George:

Here's a statement I delivered regarding the proposed "fixes" for the Ivy Landfill mess .... go ahead & post on your site if you deem appropriate. This is an issue we should all be paying attention to, as implications in terms of dollars and environmental stewardship (or lack thereof) are huge. I'd be happy to respond to questions or comments.

Regards, Nick

Statement delivered April 17, 2001 at a public hearing in Charlottesville City Council chambers regarding Assessment of Corrective Measures, DEQ Permit Number 125, Ivy Sanitary Landfill

Nick H. Evans, PhD & Virginia Certified Professional Geologist Chairman, Thomas Jefferson Soil & Water Conservation District

The mission of the Soil & Water Conservation District is to promote informed decision-making with respect to protecting water resources, and I am here tonight to do just that.

Like it or not, the Ivy Landfill is part of the heritage of our community, and a problem for which all residents of Albemarle County and the City of Charlottesville share ownership and responsibility. We're at a critical juncture where decisions need to be made as to how to deal with this problem. These decisions are going to be based, in large part, on interpretations of technical data having to do with groundwater flow. I have examined several voluminous reports produced by Joyce Engineering Inc., consultant to RWSA: the 1996 Nature and Extent Study, the 1999 Addendum to that study, and the Assessment of Corrective Measures (ACM) of August, 2000. To me, there is a serious flaw in an assumption that is basic to these documents. The flawed assumption is that downward groundwater flow (and contaminant transport) into the deep fractured bedrock aquifer beneath the landfill is so minimal that it can be considered negligible and ignored. That bedrock aquifer is the water source for all rural county residents, landfill neighbors and elsewhere.

The bedrock aquifer beneath the landfill is made up of intersecting fractures that contain water. These fractures are geometrically complex, and depending on their orientation, groundwater movement can be very rapid in one direction, and negligible in another. It is difficult or impossible to model the subsurface fractures with enough precision to be able state with certainty just what connectivity exists, and where, with respect to the shallow, near-surface aquifers that carry landfill contaminants. We know, by virtue of domestic wells in the immediate vicinity of the landfill that are capable of producing 50 or more gallons of water per minute, that substantial groundwater flow is not only possible, but may be commonplace within the bedrock aquifer. We also have evidence of landfill contaminants within the bedrock aquifer, both in monitoring wells drilled on Ivy Landfill property, and in wells drilled on neighboring properties. The data show there is substantial probability that shallow, near surface aquifers at the landfill, which carry the three documented contaminant plumes, are in hydraulic connectivity with the deeper fractured bedrock aquifer. The data also show there is substantial probability that contaminant transport is occurring within the bedrock aquifer beyond the limits of the landfill. Any mitigation scheme that discounts or ignores possibility of contaminant transport in the bedrock aquifer, as do alternatives 1, 2 and 3 of the ACM, does not serve the long-term interests of water quality protection in our community.

Given the virtual impossibility of preventing migration of contaminants from the shallow landfill aquifer into the fractured bedrock aquifer, the starting point of any plan to clean up the mess we've made at the Ivy Landfill must be to remove and contain the contamination source(s). This means removing and properly disposing of materials in the so-called "paint pits", and cleaning up or containing the contamination in residual soils. The up-front costs of these "active" remediation strategies will be considerable. But if we do not remove the source of contamination, and proceed with "passive" remediation strategies such as presented in the ACM, we face long-term uncertainty, and enormous collective liability for replacing domestic water supplies that could become contaminated at any time. It would be a huge mistake for us to, in the name of short-term expediency, fail to implement the "active" corrective measures that are the only long-term "fix" for the Ivy Landfill problem (Nicholas Evans, electronic mail, April 18, 2001).