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Page5of6 <br />Letter to Mr. Join Elks & Mr. Matt Ledvina <br />RE: Revised SAA I~ydrogeologic Evaluation Report <br />Eik River Landfill, Inc. <br />A maximum spacing of 400 feet between downgradient compliance boundary <br />monitoring wells has be used for the existing landfill, It is suggested that this <br />maximum spacing be maintained for the landfill expansion. This implies that several <br />additional upper outwash monitoring wells would be included in the monitoring <br />network. <br />The outwash unit consistutes the uppermost saturated groundwater flow pathway at the <br />Site. Hydraulic head monitoring at the SDA indicates there is a downward hydraulic <br />potential between the outwash and lower outwash units. Downward flow potential is <br />not unusual for permeable units underlain blow-permeability deposits and it is not <br />indicative of actual flow direction. The weight of the evidence suggests that flow in <br />both outwash units is horizontal and that these units are not in direct hydra.L~ic <br />connection. This evidence includes LIST~~er our meeting_ However, the potential <br />does not ;however, downward migration of groundwater is not predicted due to the <br />continuous till deposit at the Site. Dif~terent hydraulic gradients between units, <br />uniformit~of the gtadients/flow field in each unit - if their were a si Z,~z ificant <br />connection it would. he reflected in the gradients. Accordingly, WMI proposes <br />routinely monitoring groundwater quality in the outwash unit. in-t~l-iir-...~~°~~* ° ~•°'°~°° ~° <br />~a°,,_,~±°,a_;K_ft,° .,t.., .,1., , .,;± ~.,h~-1 e--ice"„M°.,:~~d-tea <br />T~~„~~~d-aooard~~gl3~It should also be noted that WMI will oontinue to monitor <br />groundwater quality in residential wells west of the SDA on an annual basis. <br />The 400 foot spacing interval on the downgradient side of the existing facility was <br />largely based on the presence of the unlined, pre-subtitle D portion of the landfill. The <br />spacing of the proposed monitoring points for the SDA is nearly 400 feet but takes into <br />account the till highs that act as boundaries to groundwater flow along the west and <br />southern property lines. <br />S. Page 22, T~Vell bzstallation Schedule: The report states that the current network of <br />monitoring wells is sufficient to monitor the expansion of the fill area through Cell 20. <br />The southerly limit of fill of Cell 20 would correspond to plan station 246,100 based <br />on available engineering plans for site development. From the Conceptual <br />Hydrogeologic Model, Figure 17, a southwesterly component to groundwater flow <br />from portions of the proposed fill area is apparent. There are no monitoring wells <br />existing or planned within a reasonably close distance that would intercept these <br />groundwater flow lines. The suitability of the existing network of wells to monitor the <br />development of the site through Cell 20 is questionable. <br />The expected life of the facility is mor°e than 19 years. The total remaining life of the <br />existingpermitted landfill area and the expansion area is more than 28 years. The <br />existing and proposed monitoring wells are located at the distance roughly 200 feet <br />from the ultimate fill boundaries. The functionality of an early warning monitoring <br />system during the operational life of the site with wells located in the proposed <br />positions is questionable. The overall schedule for the placement of monitoring wells <br />in relation to the site development needs to be further evaluated. <br />