the temperature is greater than

185ºF above and below 40 feet,

both pathways will be taken.

Frequently monitor well(s) for three

weeks

Contact EPA/MDNR within 24 hours to explain why initial exceedance wasn't verified and what actions

have been taken.

NO

YES

YES

NO NO

YES NO

NO

Documents

Email Regarding Response to EPA Comments made on July …406 East Walnut Street Chatham, IL 62629 Phone (217) 483-3118 Fax (217) 483-2356 August 4, 2017 Mr. Tom Mahler On‐Scene Coordinator