2013-11-25 Letter Feezor to EPA WLL Phase 1 Status Report


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November 25, 2013
Ms. Cecilia Tapia Director Superfund Division
United States Environmental Protection Agency
Region 7 11201 Renner Boulevard Lenexa, Kansas 66219
RE: Bridgeton Landfill-West Lake Landfill: Phase 1 Status Report
Dear Ms. Tapia:
On behalf of our client, Bridgeton Landfill, LLC (h ereinafter Bridgeton Landfill), Feezor Engineering, Inc. (FEI) hereby submits an update to the Phase 1 Gamma Cone Penetrometer Test (GCPT) field investigation. This update was requested by EPA as a preliminary update and this is not a report anticip ated by the Phase 1 Work Plan. The update contained within this correspondence and att ached drawing is through Friday, November 22, 2013. Please note that because the Ph ase I work has not yet been completed and necessary calibration and correlation completed, this update and information is collected from field data and should be considered draft preliminary in nature.
The Phase 1 Work Plan is consistent with Environmen tal Protection Agency’s (EPA) September 20, 2013, letter directing the investigat ion under the Additional Work provision of the Administrative Order on Consent for the West Lake OU-1 Superfund Site.
The project was initiated by conducting General Empoyee Radiological Training (GERT) on October 28, 2013. Auxier and Associates, Inc. who is providing the radiological safety and monitoring services for the project provided th e GERT and answered any worker safety and monitoring questions. On October 29, 2013, vegetation clearing was initiated by Agricycle, Inc. Prior to any vegetation clearing AAI provided an onsite health physicist who will conducted an overland gamma scan. The hea lth physicist held the detector approximately 30 em above the ground surface and adtanced across the areas of interest in a series of straight lines at a rate of approxim ately one meter per second. The separation distance between the lines were approxim ately 1.5 meters. In all areas of vegetation clearing, no elevated overland gamma readings were detected.
406 East Walnut Street • Chatham, IL 62629 Phone (217) 483-3118 • Fax (217) 483-2356
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-2-November 25, 2013
Vegetation clearing proceeded from October 29, 2013 to November 18, 2013 by using a tree shear or a skid steer with a brush hog attachm ent. Care was taken to select paths which required a minimum amount of clearing. The tree shear was used for the majority of the clearing, while the brush hog was used in areas deemed too thick such as a thicket type vegetation. To prevent any visible dust emiss ions a water truck was available to water the vegetation. However, rain events and nat ural moisture provided sufficient wetting, and it was decided that additional waterirg was not needed for dust suppression and could create conditions more conducive to rutting.
Once the path was cleared, Agricyle deployed a 10 o unce per square yard non-woven geotextile, and then approximately 6-8 inches of ro ck aggregate was spread to advance gravel roads to each test location along the cleara:l alignments. The gravel path locations were surveyed and the locations are depicted on the attached drawing entitled GCPT
As of the end of the work day on November 22, 2013 the following paths have been constructed, which should suffice for the Phase 1 investigation.

Entrance Alignment

Main Alignment to west fence

Main Alignment to east fence

Path 1-GCPT 4-1 to GCPT 4-2

Path 2 -GCPT 5-1 to GCPT 5-4

Path 3 -GCPT 6-3 to PVC-36

Path 4-GCPT 7-2

Path 5-GCPT 9-2, WL-108, GCPT 9-1, and GCPT 7-1

Path 6-GCPT 10-2 to GCPT 10-1 to PVC-25

Path 7-GCPT 12 -2 to GCPT 12-1 to PVC-38 to PVC-28 to GCPT 11-2

Path 8-GCPT 13-1 to GCPT 13-7 (also including GCPT 13-1 to GCPT 16-1)

Path 9-GCPT 14-1 to GCPT 14-7

Path 10-GCPT 15-1 to GCPT 15-8

Path 11-GCPT 16-4 to GCPT 16-8

Path 12-Entrance Alignment west to GCPT 6-4

Path 12B -GCPT 12-6

Approximately 4,200 feet of paths have been constru cted to date. Approximately 3265 tons of rock, and approximately 400 yards of soil have been delivered to date.
ConeTec arrived on site on November 12, 2013 and, cfter obtaining the proper health and safety training, proceeded to conduct a GCPT soundi ng at the existing boring WL-111. After the AAI Health Physicist approved that the GCPT rods and the GCPT machine tracks were devoid of any radiological contamination, the GCPT rig was moved to PVC-28 and a sounding was conducted there. ConeTec was able to detect elevated gamma counts
11-25-13 GCPT Status Report.docx
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within this boring. No PVC casing from the NRC stu dy was found, since under the approved materials management plan over 8 feet of c onstruction and demolition debris was placed in this area since the NRC borings were initially conducted. (As discussed below, this construction and demolition debris has proved to be an impediment with the advancement of the gamma cones along the eastern ha If of the OU-1, Area 11andfill.) After the sounding at PVC-28, the AAI health physic ist released the GCPT rig to proceed to the next location.
The next sounding occurred within the existing casing for PVC-25 an existing NRC boring. The September 27, 2013 Gamma Cone Penetration Test {GCPT) Work Plan Revis ion 2 (hereinafter referred to as the Work Plan) listed FVC-38 as a correlation boring. However, after clearing up to this boring, it was determined that the topography would deem this location unsafe for the GCPT rig. Upon consultatio n with Region 7 of the USEPA, it was determined to use PVC-25, another known impacted NR C boring. This location was beyond the construction and demolition debris fill,and the existing PVC casing was found. ConeTec was able to lower their GCPT rods into this casing and again, was able to detect elevated gamma readings. After AAI scanning and rE!ease, the GCPT rig proceeded to PVC -36, another NRC PVC casing that was discovered. T he GCPT rig was able to detect a slightly elevated gamma reading from this PVC casin g. Having completed testing of the three known radiologically impacted borings with the GCPT rig, it was decided in the field that the GCPT technology was recording relevant gam ma data. Even though statistical correlation studies and analytical sampling will be necessary in the future to provide proper correlations, the device would be used to co llect raw data at the proposed sounding locations.
Soundings occurred within the OU-1 Area 1 fenced ar ea from a general west to east progression. A summary of the raw data from the so undings is included in the attached drawing entitled GCPT Status. As of the end of the work day on November 22, 20 13 the following GCPT locations have been completed, or at least attempted with upper level rock refusal.

GCPT 4-1, 4-2

GCPT S-1, S-2, S-3, 5-4

GCPT 6-1 (also PVC-36), 6-2, 6-3, 6-4, 6-5

GCPT 7-1, 7-2, 7-3

GCPT 8-1

GCPT 9-1, 9-2, 9-3

GCPT 10-1, 10-2, 10-3, 10-4

GCPT 11-1, 11-2, 11-3, 11-4

GCPT 12-1, 12-2, 12-3, 12-4, 12-5, 12-6

GCPT 13-1, 13-2, 13-3, 13-4, 13-5, 13-6, 13-7

GCPT 14-1, 14-2, 14-3, 14-4, 14-5, 14-6, 14-7

11-25-13 GCPT Status Report.docx
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