2014-05-30 – EPA – West Lake Landfill – Pre-Construction Work Plan – USACE Review Comments as of 30 May, 2014

2014-05-30 - EPA - West Lake Landfill - Pre-Construction Work Plan - USACE Review Comments as of 30 May, 2014

Leave a Reply

Your email address will not be published. Required fields are marked *

West Lake Landfill Superfund Site
Work Plan for Removal Action: Pre-Construction Work Plan Dated May 16, 2014
USACE Review Comments as of 30 May, 2014
Comment
Document
Reference: Section/
Commentor
# Paragraph/ Appendix
Vegetation & Surface
1 Work Plan Obstacle Clearing, Sec Donakowski
2.2
Vegetation & Surface
2 Work Plan Obstacle Clearing, Sec Donakowski
2.2
Vegetation & Surface
3 Work Plan Obstacle Clearing, Sec Donakowski
2.2
Vegetation & Surface
4 Work Plan Obstacle Clearing, Sec Donakowski
2.2
Vegetation & Surface
5 Work Plan Obstacle Clearing, Sec Donakowski
2.2
Air Monitoring
6 Work Plan Sampling, and QA/QC, Donakowski
Sec. 2.4
Air Monitoring
7 Work Plan Sampling, and QA/QC, Donakowski
Sec. 2.4
8
Air Monitoring, Sampling,
Appendix B Donakowski
and QA/QC Plan
9 Radiation Safety Plan 4.1, Appendix D Donakowski
WLLFOIA4312- 001 – 0059056
Identification of
Waste Staging,
10 Work Plan Management, & Conroy
Relocation Areas, Sec
2.1
Identification of
Waste Staging,
11 Work Plan Management, & Conroy
Relocation Areas, Sec
2.1
Identification of
Waste Staging,
12 Work Plan Management, & Conroy
Relocation Areas, Sec
2.1
Identification of
Waste Staging,
13 Work Plan Management, & Conroy
Relocation Areas, Sec
2.1
Vegetation and
14 Work Plan Surface Obstacle Conroy
Clearing, Sec 2.2
15 Work Plan
Litter Control Barriers,
Conroy
Sec 2.5
16 Work Plan
Litter Control Barriers,
Conroy
Sec 2.5
WLLFOIA4312- 001 – 0059057
Identification of
Waste Staging,
17 Work Plan Management, & Kiefer
Relocation Areas, Sec
2.1
Identification of
Waste Staging,
18 Work Plan Management, & Kiefer
Relocation Areas, Sec
2.1
Vegetation & Surface
19 Work Plan Obstacle Clearing, Sec Kiefer
2.2
Vegetation & Surface
20 Work Plan Obstacle Clearing, Sec Kiefer
2.2
Vegetation & Surface
21 Work Plan Obstacle Clearing, Sec Kiefer
2.2
Air Monitoring
22 Work Plan Sampling, and QA/QC, Kiefer
Sec. 2.4
23 Work Plan Table 2, Schedule Kiefer
24 Work Plan Table 2, Schedule Kiefer
25 Bird Monitoring Plan Appendix A, Bass
Identification of
Waste Staging,
26 Work Plan Management, & Speckin
Relocation Areas, Sec
2.1, 4th Para, pg 3
Identification of
Waste Staging,
27 Work Plan Management, & Speckin
Relocation Areas, Sec
2.1, 4th Para, pg 3
WLLFOIA4312- 001 – 0059058
Vegetation & Surface
28 Work Plan Obstacle Clearing, Sec Speckin
2.2, 4th Para, pg 5
Vegetation & Surface
29 Work Plan Obstacle Clearing, Sec Speckin
2.2, 4th Para, pg 5
Air Monitoring
30 Work Plan
Sampling, and QA/QC,
Speckin
Sec. 2.4, 2nd Para, pg
7
31 General Odor Control Speckin
Vegetation & Surface
32 Work Plan Obstacle Clearing, Sec Kiefer
2.2, 2nd Para
Vegetation & Surface
33 Work Plan Obstacle Clearing, Sec Kiefer
2.2, 4th Para
34 Radiation Safety Plan Appendix Kiefer
WLLFOIA4312- 001 – 0059059
Comment
“Background” not well defined in the document. Should either reference established background from past activities or discw
establishment of a reference area prior to scanning
“Above background” can be a nebulous term. Suggest using more definitive action level such as instrument MDC, instrument 1
instrument readings at levels above 95% UCL of established reference area, etc. Often background is taken as the average of 1::
measurements, which can lead to situations where 50% of measurements are “above” background even though they are cons
expected background readings.
~o note, in past discussion it appears UMTRCA 5.0 pCi/g total thorium has been established as the “free release” criteria. As sL
“above background” measurement may still meet the release criteria.
f:>oil sampling requirements are not discussed. Will soil samples be collected? If so, there should be some discussion of sample
bias sample identification, duplicate frequency, sample depth, etc.
Provide clarification regarding the the purpose of placing a layer of rock over areas of elevated gama. Is it an engineered cant
speard of contamination or to provide shielding for workers? If significant contamination is encountered that requires contan
control or shielding, it is recommended the work plan should include re-evaluation of the barrier location in order to avoid thE
area rather than attempt to place a temporary barrier/shield.
~able llists collection frequency for alpha track detectors as semi-annual. Recommend deploying multiple sets of detectors, c
left for annual monitoring and one set to be switched out quaterly, rather then semi-annually, to coincide with the collection 1
Note -Air monitoring plan states alpha track etch detectors are to be exchanged quaterly. If in error, reconcile these two. Que:
out is preferable.
~he reviewer is not familiar with the Inspect USA alpha track detectors, but with some alpha track vendors it is possible to pur
detectors with a thoron (i.e. radon 220) filter. Recommend deployment of both unfiltered and thoron filtered alpha track detE
significant difference in colocated filtered and unfiltered detectors would suggest thoron, though short lived, is a significant d1
radon levels. This is important to ensure that reported radon-222 results are not biased high due to radon-220 contribution a
determine whether radon-220 and its decay products are present at levels that could cause it to become a constiuent of cone
General question regarding air monitoring and not necessarily a comment directly related to the preconstruction activities- is
rom the surface of the disposal areas conducted? UMTRCA has limits of 20 pCi/m” 2/s. If surface flux monitoring is performec
helpful to include a discussion of that activity as well.
ft\re there locations where dose rates in excess of 2 mrem/hr exist? If so, is work planned in these areas? Recommend a map a
radiologically restricted areas, if they exist, be included in the work plan.
WLLFOIA4312- 001 – 0059060
Recommend the designers take a closer look at the bottom width of the proposed excavation to aid the excavation
isolation barrier. Although the proposed bottom width of 45-feet would be just wide enough to accommodate an e
machine wielding a clamshell, it may not be wide enough to allow support vehicles to pass behind the excavating m
configuration assumes the machine is orientated at a 90-degree angle to the excavation centerline and that the cen
located at an edge of the proposed excavation. If the excavation must be made wider than 45-feet at the base, the
quantities will be larger and more disposal area may need to be identified.
he disposal area for any encountered RIM is not identified. The plan only states that RIM will be disposed of in an
manner”. An area for disposal of RIM encountered in the excavation must be identified. Recommend including a fi,
outlining the areas designated for disposal.
The plan identifies a map to be prepared which identifies potential areas for waste relocation, the size of each area,
preliminary estimate of the expected in-place volume of waste material that can be relocated to each area. Recom1
figure be prepared now and included with this plan.
Excavation of a slurry trench is very messy. Slurry used to support the side walls of the excavated trench will splash
rench, drip from the clamshell, and drip out of the dump trucks used to haul the excavated wastes to the previous
disposal areas. The equipment will track the wet slurry around the site. Strongly recommend the designer conside1
concrete work surface on the bottom of initial excavation. This work surface would include guide-walls to control tl
and horizontal alignment of the trench. The work surface will also include curbing to contain the slurry and prevent
running off of the site. The inclusion of this concrete work surface will increase the proposed width and depth of tl
excavation to aid the excavation of the isolation barrier.
he plan states that the process for clearing and vegetation management will follow the previously approved proce
or the 2013 fence construction and 2013 GCPT Investigation. Does this process include the removal of the root bal
rees that are felled as part of the vegetation control? Or is this type of “grubbing” unnecessary for this work? Rec1
including the previously approved processes in an Appendix so all work plans associated with pre construction are i1
his document.
dozer moveable litter control units that are each wide control nettir
of the active excavation. Four of only provide protection for slis
2.1 of the proposed excavation to aid
across at base and will slopes 3
describe an excavation is wide at the top. Four dozer
control units may not be to all litter emanating from an excavation of this p
include provision to mobilize additional litter control units if the original four are observed to be ineffective.
Figure 4 in the plan shows location a long litter barrier located along St. Rock Road. H
should provision to increase the length of this litter barrier, or erect portion of it in an additional
initially proposed barrier is observed to be ineffective at all windblown
WLLFOIA4312- 001 – 0059061
3rd paragraph references an appropriate unit. Work Plan should provide parameters and range of criteria that bett
~hat would be considered an appropriate subsurface unit.
Paragraph 7 states, “if RIM is encountered, this waste will be disposed in an approved manner and not disposed in the relocat
~ork plan should outline what that “approved manner” will be.
Paragraph 4 references process utilized for 2013 fence construction and 2013 GCPT investigation will be used. Recommend tf
included as an appendix to this Work Plan so all documents are together in one document.
Paragraph 4 references that moisture may be added to the vegetation during brush hog and chipping operations if the natura
insufficient to suppress dust. Work Plan should identify how you will determine that the natural moisture is insufficient to su1
Last paragraph states that if the overland gamma scan indicates a radiation level above background, the health physicist will n1
clearing crew. Please specify in this plan the background radiation level.
Paragraph 4 states that the meterological station will be placed on top o fthe landfill office if the roof condition is adequate. F
alternate location in the event the roof is not adequate to hold the equipment.
Recommend that initial identification of waste storage areas be provided now (in this work plan, per comment 12) and schedL
o show that final adjusted locations of waste storage areas will be provided within 30 days of Work Plan approval.
Recommend that a more definitive schedule be provided for clearing of vegetation and surface obstacles. Example: Clearing
and surface obstacles will be completed within 30 days of approval of IB Design.
~he Summary Report dated March 18, 20141ocated in Appendix A, paragraph 1.0 of the Bird Hazard Monitoring and Mitigatia
references 2 letters from the St. Louis Airport’s Counsel that provided concepts and comments that were recommended to be
ongoing monitoring plan. USACE has not been provided with those letters, so it cannot be verified if the recommended contn
limited clearing work to be completed during pre construction activities. Please provide copies of those letters so verification
performed.
~he 3rd sentence indicates any excavated material that will be excavated below the April 6, 1975 surface will be given prefere
relocation to theSE corner Area 1. Does this mean that North Quarry landfill material placed after April 6, 1975 will be given 1
relocation in SE corner of Area 1 or material placed prior to April 6, 1975 … which it is assumed would be the original Area liar
overlay of the North Quarry Material. If the latter, it appears the sequence of excavation may make this difficult since North C
material would be excavated first, followed by the Area 1 material. Please clarify.
~he 4th sentence discusses the potential for placement of excavated material on the North Quarry Landfill. The summary of 1
Monitoring Plan indicates anticipated construction activities may require relocation of the air monitoring stations. Are the cu1
proposed air montitoring station locations suitable if material placement is required on the North Quarry Landfill?
WLLFOIA4312- 001 – 0059062
It appears that the precautions during clearing described in this paragraph will only be necessary if surface RIM is discovered i
scans described in the prevous two paragraphs. Although it may already be planned, it is recommended that any areas identi”
containing RIM be cordoned off so there is a visual demarcation of areas to avoid or where extra precautions need to be taker
paragraph is currently written it is uncertain if there will be a visual demarcation or if it will simply be a Rad Tech guiding thosE
he clearing.
Last sentence suggests that clearing and addressing gamma areas above background will be the first step before other activiti< uses "installation of air monitoring equipment" as an example of activities that will occur after addressing the gamma areas. f appears part of the process of addressing the gamma involves clearing and potential ground disturbance. Does the air monitc need to be in-place prior to these activities or is a more localized air monitoring program planned? ~his paragraph indicates that air monitoring stations may need to be relocated due to availability or restrictions on the deliver power to each location. USACE has had good luck with the use of solar powered air monitoring stations under similar circums hat may be an option to consider if it becomes an issue. It was not indicated that a separate odor control plan was going to be developed for this site. However, odor control is discus association with the Bird Mitigation Plan. Since odor control appears to be a significant factor in mitigating bird issues, are thE measures to be implemented as part of the Bird Mitigation Plan considered sufficient to address odor issues affecting the pub f:>tates that topsoil and grassy areas from OU-1 will be stockpiled near N. Quarry Landfill crown area with silt fencing to preven
Please specify how potential blowing dust from that stockpile will be minimized.
f:>tates that the process for clearing and vegetation management will follow previously approved processes utilitzed for the 20
investigation. This section includes some language verbatim from the 2013 GCPT work plan, but not all. To ensure there is nc
o what will be done and to prevent the need to reference multiple work plans, it is recommended that the few paragraphs of
GCPT work plan that apply to the pre-construction work be incorporated into Sec 2.2 of the pre-construction work plan.
Personnel, tools, and equipment used for clearing areas of OU-1 that are impacted with surface RIM will require an equipmen
in accordance with section 5.3.5. The work plan should include a figure showing the exist survey area for pre-construction act
WLLFOIA4312- 001 – 0059063
Critical
Issue
Y/N
N
N
N
N
N
N
N
N
N
WLLFOIA4312- 001 – 0059064
N
N
N
N
N
N
N
WLLFOIA4312- 001 – 0059065
N
N
N
N
N
N
N
N
N
N
N
WLLFOIA4312- 001 – 0059066
N
N
N
N
N
N
y
WLLFOIA4312- 001 – 0059067