1999-12-29 -Letter -EPA and EMSI -Interim Work Plan for Derived Waste and Surface Soil

1999-12-29-letter-epa-and-emsi-interim-work-plan-for-derived-waste-and-surface-soil

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RECEIVED’
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VEC 3 1 19991 ENGINEERING MANAGEMENT SUPPORT INC.
12335 West 53rn Ave. Suite 201 Telephone (303) 940-3426 Arvada, CO 80002 Telecopier (303) 940-3422 [email protected]
December 29, 1999
U.S. Environmental Protection Agency
Region VII
901 North sch Street
Kansas City, Kansas 66101

ATTENTION: Mr. Dan Wall
SUBJECT : Interim Measures Work Plan Soil Piles on the Ford and Crossroad Properties West Lake Landfill Operable Unit 1, Bridgeton, Missouri
Dear Mr. Wall,
On behalf of Cotter Corporation (N.S.L.), Laidlaw Waste Systems (Bridgeton), Inc., Rock Road Industries, Inc., and the United Sates Department of Energy (the “Respondents”), Engineering Management Support Inc. (EMSI) submits the attached Interim Measures Work Plan to address occurrences ofradionuclides in surficial soil on properties owned by Ford Motor Credit Company (Ford) and Crossroad Properties, LLC. (Crossroad) located immediately west ofRadiological Area 2 of the West Lake Landfill. If you have any questions or desire additional information related to this Work Plan or any other aspect of the project, please do not hesitate to contact me.
Distribution :
John Niffenegger-Sverdrup
Doug Borro-Allied Waste Industries, Inc.
Ward Herst-Herst & Associates, Inc.
Michael Hockley-Spencer Fane Britt & Browne
Steve Landau -Cotter Corporation
Charlotte Neitzel -Holme Roberts & Owen
James Wagoner II-U.S. Department of Energy
William Werner-The Stolar Partnership

40273136
W.E. Whitaker-Rock Road Industries

IIIIII :’J.Q

INTRODUCTION
On behalf of Cotter Corporation (N.S.L.), Bridgeton Landfill, LLC., Rock Road Industries, Inc., and the United States Department of Energy (the “Respondents”), Engineering Management Support, Inc. (EMSI) has prepared this Interim Measures Work Plan to address occurrences ofradionuclides in surficial soil on properties owned by Ford Motor Credit Company (Ford) and Crossroad Properties, LLC. (Crossroad) located immediately west ofRadiological Area 2 of the West Lake Landfill. The Respondents, through EMSI, are currently involved in the completion ofa Remedial Investigation/Feasibility Study (RifFS) for Operable Unit 1 (OU-1) ofthe West Lake Landfill in Bridgeton, Missouri. Recent grading activities by others have resulted in removal of stabilizing vegetative cover and disturbance of soil containing radionuclides on the Ford and Crossroad properties. Removal of the vegetation and disturbance of the soil has resulted in a potential for wind or water erosion of the soil and potential transport to unimpacted areas.
This work plan includes a proposal to manage surficial soils containing radionuclides that were recently scraped from the Ford and Crossroad properties and piled in a berm adjacent to the northern boundary ofArea 2 ofOU-1 of the West Lake Landfill. EMSI is also proposing to conduct additional soil sampling of the Ford and Crossroad properties to characterize the current condition of these properties. In addition to addressing the soil piles on the Ford and Crossroad properties, EMS! is also proposing to consolidate soil-boring cuttings piles from OU-1 RifFS field investigations into Area 2. Both the cuttings materials and the soil piles will be consolidated at a single location in Area 2.
The specific activities addressed by this work plan include the following:
1.
Obtaining access to the Ford and Crossroad properties for the purposes of removing the soil piles and obtaining additional surface soil samples;

2.
Collecting various soil-boring cuttings piles present in OU-1 Areas 1 and 2 resulting from performance of the RifFS field investigations and consolidating the materials from these piles in one location on Area 2;

3.
Re-locating the soil piles resulting from the grading activities on the Ford and Crossroad properties onto the surface ofArea 2 above the consolidated soil-boring cuttings;

4.
Re-characterizing surficial soil remaining on the Ford and Crossroad properties for radiological constituents; and

5.
Final grading and revegetation ofthe location on Area 2 where the soil-boring cuttings and relocated soils are placed.

Draft Interim Measures Work Plan
West Lake Landfill OU-1 Rl/FS

24-inches in these areas did not detect elevated levels of radionucliJcs. Based on these
sampling results and the assumed mechanisms oftransport, EMSI concluded that the
radionuclide occurrences were likely limited to approximately the uppem10st 6-inches of
soil in this area.
On November 18, 1999, Herst & Associates, Inc. (Herst, 1999) perfom1ed a site walkover of the Ford and Crossroad properties and observed that the upper 2 to 6-inches of soil material had been scraped from the Ford Buffer and Lot 2A2 and pushed up against the boundary fence separating the Ford and Crossroad properties from the West Lake Landfill (Figure 3). A minor amount of scraped material was also mounded along the northern portion of the Ford and Crossroad properties. Approximately I 0 to 12 inches of gravel had been placed over the eastern portion of the Property (Lot 2A I and a small component ofLot 2A2), while the remaining disturbed soils were left exposed. The dates during which the excavation occurred are not known.
The excavation was performed despite signage warning ofthe presence of radioactive contamination. Numerous sets oftire tracks were also observed on the excavated property, including tracks indicating that vehicles have been driven directly past a radioactive contamination warning sign. It was noted by Herst & Associates, Inc. (Herst, 1999) that the excavation process has “increased the potential for windblown particles to exit the property”, and the mounded material is “subject to erosion potential due to runoff fruu1 prt:cipilaliou”.
EPA was notified on November 24, 1999, via telephone cumcrsatiun bel\\ cell :vi;d1acl Hockley on behalf ofthe Respondents and David Hoefer of EPA that an unknown party had initiated clearing and grubbing activities on property adjacent to the West Lake landfill. A written notification ofthis discovery was mailed to EPA on December 2, 1999 (Hockley, 1999).
Based on the potential for wind or precipitation runoff-induced erosion and transport of these soils, the Respondents through this work plan are proposing to conduct. subject to EPA approval, a time-critical removal action to retrieve and relocate the soi I piles to prevent potential offsite transport.
1.2 Purpose and Scope
The purpose of this work plan is to present proposed activities to retrieve and control radionuclides in soil that has been scraped and bermed on the Ford and Crossroad properties and to characterize the current conditions of the Ford and Crossroad properties. Specifically, the Respondents propose to excavate the soil piles resulting from the recent regrading ofthe Ford and Crossroad properties and convey and consolidate these materials in a cell on the surface ofArea 2. Upon completion of the excavation activities the surface ofthe cell will be re-vegetated to reduce the potential for windblown or nmoff transport of these soils.
Draft Interim Measures Work Plan
West Lake Landfill OU-1 RIIFS

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The scope of this work includes the following activities:
I. Obtaining access from Ford and Crossroad to allow for removal of the soil piles;
2.
Selecting a location for a “consolidation cell” on the surface of Area 2 where surficial soil graded and placed in a berm and pile on the Ford and Crossroad properties and soil-boring cuttings from OU-1 RifFS field investigations will be placed;

3.
Clearing/grubbing the surface of the consolidation cell;

4.
Collecting the soil-boring cuttings and placing them in the cell;

5.
Collecting and consolidating onto the surface of Area 2 the surficial soil which was graded and placed in a berm and pile on the Ford and Crossroad properties;

6.
Regrading and revegetating the consolidated soil;

7.
Completing additional radiological characterization of surficial soils located on the Ford and Crossroad properties; and

8.
Preparing a construction completion report.

Specific information regarding each ofthese activities is presented below.
2 ADDITIONAL SITE CHARACTERIZATION
This section develops objectives for additional site characterization and presents sampling and analytical details.

2.1 Site Access
Prior to conducting any of the proposed activities, an agreement will need to be reached with Ford and Crossroad to allow for access to remove the soil piles and collect the additional soil samples. The prior access agreement between Ford and the Respondents only provided for sample collection and would need to be renewed and modified to allow for removal of the soil pile on the Ford property. The Respondents have never had any form ofaccess agreement with Crossroad and such an agreement would need to be developed prior to initiating any of the work. If it is determined to be necessary to transport the soil along the Old St. Charles Rock Road alignment, an access agreement
Draft Interim Measures Work Plan
West Lake Landfill OU-1 RJ/FS

EXCAVATION PLAN
The proposed excavation activities include relocating soil piles from the Ford and Crossroad properties to a “consolidation cell” located on the surface of Area 2. The proposed excavation activities also include collecting the various soil-boring cuttings piles present in Areas 1 and 2 resulting from performance of Rl/FS field investigations and consolidating the materials from these piles along with the surficial soils from the Ford and Crossroad properties at the consolidation cell on Area 2. The excavation plan presented in this section discusses the configuration and location ofthe consolidation cell, cell construction and material excavation/placement, and preparation of a construction completion report.
3.1 Consolidation Cell Configuration and Location
The excavated soil from the Ford and Crossroad properties and Rl/FS soil-borings cuttings will be transferred to and consolidated at a location on Area 2. Based on the estimated volume of the soil piles of approximately 750 cubic yards (Herst, 1999) and assuming that an additional6-inches of material will be excavated from below the approximately 1,250 fe footprint ofthe piles, the total volume of soil to be removed is estimated to be approximately 800 cubic yards. The volume of the soil boring cuttings piles is estimated to be between approximately 180 and 300 yards. Therefore, the total volume of material to be placed in the cell in Area 2 is approximately 1,000 cubic yards. Assuming a nominal placed thickness of up to 2.5 feet, an area of approximately I 0,000 square feet (approximately 0.25 acres) will be necessary for placement of the cuttings and soil in Area 2. The 2.5-foot thickness was chosen to minimize the cell footprint while producing a cell height with a minimal elevation to facilitate revegetation and maintenance. For purposes ofthe following evaluations, the configuration of the cell has been assumed based on a square cell with 1 00-foot side lengths. The actual con figuration ofthe cell will be engineered in the field based on the local topographic conditions and the final volumes of soil material to be placed in the cell.
EMSI proposes that the cell be constructed in the northern part ofArea 2 where radiologically affected materials are already present at the surface (Figure 4 ). The proposed area for the cell is relatively small in comparison to the surficial expression of the radiological materials in Area 2. Therefore, it will be relatively easy to delineate an appropriate location for the cell within the affected area.
The proposed location ofthe cell has been identified based on as many of the following criteria as possible (listed in order of importance):
• The cell is placed outside the boundaries of any region within Area 2 where
ponded water is present for prolonged periods;

Draft Interim Measures Work Plan West Lake Landfill OU-l Rl/FS
Page 6
WLLFOIA4312-001 -0020593

The cell is placed in an area with an existing slope that facilitates runoff\’,:ithout resulting in enhanced erosion (nominally 1 to 3 percent);


The cell is placed in an area where runoff from the cell location and immediately surrounding area will drain to the interior low spots of Area 2 rather than off site;


The cell is placed in an area where the uphill boundaries ofthe cell will be blended into the existing topography to minimize side slope surface area and the resulting potential for enhanced erosion;


The cell is placed in an area with limited existing vegetation to provide additional erosion protection in Area 2 through revegetation of the cell; and


The cell is placed in a location that is easily accessible for both construction and future maintenance activities, if any.

In-place configuration ofthe consolidation cell will be based on the actual volume of materials excavated from the Ford and Crossroad properties and the RifFS soil-borings cuttings. The currently anticipated dimensions are provided above.

3.2 Cell Construction and Material Excavation and Placement
A Health and Safety Plan for the proposed activities will be prepared prior to initiation of site construction activities. The Plan will include descriptions ofequipment and personnel to be employed and decontamination procedures.
Prior to placement ofany materials in Area 2, the area of the consolidation ce11 wi11 be cleared and grubbed of vegetation and surficial debris. The materials contained in the various soil boring cuttings piles in Areas 1 and 2 will then be collected, transported to the cell, and consolidated in the cell.
The following sequence ofconstruction activities will then occur:
• Soil piles on the Ford and Crossroad properties will be excavated to an anticipated depth of 6 inches beneath the preexisting ground surface using a front-end loader and/or bulldozer, and placed in off-road trucks using a front-end loader. It is anticipated that the trucks will use a temporary road cleared through the existing vegetation on the face of the landfill berm located immediately to the east of the Ford and Crossroad properties (to haul the soil directly to Area 2). Alternatively, the Old St. Charles Rock Road alignment may be used to to haul the materials to Area 2 via the gated southeastern entrance to the landfill. The bed ofeach truck will be covered while traversing the offsite roads or through portions ofthe landfill outside of Areas 1 and 2.
Draft Interim Measures Work Plan West Lake Landfill OU-1 Rl/FS
Page 7

Transported soils from the Ford and Crossroad properties will be placed over the
cuttings materials in the consolidation cell and spread in one-foot lifts by a dozer.
The first two lifts will be compacted by making at least three passes with the
dozer over the soils. The final lift will not be compacted to allow for revegetation
efforts. However, the final lift will be graded to blend with the surrounding
topography, with maximum sideslopes of 5H: 1 V, and contoured to match existing
drainage patterns (see grading objectives below).


The top and sides ofthe cell will be revegetated with native grasses during the
subsequent growing season.


The corners ofthe cell will be staked and surveyed upon completion ofthe final
grading and contouring activities.

During placement activities, the placed soils will be contoured to promote diversion of run-on waters and to minimize the potential for erosion of the place soils by precipitation runoff. The grading objectives will require the upper portion of the cell to drain with a minimum slope of 1%. The side-slopes of the cell will be graded to a maximum 5H: 1 V slope to minimize the potential for erosion. Upon completion of the grading and contouring, the surface of the cell will be vegetated with native grasses to further reduce the potential for erosion, as discussed above.
Reclamation of the Ford property and Lot 2A2 that may be transferred to a Respondent to give the Respondents control of this property and provide additional buffer zone will involve re-vegetating exposed soil with native grasses. It is anticipated that seeding will occur during the springtime when germination can best occur.
3.3 Construction Completion Report
Upon completion of all field activities, a construction completion report will be prepared and submitted to EPA. The construction completion report will include the following information:
1.
Narrative description of the activities conducted;

2.
Survey information and record drawing(s) ofthe consolidation cell;

3.
Summaries of the areal extent and volumes ofmaterials removed from the Ford
and Crossroad properties;

4.
Results of the sampling and analysis efforts; and

5.
Discussions of any unanticipated conditions encountered or any field changes
made to the program.

Draft Interim Measures Work Plan West Lake Landfill OU-1 RifFS 12/29/99Page 8
WLLFOIA4312-001 -0020595
IMPLEMENTATION SCHEDULE
It is anticipated that the measures discussed in this proposal can be …. ,-1 in
accordance with the following schedule:
Obtain bids from qualified
contractors and obtain site access
Select preferred contractor
Mobilize equipment, prepare consolidation cell, relocate soil-boring cuttings, relocate Ford and Crossroad properties soils
Complete final grading of
consolidation cell
Conduct additional”surface soil sampling on Ford and Crossroad properties
Submit Construction Completion
Report Within 21 days of approval or this proposal from EPA
Within 14 days of receipt and review of contractor bids
Within 14 days of selection of the preferred contractor (assuming necessary site access has been obtained)
Upon completion of cuttings and soil consolidation activities
Upon completion of excavation of the soil piles on the Ford and Crossroad properties
Within 30 days of receipt of additional soil sampling results
Dra(t lntenm Measures Work Plan
West Lake Landfill OU-1 RI/FS

REFERENCES
Auxier and Associates, 1998, DraftBaseline Risk Assessment, West Landfill,Operable Unit 1, April 22, 1998.
Engineering Management Support, Inc., 1997, Amended Sampling and Analysis Plan, West Lake Landfill, Operable Unit 1, Prepared for West Lake OU-1 Respondents Group. February
Engineering Management Support, Inc., 1998, Draft Remedial Investigation Report, West Lake Landfill, Operable Unit I, Prepared for West Lake OU-l Respondents Group. March
Herst & Associates, Inc., 1999, Letter Report to Mr. Michael Hockley of Spencer, Fane, Britt & Browne entitled “November 18, 1999 Site Walkover, Ford and Crossroad properties Area, West Lake Landfill Operable Unit 1 RifFS”, prepared by Ward E. Herst. December 1.
Hockley, Michael, D., 1999, Letter to David Hoefer, U.S. EPA, Re: West Lake Landfill Superfund Site, December 2, 1999.
McLaren/Hart, 1994, RifFS Work Plan for the West Lake Site. Bridgeton. Missouri. August 15.
Draft Interim Measures Work Plan West Lake Landfill OU-l Rl/FS!2/29/99Page 10
WLLFOIA4312-001 -0020597