2011-12-29 – NATIONAL REMEDY REVIEW BOARD Questions and Answers for Superfund Site Managers

.. {In Archive} State attendance at a NRRB Westlake "meeting"? ~~~ Craig Smith to: Dan Gravatt,... View Document

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2012-01-04 – Considering environmental justice issues EPA should establish a CAG for West Lake Community

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PUBLIC INFORMATION CLEARANCE RECORD
I I I I

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1. ORIGINATOR end PHONE DTBISION DA’n:
Debbie Kring, X7725 114/2012
2. PRODUCT TITLE
Ad-Announcement of Release ofthe West Lake Landfill Superfund Site Final Supplemental Feasibility Study (SFS)
3. PROPOSED USE
Announcement for the community at large, the Superfund repositories and the Record Center.
4. CONCURRENCE: SlgiHff …. Dille
OPA SUPR CNSL OPA ~ ~ Ji Thomas/Hood 01 ~~12011.l {?/’ SUPR CNSL -Singletary Gonzales
Signature in this block indicates the appropriate assistant administrator, regional administrator, head of staff office, or their delegate has reviewed and approved the material submitted to OEP or RGAD for signature.

G Drive: Product Masters File/Public Information Form 11 /1/05
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Superfund
Region 7
Project/Background/Purpose:
West Lake Landfill (Superfund Site)
Atter listing the site on the NPL the EPA completed a preliminary study and determined that no immediate actions were necessary at the Westlake Landfill site while site studies are underway. Subsequently, EPA entered into a consent agreement with the responsible parties in which the parties agreed to perform field studies and engineering evaluations designed to identify the best strategies for cleanup. Remedial investigation and feasibilty study work was completed in 2006 and a proposed plan for both operable units was published in June 2006. The Record of Decision for Operable Unit 1 was signed in May 2008. The selected remedy calls for the installation of an engineered landfill cover and implementation of a long-term monitoring program. The Record of Decision for Operable Unit 2 was signed in July 2008. Under this decision, the other landfill units \\·ill be closed and monitored in accordance with Missouri solid waste regulations.
Critics of the selected remedy for OU 1. including the Missouri Coalition for the Environment. want the waste material to be excavated and shipped to an off-site location. In an April 2009 letter to the Administrator, the Great Rivers Environmental Law Center (on behalf ofthe Coalition) again raised its concerns and requested the remedy be reevaluated. After extensive consultation between the Region and Headquarters. EPA made a decision to conduct a supplemental feasibility study (SfS) for QUI that further evaluated full-scale excavation of the radiologically-contaminated landfill material and disposal either off-site or in a new, on-site engineered disposal cell. The Remedial Design/Remedial Action (RD/RA) negotiations (which sequentially follow the signing ofthe Record of Decision) \Vere put on hold in June 2009, pending the outcome of this study.
In January 20 I 0. EPA agreed to allow the Potentially-Responsible Parties ( PRPs) to perform the SFS, pursuant to the existing Administrative Order on Consent under which the PRPs had performed the Remedial investigation/Feasibility Study (RI/FS) and RD. EPA-Headquarters (Jim Woolf(Jrd) sent a letter to the Great Rivers Environmental Law Center on March 3, 2010 stating that EPA would conduct a SFS. The SFS Work Plan was approved under a cover letter dated May 21, 2010, and was released to the public in June 2010. EPA received the draft SFS report on July 23.2010. On September 22,2010. EPA met with MDNR and the PRPs to discuss comments about the report. On November 10, 2010, EPA formally submitted comments to the PRPs and requested changes to the report by January 16, 2011. The PRPS asked for an additional 60 days, which EPA granted. PRPs responses to comments are currently under rCVlC\V.
Support Needed:
Contractor support is needed to potentially provide facilitation, technical assistance to public groups (i.e., the CAG), and review of technical documents that support the site:
+
Coordinating with Public Groups (i.e .. CAG):

+
Preparing tor, Facilitating, and providing summaries at EPA & Group (CAG) Meetings (up to 6 meetings):

+
Technical Document Review and Summary of Content (estimate= 3 technical documents):

+
Developing Presentation Materials (technical document content breakdown and summary):

+
Developing Responses to Community Inquiries (technical issues);

* Currently there is not a CAG at this Superfund Site, however, due to the site complexity, the extension of the original public comment period on the Proposed Plan (6 extensions). the political inquiries. EJ considerations, and environmental group involvement. it would be a wise move on EPA’s part to have additional options in the review, response, and facilitation arenas.

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2012-01-04 – EPA – Request for total assessed value of businesses within the Levee District encompassing the West LakeLandfill

{In Archive} Can you get the total assessed value of businesses within the Levee District encompassing the WL landfill Cecilia Tapia to: Dan Gravatt 01/04/2012 03:13PM Cc: DeAndre Singletary, Audrey Asher
History: This message has been forwarded.
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Karl thought that this would be a good indicator of the private levee’s ability to maintain the levee system .
In addition he wants to know if there has ever been any flooding in the area since the levee was built.

Thanks, Cecilia Tapia Director, Superfund Division
U.S. EPA901 N. 5th Street Kansas City, KS66101 (913)551-7733 FAX: (913)551-7145 CELL:(913)449-4171 EMAIL: [email protected]
The information., t 1 ematl and in any of tt a tachmen IS confrdenbal and may be privileged. If you are n<>l the intended 1ecip~en please destroy 1 · message. (La inlonnaaon contemda en esle menS

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2012-01-04 – Purpose of public interviews in the Superfund Process

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. \ ‘ RE: West Lake Landfill: possible interivews related to the revised CIP
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\. -~”””C7 Muenk.s, Shawn to: Dan Gravatt, Debbie Kring 01/04/2012 04:31 PM Cc: “Doster, Branden”
1”1 orn: “Muenks, Shawn”
To: Dan Gravatt/R7/USEPA/[email protected], Debbie Kring/R7/USEPA/[email protected]
Cc: “Doster, Branden”
Dan & Debbie,
It was our understanding that the purpose of the public interviews would be to
gauge concerns and expectations of nearby communities regarding West Lake
Landfill and how they want to be interacted with during the public comment
period. The interviews should be done prior to the public comment period and
information gathered included in the CIP. The interviews would not
necessarily be used to determine which remedy the public supports. We were
also under the impression from our discussion at the last site tour that EPA
was committed to conducting these interviews. I think a call to discuss this
issue is warranted. Please advise of availability. We are available Thursday
or Friday morning this week and Monday or Tuesday of next week.

Thanks,
Shawn Muenks, P.E.
Missouri Department of Natural Resources

P.O. Box 176, Jefferson City, MO 65102-0176 Ph: (573) 751-3107 email: [email protected] —–Original Message—-.From: Dan Gravatt [mailto:[email protected]] Sent: Wednesday, January 04, 2012 3:53 PM To: Muenks, Shawn; Doster, Branden Cc: Debbie Kring Subject: West Lake Landfill: possible tnterivews related to the revised CIP
Shawn, Branden,
Following up on the question you posed in yesterday’s biweekly conference call, I spoke with Debbie Kring yesterday on the issue of conducting public interviews as part of the revised CIP. Debbie stated that it has not been decided whether EPA will conduct these interviews, but if our Office of Public affairs decides to do so, they will be conducted in the spring. OPA intends to treat these interviews separately from public comment periods and/or public meetings associated with any decision documents.
If you have any other questions on this issue, please contact Debbie directly at 913-551-7725.
Sincerely, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063
Principles and integrity are expensive, but they are among the very few things worth having.
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2012-01-25 – NRRB – Questions and Answers for Superfund Site Managers

{In Archive} Fw: NRRB review of Westlake Landfill Craig Smith to: Dan Gravatt 01/25/2012 03:42PM Cc: DeAndre Singletary, Audrey Asher, Robertw Jackson, Cecilia Tapia
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As Amy said, here is the current schedule of meetings:
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FY 2012 NRRB Meeting Calendar.docx
The guidance calls for the review packages as follows, so this may influence the schedule:
“Finalize the informational site package at least four weeks before the meeting and provide the package to the relevant regional NRRB member for distribution to Board members in preparation for the site review. The package will be posted on the Board’s Quickr site so that Board members may download it at their convenience. Oversized charts, maps or tables should be mailed to the Board members. The mailing list is available from the Board’s Quickr site. Please note that two additional copies should be mailed to the Board chair for distribution to OSRTI participants.”
Let me know what looks good.
Thanks, Craig S
Craig W. Smith, P.E. Senior Engineer and Policy Coordinator Superfund Division USEPA Region 7 Kansas City
(913) 551-7683
—–Forwarded by Craig Smith/SUPR/R7/USEPAIUS on 01/25/2012 03:28PM—-.
From: Amy Legare/DC/USEPAIUS· To: Dan Gravatt/R7/[email protected], Craig Smith/SUPR/R7/[email protected] Cc: Dave Crawford/DC/[email protected], Gary Worthman/DC/[email protected] Date: 01/25/2012 12:28 PM Subject: NRRB review of Westlake Landfill
Hello all! It is my understanding that the Administrator, Region 7 RA, your DD, and my OD agree that the NRRB should review the remedial action planned for this site. We have some flexibility for when this could happen. We can hold a web conference (not video) during the week of February 13 or 20, or you can join· the already planned meeting the week of March 12 in Chicago. April is difficult due to spring break and we already have a packed meeting the week of April 23. The month of May is wide open. Let me know what works for you.
Here is the Q&A guide for the Board. It contains an outline for the review package and presentation.
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Finai.RPM.NRRB.Manual.12.29.11.doc

Amy R. Legare
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U.S. Environmental Protection Agency
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Superfund
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OSWER/OSRTI/ARD/SARDB 5828 Potomac Yard South MC 5204P 703-347-0124
3/28/2014

Completed Reviews
October 18, 2011 (web conference) Lava Cap OU3 -R9 (consultation)
December 6-7, 2011 -Seattle (NRRB/CST AG -full 2-day meeting) Lower Duwamish -R 1 0
Planned Reviews
March 12-16, 2012-Chicago or Denver Raritan Bay Slag-R2 MEW-R9
March 26-30, 2012-Hanford, WA Tour Hanford 1 00-K Area Hanford 200 UPI Hanford 300 Area
April23-27, 2012-HQ Gowanus Canal-R2 (joint w/ CSTAG) V elsicol -R4 Montross -R9
June 18-22,2012-Philadelphia Ringwood Mine-R2 681h Street Dump -R3 American Creosote-R4
July 23-27, 2012 Sauget Area 2 -R5 Stringfellow-R9 San Gabriel -R9
October 22-26, 2012 Lower Darby -R3 Casmalia -R9
Future Passaic River-R2 (with CSTAG, 2 day meeting) Libby OU4-R8 Portland Harbor-RIO Quendall Terminals-R 10

NATIONAL REMEDY REVIEW BOARD

Questions and Answers for
Superfund Site Managers

December 29, 20 11
1. What is the National Remedy Review Board?
In October 1995, the EPA Administrator announced a collection of initiatives designed to help control remedy costs and to promote consistent and cost-effective Superfund cleanup decisions. As one of these initiatives, the National Remedy Review Board (NRRB, the Board) reviews proposed high-cost cleanup decisions to help evaluate whether they are consistent with current law, regulations, and Agency policy and guidance.
The Board is a technical and policy review group made up of members that have experience with both regional and Headquarters perspectives in the Superfund remedy selection process. Its members include senior managers and technical experts from each EPA region, as well as senior technical and policy experts from other EPA offices. These include the Office of Superfund Remediation and Technology Innovation (OSRTI), Office ofResearch and Development, Office of Radiation and Indoor Air, Federal Facilities Restoration and Reuse Office (FFRRO), Office of Site Remediation Enforcement, and Office ofGeneral Counsel. The Board is chaired by OSRTI.
The Board generally meets quarterly to review proposed decisions that meet its cost-based review criteria. The product of the review is a memorandum sent from the Board to the regional Superfund division director that documents Board recommendations about the proposed cleanup strategy. The Board review process allows full input from EPA regional site managers and other site team members as deemed appropriate by the region whose site is under review. EPA’s site managers are asked to participate in all deliberations to ensure that the Board fully understands the circumstances influencing their proposals.
2. Which sites will the Board review?
Typically, the Board reviews cleanup strategies after the remedial investigation/feasibility study (RVFS) and before the region releases the proposed plan for comment. If necessary, the Board may review sites at other phases of cleanup, possibly before the FS is completed. The Board tries to accommodate regional preferences for scheduling reviews; however, it may not be able to meet all desired regional schedules. It is therefore imperative that site managers work closely with their Board representatives and regional management to schedule sites for review as soon as cost estimates trigger the review criteria outlined below.
Both National Priorities List (NPL) and non-NPL (e.g., “Superfund Alternative”) site actions are reviewed by the Board whenever the Agency expects the work to be done underthe Comprehensive Environmental Response Compensation and Liability Act (CERCLA), in accordance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and other relevant guidance, and when the general criteria below are met. The Board reviews
sites when EPA is directly responsible for the decision or has a concurrence role, including PRP.lead, special account-funded and federal facility-lead sites.
Board Review Criteria
The Board will typically review proposed interim and final Superfund response decisions at both NPL and non-NPL (including Superfund Alternative) sites for which the proposed:

Remedial action costs more than $25 million; or


Non-time critical removal actions (NTCRA), at sites other than a federal facility, is estimated to cost more than $25 million; or

Board reviews will also occur for NPL and non-NPL sites following changes made after the release of the proposed· plan:

A different or modified alternative (which was included in the original proposed plan) is selected by the region that costs more than 20 percent when compared to the original proposal and these costs trigger review criteria (even when the earlier proposed action had undergoneBoard review).


A new alternative is developed and the costs ofthe new alternative would trigger a review.

The Board may review (at regional discretion) sites where the proposed action’s original cost estimate increases more than 20 percent after issuance ofthe Proposed Plan due to either updated cost information or minor changes to the alternative that trigger review criteria. Examples of minor changes are presented in Chapter 7 ofA Guide to Preparing Supe1:(und Proposed Plans, Records ofDecision, and Other Remedy Selection Decision Documents, Office of Solid Waste and Emergency Response Directive No. 9200.1-23P, July 1999 (ROD guidance).
Federal Facility Sites (other than the Department ofEnergy)
Federal facility sites (including Formerly Utilized Sites Remedial Action Program-FUSRAP) follow the same review criteria above with the exception ofNTCRAs; federal facility NTCRAs do not undergo Board review unless requested by the federal facility. Decisions at Base Realignment and Closure (BRAC) sites do not undergo Board review.
Department ofEnergy Sites
The NRRB typically will review sites where the primary contaminant is radioactive waste and · the proposed remedial action costs more than $75 million. The Board will also review NPL sites with NTCRAs exceeding $30 million involving primarily radioactive waste; (per joint Department of Energy/EPA memorandum dated October 5, 1998).
3. Can Regions Request an optional early consultation?
Regions may request an optional NRRB consultation on remedial alternatives at the draft FS scoping stage or any time prior to the draft proposed plan. Regions will not be expected to respond to this early review. Regions should notify states, tribes, local governments, PRPs and local communities when a site will be the subject of an early consultation. Stakeholder, including PRPs, input (up to 10 pages) should be requested as part ofthe early consultation process. This optional consultation will not excuse a site from NRRB review at the proposed plan stage ifthe proposed remedial action meets the NRRB review criteria.
4. Can Regions Request an exemption from Board review?
Regions may request that the NRRB Chair exempt their eligible site from Board review. In addition, Regions can request an exemption in cases where the Region selects a different alternative (after the release of the Proposed Plan for public comment) which costs more than 20 percent from the original proposal and these costs trigger review. The OSRTI office director will make the ‘final exemption decision. The Regional Division Directors can appeal a decision to deny an exemption to the OSRTI Office Director. Regions should offer states, tribes, local governments, PRPs and local communities an opportunity to summarize in writing their opinion regarding the proposed exemption decision. This information will be forwarded to the Board chair along with the exemption request. Regions will not be expected to respond to these letters but will notify the commenters ofthe final decision regarding an exemption.
NRRB Exemption Request Process and Criteria
The region requesting an exemption from an NRRB review should provide a summary of the following information to the Board chair. Exemption requests should not exceed 10 pages.
1.
Site name

2.
Media to be addressed, primary contaminants of concern, preliminary remediation goals

3.
Scope and role of the operable unit or response action

a. Does this action hinge on previous actions?

4.
Risk summary

5.
Remedial action objectives

6.
Alternatives-do they address

a.
TI or MNA?

b.
Treatment of principal threat waste?

c.
Presumptive remedy?

d.
Addressing munitions? (no chemical COCs or groundwater)

7.
Tribal or state ARARs

8.
Stakeholder views

a. Congressional or community controversy?

9.
Decisions requiring headquarters coordination or consultation

a.
Non-time critical removal actions over$ 6M

b.
Remedies for lead, radionuclides, PCBs, asbestos, mercury and dioxin

10.
Concurrence ofregional division director on exemption request

After receipt of the exemption request, the Board chair will hold a conference call with the region to discuss the request. The Board ch~ir will forward the exemption request and recommendation to the OSRTI office director. If the site is a federal facility the FFRRO Board member and office director will participate in the exemption process.
The region should seek input from site stakeholders (e.g., PRPs, states, tribes, and communities) on the request for exemption from NRRB review. Stakeholders may submit up to 10 pages stating their specific issues or concerns. Submissions may be sent to the region or Board Chair at the following address:
Amy Legare
National Remedy Review Board
US EPA
1200 Pennsylvania Ave., NW MC5204P
Washington, DC 20460
Or
[email protected] gov
The OSRTI office director will make the final exemption decision after consultation with the regional division director and consideration of stakeholder input.
5. Will the Board review sites with Record of Decision amendments or Explanation of Significant Differences?
Generally, the Board reviews proposed Record of Decision (ROD) amendments where there is a change from the original remedial strategy (e.g., moving from a containment remedy to a treatment remedy) that results in remedial action costs greater than $25 million.
Generally, the Board does not review ROD amendments where the:

Original remedial strategy remains the same (e.g., where the cost increase results from an unexpected increase in contaminated soil volume), even ifthere is an appreciable change in cost (however, the region should consult with their board representative to contlnn review criteria) or


Amendment results in a cost savings.

The Board usually does not review Explanation of Significant Differences unless the region believes the site would benefit from such a review.
6. Will the Board review sites with final Record of Decision following an interim Record of Decision?
Generally, the Board will review final RODs that follow an interim ROD where there are new significant capital costs in addition to the incremental operation and maintenance (O&M) costs associated with the final ROD. When the costs of a planned final ROD (following an interim ROD) exceed the trigger criteria due to costs driven primarily by the interim remedy’s O&M (e.g., the plant is already constructed and the remaining costs are due to long term system operation), the site does not require Board review. In lieu of a Board review, the region should conduct an optimization review, consistent with EPA guidance, before the final remedy is selected. Information on remedy optimization may be found at this linlc http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm
7. Will the Board review proposed sediment actions that are also subject to Headquarters consultation or Contaminated Sediments Technical Advisory Group review under Office of Solid Waste and Emergency Response Directive 9285.6-08, Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites?
Yes. As explained in the Office of Solid Waste and Emergency Response (OSWER) Directive 9285.6-11, OSRTI Sediment Team and NRRB Coordination at Large Sediment Sites, issued on March 5, 2004, review of consultation memos by the OSRTI Sediment Team (for Tier 1 sites) and by the Contaminated Sediment Technical Advisory Group (CST A G) will be coordinated with the Board so that the region receives only one set ofcomments at the time ofthe proposed plan. This process is explained in more detail below.
Tier 1 Sites
For Tier 1 sites that will undergo a NRRB review, the region should include a draft Tier 1 Consideration Memo in the site information package sent to the Board. A copy ofthe Consideration Memo should also be sent to the appropriate OSRTI regional coordinator and to the OSRTI Sediment Team leader. The OSRTI Sediment Team will review the Consideration Memo and the site package, and will provide comments to the chair of the NRRB prior to the Board’s meeting on the site in question. If the draft Proposed Plan is available, it should also be submitted to the OSRTI regional coordinator and the Sediment Team Leader at that time. If it is not available, it should be submitted as soon as it is drafted. The Sediment Team will not submit separate comments on the Consideration Memo to the region.
As part of its response to the NRRB recommendations, the region should include a revised Tier I Consideration Memo that addresses any comments made by the NRRB related to the issues covered by the Memo. If the NRRB chair and OSRTI Sediment Team leader believe that their comments were not appropriately addressed, and after consultation with the OSRTI Regional Branch Chief, the region may be asked to make additional revisions to the Consideration Memo.
Contaminated Sediments Technical Advisory Group Sites
It is anticipated that the proposed remedy for most ofthe large sites being reviewed by the Contaminated Sediment Technical Advisory Group (CSTAG) will also meet the NRRB review requirements. Therefore, a subset ofCSTAG members will participate in the NRRB review. This subset will be selected based on expertise matching the site characteristics. When a site manager prepares the site package for the NRRB it should include a draft Tier 2 Consideration Memo. The memo should document how the region considered all 11 principles when selecting the site’s proposed remedy; the memo should normally be less than 20 pages in length. The site manager will be provided with one set of recommendations from this joint review.
8. What is the role of the Office of Superfund Remediation and Technology Innovation?
OSRTI will assign an ad hoc Board member for each review. The ad hoc member will be assigned based on the area of expertise required for the review. For example: risk assessment, contaminated sediments, radiation, groundwater contamination, or vapor intrusion. In addition, the technical regional coordinator will work closely with the Board chair on all aspects ofthe revtew.
OSRTI will also work to develop any needed policy, guidance or training materials deemed necessary after each annual review of recommendations. For additional infonnation see Question
28.
9. Will the Board review proposed remedies selected pursuant to presumptive remedy guidance?
Yes, unless the review is waived by the Board chair. Regions and regional Board members are encouraged to consult with the Board chair on presumptive remedies to ensure a productive review of t~e proposed remedy.
10. How long does a typical Board review take?
Generally, the review process takes about eight weeks, from the time the Board receives the informational site package until it transmits its recommendations to the region. Regions should consider this additional time in developing the site work plan and Superfund Comprehensive Accomplishment Plan targets. However, regions should also be aware that, in a few cases, Board recommendations may delay site decisions while the regional decision makers consider and respond to Board findings. Also, the region should allow adequate time for preparation of a comprehensive site package. The average preparation time is generally one to two months.
Board reviews are planned for the first month of each quarter of the year. Site managers should notify their regional Board member and the Board chair of the need for a review as soon as possible so the site can be added to the calendar ofplanned reviews. Generally one to two months time is needed to plan a review with travel, hotel, and meeting space accommodations.
11. What does the Board look at when it reviews a cleanup decision?
Generally, the Board analyzes proposed cleanup strategies to help ensure they are consistent with CERCLA, as amended, the NCP, and relevant EPA cleanup guidance. To assist Board members with these reviews, the region prepares a site information package for each site (see additional questions below and Attachment A for more details). Generally, the Board will not be reviewing the draft FS nor the draft decision document.
When the Board reviews a site, the members consider a variety of information, including elements ofthe RIIFS process related to the development of the alternatives and selection ofthe preferred alternative. Site-specific circumstances often influence the nature of the discussion. Please referto Appendix D for questions frequently asked by the Board.
12. What are the site manager’s responsibilities before the meeting?
As soon as the site manager becomes aware that he/she has a site that may trigger the Board’s · review criteria, the manager should notify his/her regional board member, who, in tum, should coordinate the NRRB review meeting date.
The site manager should:

Convey to the regional board member any preferences regarding review timing. The Board tries hard to accommodate the interests ofthe regions and site managers when scheduling reviews.


Provide the site-specific charging number to the Board chair as soon as possible once it has been determined that the site will come before the Board.


Contact the state and any appropriate tribes, Potentially Responsible Parties (PRPs), community groups, or federal facilities to notify them that the site triggers the review criteria. At this time, discuss with these stakeholders the procedures governing their involvement in the review process. A Community Guide is provided in Appendix E. Questions 16-21 of this packet provide additional information on the usual role ofthese parties in the review process.


Prepare a site information package that the Board will use to conduct its review . Question 13 and Appendix A present information on the package and a recommended outline.


Finalize the informational site package at least four weeks before the meeting and provide the package to the relevant regional NRRB member for distribution to Board members in preparation for the site review. The package will be posted on the Board’s Quickr site so that Board members may download it at their convenience. Oversized charts, maps or tables should be mailed to the Board members. The mailing list is available from the Board’s Quickr site. Please note that two additional copies should be mailed to the Board chair for distribution to OSRTI participants.


Prepare a presentation that summarizes the site, proposedremedy, and major issues. See Appendix C for a suggested outline forthe presentation.


Prepare for the meeting by expecting questions that probe beyond the basic information presented in the site information package (e.g., questions about important assumptions, models, peer reviews or tools used in developing key supporting information). Appendix D presents several lists ofquestions typically asked during the review and deliberations.


OPTIONAL: Participate in a pre-meeting conference call two weeks after the Board

receives the site package (i.e., two weeks before the meeting) to give the Board an opportunity to ask clarifying questions regarding the factual infonnation in the site infonnation package and to possibly request more information prior to the board meeting, or as part of the region’s presentation at the board meeting. The pre-meeting conference call should provide feedback to the region prior to the board meeting as to whether the inforn1ation provided is sufficient to support Board discussion and development of key/substantive recommendations. The Board chair and site manager will decide if a pre.call is necessary.
Recognizing that the reviews generally are part of EPA’s internal deliberative process, please label all documents “DRAFT-DELIBERATIVE.”
13. What should be in the site information package?
Appendix A contains a suggested outline for the site infonnation package.
This informational package should be written as a “stand alone” and succinct document that summarizes the key remedy selection issues faced at the site, and explains the regional rationale for choosing its preferred cleanup strategy. Additional detailed documents may be made available for review, at the region’s discretion, through Quickr or the Superfund Document Management System. The Board expects to base its review and any resulting recommendations primarily on this document. Inclusion of clear and well labeled maps, figures and tables usually are critical to the review.
Site managers should develop a site information package that tells the story and explains the rationale of the cleanup decision at the site in question. That is, the package should identify and explain the key remedy selection issues and support the preferred cleanup strategy. The exact content may vary based on site conditions. However, all packages should include summary information such as site background, contaminants and media ofconcern, site characterization, conceptual site model, key modeling land use assumptions and uncertainties, risk analysis, basis for action, the range of alternatives considered, the preferred remedy, arid the preferred remedy cost breakout. For example, if a chosen cleanup level is driven by Applicable or Relevant and Appropriate Requirements (ARARs), the information package should explain the ARAR, why the region believes it is applicable or relevant and appropriate, how it affects the remedy, etc. This information can help reduce or eliminate the need for exploring the subject during the review meeting. The package should contain a summary of the state and/or tribe position(s) on the site, and have attached any technical submissions from states/tribes, PRPs, federal facilities, Natural Resource Trustees, community groups and/or other stakeholders as appropriate. The Board expects to base its review and any resulting recommendations on this package.
The Board recommends that the site manager have the draft package reviewed by regional staff unfamiliar with the site to be sure the package is clear and consistent. Site managers should take advantage of the resources provided by their regional Board members and OSRTI’s remedy decisions branch; they can give advice on preparing for the review, assembling the package, characterizing key issues, and developing appropriate supporting information.
14. What happens at the meeting?
For each site review, the Board meeting typically lasts one full day and is broken into two stages:
i1~(ormation gathering and deliberations. The role ofthe various stakeholders is described in subsequent sections ofthis manual. The site manager should invite state and appropriate tribal representatives to participate in the information-gathering phase. Typically, these representatives do not participate in the deliberative discussion, which the Board limits to EPA personnel.
The site manager begins the information-gathering phase with a short site briefing. Generally, the briefing should not repeat in detail material already presented in the infonnation package. Rather, it should include a brief overview ofthe site and focus on orienting the Board members to the key site features and key remedy selection issues. Following this briefing; state and/or tribal representatives may present their view of key technical issues. Generally, the total length of the presentations should not exceed one hour (typically EPA 45 minutes, state/tribe 15 minutes). The Board usually spends some time after these presentations asking technical or clarifying questions (refer to Appendix 0 for examples). The site manager should be familiar with community, state/tribe, and/or PRP technical comments, as the Board will explore these as appropriate.
Following the briefings and the question/answer session, the Board deliberates for several hours, focusing on whether the proposed cleanup decision is cost effective, technically sound, and otherwise consistent with the NCP and/or supported by the most current program guidance. The Board asks the site manager and other regional staff, as determined by the region, to attend the deliberations for follow-up questions and to ensure the site manager understands the Board’s proposed recommendations. A draft memorandum normally will be developed at the meeting, detailing any Board findings and recommendations.
Following the review meeting (typically within two to four weeks), the Board chair transmits a final draft ofthe recommendations to Board members and the site manager before issuing the final recommendations memorandum documenting any recommendations or comments to the appropriate regional division director. EPA expects to post the recommendations memo on the Board’s web page within 30 days of the chair’s signature.
The Board considers the review to be an internal, deliberative, and (in certain cases) enforcement-sensitive process. Given the nature of the process, the Board defers to regional judgment with respect to releasing documents related to the reviews, and assumes that regions will comport with established relevant Agency policy. The Board expects the region to place the Board recommendations in the site administrative record at the time a proposed plan is published for comment. Regional materials used to support Board reviews (e.g., review packages, briefing materials, and stakeholder memoranda) should also be retained in the regional site-specific administrative record as appropriate.
15. What happens after the meeting?
Regional Response: Regional division directors are asked to respond in writing within a reasonable time frame to the Board chair regarding how the region has or will address board recommendations. As part of this response, the region is asked to describe how the Board’s review has impacted the cleanup process. The site manager is encouraged to submit a draft ofthe regional response to HQ to resolve any remaining issues prior to the issuance of the proposed plan. The site manager should work closely with the Board chair and OSRTI to incorporate the recommendations in the decision documents.
The Board’s existence does not change EPA’s remedy selection process as provided for in CERCLA and the NCP. The regions retain decision making authority as delineated in formal delegations of authority. The Board does not “approve” or “disapprove” regional proposals. However, the Agency expects decision makers to give Board recommendations substantial weight when finalizing cleanup decisions. Ifissues arise regarding incorporation of recommendations into decision documents, the OSRTI office director can request a discussion with the regional division director to resolve them.
Public inquiries and release ofinfonnation: The regions are expected to handle site-specific inquiries related to the reviews. It is .expected that regions will place Board recommendations and regional response memoranda in the site administrative records on or before the date that the region issues proposed plans for public comment. See question 25 for further clarification.
Record keeping: In the case ofboard-related materials, OSRTI maintains the Agency records of pertinent Board-issued documents (e.g., the board memos, operating protocol, etc.). General information, site-specific Board memoranda, and regional responses are available at: http://www.epa.gov/superfund/programs/nrrblindex.htm. EPA regional offices are responsible for retaining all documents prepared for the presentation package either in the site file or administrative record as appropriate (e.g., the site information packages, PRP and stakeholder submissions and any other information used in the Board process related to the cleanup decision in question). This record-keeping policy is consistent with established Agency guidance.
Web page: The recommendations memo will be posted on the Board’s web page within 30 days ofthe chair’s signature. The Board’s web page will also provide a link to the Superfund Site Progress Profile that will provide links to decision documents and the administrative record. PRP and stakeholder position papers should be included in the administrative record.
16. What is the role of the PRP?
The Board and its current process do not alter existing mechanisms for PRP involvement in the remedy selection process. The current process allows the PRP to work closely with the Agency in conducting the RI!FS, including appropriate, periodic meetings between EPA and the PRPs to ensure that issues such as site characterization, treatability of contaminated media, and the feasibility ofdifferent remedial options are fully considered.
When there is a PRP-lead RI!FS, the site manager should notify the PRPs of the pending review as soon as the region identifies the site as a review candidate. At this time, the region should offer the PRPs an opportunity to summarize in writing, 20 pages or less*, any technical issues they believe are pertinent to the cleanup decision, including their recommended approach and rationale for that approach. The site manager should attach the PRP’s summary to the site infonnation package submitted to the Board four weeks before the meeting. PRP submissions should be made part ofthe administrative record.
The region, at its discretion, may solicit comments from PRPs who do not conduct the RI!FS. Generally, the region may do this in cases where PRPs have been substantively involved in RI!FS work and/or remedy selection issues, or if the region believes that PRPs may offer technical comments critical to understanding key remedy selection issues at the site.
Note that those groups that have not been working closely with the Agency early in the remedy selection process will still have the opportunity to comment formally on the proposed action during the proposed plan corriment period.
PRPs are not involved in any direct discussions with the Board nor are they involved in Board meetings or pre-meeting calls. EPA is responsible for preparation of the Board’s review package.
* PRPs may submit up to 40 pages for sites where the estimated remedial action costs exceed $I OOM.
17. Can Potentially Responsible Parties or others nominate sites for Board review?
Site managers may get calls from PRPs or other stakeholders asking whether a site can be nominated for Board review. The Board expects to review only those decisions that meet the review criteria.
18. What is the role of federal facilities?
Consistent with policy established by EPA’s FFRRO, the Board generally treats federal facilities as PRPs for the purpose of Board reviews.
Please refer to “Which sites will the Board review?” for federal facility review criteria.
19. What is the role of the community?
The Board process does not alter existing mechanisms for community involvement in the remedy selection process. The current community engagement process allows the community to work closely with the Agency in conducting the RI/FS, including appropriate, periodic meetings between EPA and the community to ensure that issues such as site characterization, treatability of contaminated media, and the feasibility of different remedial options are fully considered. The site manager may provide the NRRB Community Guide (Appendix E) to interested stakeholders.
At sites where EPA has awarded a Technical Assistance Grant (TAG) or recognized a Community Advisory Group (CAG), the site manager should notify them of the pending review as soon as the region identifies the site as a review candidate. At this time, the region should offer the TAG/CAG groups an opportunity to summarize in writing, 20 pages or less**, any technical issues they believe are pertinent to the cleanup decision, including their recommended approach and rationale for that approach. The site manager should attach this summary to the site information package submitted to the Board four weeks before the meeting. Stakeholder position papers should be included in the administrative record.
Where the site manager has established close working relationships with other stakeholder groups early in the RVFS process, the site manager may offer these groups the opportunity to submit written technical comment at his/her discretion.
** Stakeholders may submit up to 40 pages for sites where the estimated remedial action costs exceed $1OOM.
Note that those groups thathave not been working closely with the Agency early in the remedy selection process will still have the opportunity to comment formally on the proposed action during the proposed plan comment period.
Community members and TAG technical advisors are not involved in any direct discussions with the Board nor are they involved in Board meetings or pre-meeting calls.
20. Are Board discussions open to the general public?
No. The meetings ofthe Board are pre-decisional, deliberative discussions and are not open to the general public. Reviews generally occur before the region issues the proposed plan. The Agency is generally at an early stage in its decision making process when the Board meets to discuss the proposed action. The intent of this early Board review is to offer a critical discussion on key remedy selection and cost effectiveness issues before the Agency formalizes its position on a preferred cleanup strategy. It is important to note that the Board process does not affect EPA’s current procedures for soliciting public comment on proposed cleanup plans.
The recommendations memo will be posted on the Board’s web page within 30 days of the chair’s signature. The Board’s web page will also provide a link to the Superfund Site Progress Profile that will provide links to decision documents and the administrative record. PRP and stakeholder position papers should be included in the administrative record.
21. How do states and tribal governments participate in the reviews?
For each site, the site manager should invite state and appropriate tribal representatives to participate in the information-gathering phase ofthe Board meeting. Typically, these representatives do not participate in the deliberative discussion, which the Board normally limits to EPA personnel; however, they may be invited to participate for a portion ofthe deliberations where the site is a state/tribe-lead fund-financed decision or state/tribe-lead enforcement decision where the state or tribe seeks EPA concurrence. Otherwise, the Board generally limits its deliberative discussion to Agency personnel.
Regional staff should contact the state or tribal representative early in planning for the Board meeting to discuss the background and purpose ofthe Board, the structure ofthe reviews, and to explain how the state/tribe might best prepare for the meeting. The site manager may also provide the Community Guide (Appendix E) to these representatives for further information. At the meeting, the state/tribe is usually offered approximately I 0-15 minutes to speak about their specific issues or concerns.
The region should also offer the state or tribal representatives an opportunity to summarize in writing, 20 pages or less***, any technical issues they believe are pertinent to the cleanup decision, including their rationale and recommended approach for site cleanup. The site manager should attach this summary to the site infonnation package submitted to the Board four weeks before the meeting. Stakeholder position papers should be included in the administrative record.
22. What is the role of contractors?
Generally, govemment contractors can help prepare presentation and package materials but do not participate in presentations or question and answer sessions at board meetings.
23. Does the region convey the Agency’s preliminary views on the remedy in question (i.e., for stakeholders to react to)?
Generally, stakeholders have an opportunity to contribute their views on remedy selection issues, consistent with the NCP and Agency guidance. Site managers should not provide stakeholders with any preliminary indication ofAgency preferences beyond that which the Agency would provide in the absence of the Board’s review.
24. When is it appropriate for Natural Resource Trustee agencies or the Agency for Toxic Substances and Disease Registry to participate in board reviews?
When a Natural Resource Trustee agency or the Agency for Toxic Substances and Disease Registry have formally provided unique or specialized site-specific teclmical or analytical support for the RIIFS in lieu of(or to supplement) regional expertise in a particular area, the region may invite representative(s) to attend the information-gathering phase ofthe review meeting but must inform the Board chair ofthis invitation.
25. When is it appropriate to release Board memoranda and meeting support materials?
The Agency considers the site-specific Board discussion materials, site names, and operable units under consideration to be deliberative and, where appropriate, enforcement confidential. EPA staff should refer questions regarding the nature ofthe Board discussions and findings to the
*** Up to 40 pages may be submitted for sites where the estimated remedial action costs exceed $1OOM.
appropriate regional board member or site manager.
The product of a Board review is typically a memorandum from the Board chair to the appropriate regional division director. While theAgency strives to be as open as possible about Board reviews, in some cases it may be appropriate for the region to withhold the Board’s recommendations memorandum until the region issues the proposed plan. At that point, the region should place the memorandum in the appropriate site administrative record. The region may release publicly its response to Board recommendations at its discretion, taking into account the internal, deliberative nature ofthe NRRB process. EPA will post the recommendations memo to the Board’s web page within 30 days of the chair’s signature. EPA expects that regions will make the regional response available publicly as soon as it is reasonable and appropriate to do so. EPA will also post the regional response on the Board’s web page.
In addition, the NRRB web page will provide the internet link to the Superfund Site Progress Profile that links to the site decision documents and administrative records containing stakeholder and PRP position papers.
26. Where can I find information about other Board reviews?
Site managers are encouraged to visit the NRRB internet site at http://www.epa.gov/superfund/programs/nrrblindex.htm. This publicly accessible site contains basic information about the NRRB and its formation, criteria that triggers NRRB review, contact information for Board members, site-specific review memoranda, and regional responses to Board recommendations. Site-specific review memoranda may also be found in the site administrative record.
27. How are Board members selected?
HQ Offices and Regions will be requested every two years to re-evaluate their representatives on the NRRB to confinn that the members have the needed expertise, experience, and time to actively participate and contribute. The chair will request this reevaluation. The qualifications for NRRB board members are:

Senior Agency managers


Senior policy experts


Senior technical experts


Areas ofexpertise

o Remedy selection

o Cost-effectiveness

o Program implementation

o National consistency

o Applicable or relevant and appropriate requirements

o CERCLA and the NCP

o Superfund policy and guidance


Available to travel at least one week per quarter to discuss proposed remedies


Ability to commit time for a detailed analysis of review packages

o Typically three review packages per quarter


Ability to reach consensus and craft recommendations to promote both consistent and cost-effective decisions at Superfund sites

28. How are recommendations used to benefit the Superfund Program?
Every year the NRRB, in consultation with the regions and OSRTI regional coordinators, will evaluate all the reviews written over that year, looking for recurring issues. OSRTI will work to develop any needed policy, guidance or training materials.
Appendix A
RECOMMENDED OUTLINE
FOR THE SITE INFORMATION PACKAGE

Recommended Outline for the Site Information Package
Inclusion of clear and well labeled maps, tables, and figures with sufficient detail are critical to the review. Time spent by the site manager in preparing the site information package, and additional regional review ofthe draft site information package, is to the advantage of everyone involved in the reviews, as complex site decisions will likely benefit from careful preparation.
It is recommended that an internal review of the draft site infom1ation package be conducted by a colleague that is unfamiliar with the site.
All reference to ROD Guidance Highlights (e.g. ROD Guidance Highlights 6-18 to 6-20) refer to examples found in OSWER Directive 9200.1-23.P, A Guide to Preparing Supe1:{imd Proposed Plans, Records ofDecision, and Other Remedy Selection Decision Documents.
A. Summary (less than five pages)
1) Site Summary

Site name and location


Site account number


Orientation to the key features ofthe site and surrounding area


On site and surrounding land use


Brief site contamination history, and facility operational history


Identify media and primary contaminants of concern (COCs) addressed by this proposed action


List the operable units addressed by this action and the media addressed by each

2) Risk Summary
Good examples ofrisk summary tables to include in the package can be found in ROD Guidance Highlights 6-18 through 6-20.

Identify by medium and operable units, the cumulative risk (if applicable), and land use scenario( s)


Identify by medium and operable units, if applicable, the primary risk drivers

3) Cleanup levels
Include a brief summary table ofremedial action objectives (RAOs) and cleanup levels. If applicable, identify by medium and operable unit (see highlight 6-21 in the ROD Guidance identified in the Risk Summary section).
4) Description of Alternatives
Describe in a brief summary table the following for each medium and operable unit (if applicable):
• Identify remedial alternatives evaluated and associated costs

Identify expected time to achieve cleanup levels 5) Preferred Alternative In bullet fonnat, include the following for each medium and operable unit, if applicable:

• Describe remedy and estimated costs of major activities


Identify expected time to achieve cleanup levels 6) Stakeholder views


State’s position on proposed action


Other stakeholder views

B.
Detailed Information

1) Site N arne, Location, and Brief Description

Include an area map and detailed site maps with well labeled key features. Include an aerial
photograph, if available.
2) Site History and Enforcement Activities
Chronological list of significant enforcement actions, including principal PRPs.

3) Scope and Role of Operable Unit or Response Action
Discuss how the operable unit or response action addressed by the proposed plan fits into the
overall site strategy. This discussion should describe the overall site cleanup strategy, including:


The planned sequence of actions


The scope of problems those actions will address


The authorities under which each action will be/has been implemented (e.g., removal, remedial final, or remedial interim)

4) Site Characteristics

Describe the Baseline Risk Assessment Conceptual Site Model (CSM) on which the risk assessment and response action are based


Provide an overview ofthe site, including the following:
Size of site (e.g., acres)

-Geographical and topographical infonnation (e.g., surface waters, flood plains, wetlands) Surface and subsurface features (e.g., number and volume oftanks, lagoons, structures, and drums on the site)
– Areas of archaeological or historical importance

Describe known or suspected sources of contamination


Describe types of contamination and the affected media (summarize in tables), including the following: -Types and characteristics of contaminants (e.g., toxic, mobile, carcinogenic,

non-carcinogenic) -Quantity/volume ofwaste -Concentrations of contaminants in each medium (see ROD Guidance Highlight 6.
15) and figures that illustrate hot spots, e.g. isopleths
-RCRA hazardous wastes and affected media


Include figures showing contaminant level changes over time


Describe location of contamination and known or potential routes of migration, including the following: Lateral and vertical extent of contamination -Current and potential future surface and subsurface routes ofhuman or environmental exposure

– Conceptual site model of the potential migration pathways of COCs in all media Human and ecological populations that are or could be affected


For sites with groundwater and surface water contamination, describe the following:

-Aquifer(s) affected or threatened by site contamination, types ofgeologic materials, approximate depths, whether aquifer is confined or unconfined Sources and source areas of groundwater and surface water contamination, including information on non-aqueous phase liquid extent, location, and characteristics
– Groundwater flow directions within each aquifer and between aquifers and groundwater discharge locations (e.g., surface waters, wetlands, other aquifers)
– Appropriate maps and cross sections showing stratigraphy and monitoring well
layout
• Identify any computer models used that served as the basis for risk, fate and transport, or ARAR compliance decisions. For non-EPA recommended model applications, list the input parameters: measured data, literature data, and default inputs used in the predicted outputs. Also, include results of model uncertainty and sensitivity analysis for key site parameters.
5) Current and Potential Future Site and Resource Uses:
Land Use

Current on-site land uses


Current adjacent/surroundingland uses


Reasonably anticipated future land uses, with expected time frames for such l!ses, and basis for future use assumptions (e.g., zoning maps, nearby development, 20-year development plans, dialogue with local land use planning officials and citizens).

Ground and Surface Water Use

Current ground/surface water uses on the site and in its vicinity


Potential beneficial ground/surface water uses (e.g., potential drinking water, irrigation, recreational) and basis for future use assumptions (e.g., Comprehensive State Groundwater Protection Plan, promulgated State classification, EPA groundwater classification guidelines)


Ifbeneficial use is an anticipated drinking water source, identify the approximate time frame ofprojected future drinking water use (e.g., groundwater aquifer not currently used as a drinking water source but expected to be utilized in future years)


Location of anticipated use in relation to location and anticipated migration of
contamination.

6) Summary ofRisk1:
Human Health Risk Assessment
• Identify potentially exposed populations in current and future scenarios (e.g., worker
currently working on site, adults and children living on site in the future)

1 The site information package should include a synopsis of the risk assessment(s). Detailed information may be provided by posting documents to the Board’s Quickr site or by providing the Superfund Document Management System document identification number.

Identify sensitive sub-populations (highly exposed and/or more susceptible) that may be exposed (e.g., farm families, children, subsistence fishermen)


Identify the routes by which each population group or sub-population group could reasonably be exposed to site contaminants (e.g., ingestion ofcontaminated groundwater for adults and children, inhalation of volatile contaminants for workers)


Include major assumptions about exposure frequency, duration, and other exposure factors that were included in the exposure assessment (e.g., exposure frequency [days/year], exposure duration [years], and body surface area for dermal exposure) could be included in an appendix


Highlight any non-standard exposure assumptions used in the baseline risk assessments


Provide a summary (preferably a table) that includes the following for all current and future land use scenarios presenting unacceptable risks: -Quantified carcinogenic risks for each COC in each exposure medium for each relevant exposure pathway -Combined carcinogenic risks reflecting total exposure to COCs in a given medium and pathway of exposure -Potential for non-carcinogenic impacts as quantified by the hazard quotient for each COC in each exposure medium for ~ach exposure pathway, as appropriate

-Potential for combined non-carcinogenic effects in each medium and pathway of exposure as expressed by hazard indices, which reflect the potential additive effects of COCs that affect the same target organ or system
– Identify key uncertainties in the baseline risk assessment
• If applicable, describe how radiological risks were calculated .
Ecological Risk Assessment (particularly where these risks drive remedy selection)

What are the assessment endpoints determined to be at risk (the foundation of the
remedial decisions, that is, the risk drivers)?


Which of these risks would require remedial action?


Which site contaminants were determined to be causal and by which exposure routes (i.e., what is the conceptual model/exposure model?).


Describe the thresholds ofexposure generating risk, and at what level ofexposure do the risk levels become severe?


What is the confidence in the risk estimates? Are there documented effects?


_Describe any site-specific data that were available


How large is the area for which ecological risks have been estimated?


Description ofkey species that could be exposed


Describe complete exposure pathways, present the conceptual site model


Monitoring or modeling data and assumptions


The ROD Guidance (Pages 6-22 to 6-25) provides summary tables that would supply the above requested information.

7) Remedial Action Objectives and Preliminary Remediation Goals

Present the basis and rationale for remedial action objectives (RAOs) & preliminary remediation goals (PRGs) (e.g., current and reasonably anticipated future land use and potential beneficial groundwater use)


Describe how the RAOs & PRGs address risks identified in the risk assessment (e.g., how will the risks driving the need for action be addressed by the response action?)


Identify any key ARARs that are driving the remedy selection


Where ecological risks drive the remedy, provide the range of protective cleanup levels and their basis.


Explain how cleanup levels are developed from these goals considering the remedy
selection criteria.


Explain the role ofbackground in the evaluation of cleanup levels.

8) Description of Alternatives:
• Provide a bulleted list and appropriate figures of the major components of each alternative. The package should include the following: -Treatment technologies and materials they will address (e.g., source materials constituting principal threats)
-Containment components ofremedy (e.g., engineering controls, cap, hydraulic barriers) and materials they will address (e.g., low concentration source materials, treatment residuals)
– Description of institutional controls and how they will be implemented and maintained and the duration -For alternatives that depend upon monitored natural attenuation, demonstrate compliance with EPA policy

Provide the total estimated capital, annual operation and maintenance (O&M), and total present worth costs, discount rate, and the number ofyears over which the remedy cost estimates are projected


Summarize the capital and annual O&M costs associated with each of the major
components of each alternative

9) Comparative Analysis of Alternatives
Provide a summary table and discussion comparing alternatives that pass the threshold criteria against the nine criteria.
1 0) Principal Threat Waste Clearly identify how source materials constituting principal threats are addressed or provide an explanation ofwhy the site does not have principal threat waste (refer to A Guide to Principal Threat and LoH’ Level Threat Wastes-OSWER 9380.3-06FS, November 1991).
11) Preferred Alternative

Clearly describe the preferred alternative and how, if appropriate, it is different from the alternatives evaluated


Describe the key factor(s) that led to selecting the preferred alternative (i.e., describe how the remedy provides the best balance oftradeoffs with respect to the balancing and modifying criteria, highlighting criteria key to the decision)

12) Applicable or Relevant and Appropriate Requirements2

List the principal ARARs for the preferred alternative


Describe the ARARs that are drivers for the remedy


For each driver, explain why it is an ARAR (versus a “to be considered”)


Where actual language of the regulation is key to the Board review, include a copy of the relevant section in an appendix to the package

13) Technical & Policy Issues
Include a discussion of technical or policy issues that require further discussion prior to implementation of the preferred alternative (data gathering, ARARs, treatability studies, modeling.
14) Cost Information4

Include sufficient information to provide an estimate of total resource costs over time

(i.e., life cycle costs) for all alternatives including (ROD Guidance Highlight 6-29) -Capital costs -Annual operations and maintenance costs -Net present value of capital and O&M costs


Cost estimate summaries should address the following: -The key cost components/elements for both Remedial Action and O&M activities -The major sources of uncertainty in the cost estimate

2 The site information package should include a synopsis of this infonnation. Detailed information may be provided by posting documents to the Board’s Quickr site or by providing the Superfund Document Management System document identification number.
– The discount rate used
-The time expected to achieve RAOs and remedial goals Periodic capital and/or O&M costs anticipated in future years ofthe project (e.g., remedy replacement or rebuild)
-The methods and resources used for preparing the cost estimate (e.g., estimating guides, vendor quotes, computer cost models)

For contingency remedy decisions, the total project costs for implementing the contingency should be provided in addition to the costs for the conditional action. This estimate should include treatability study costs, if applicable.


The assumptions used to develop the cost estimate should be consistent with the stated RAOs and remedial goals (e.g., duration of the cost estimate should match time to achieve cleanup objectives).

15) Letters from Stakeholders and State
Include in the package any technical comments provided by the state or other stakeholders.
Appendix B
SAMPLE AGENDA FOR THE BOARD MEETING

Sample NRRB Meeting Agenda
8:30-8:45 Introductions
8:45-9:45 Site Presentations (1 0-15 minutes additional time for state/tribal presentations)
9:45-10:00 BREAK 10:00-11:30 Questions & Answers 11:30-12:30 LUNCH
The following sessions are for EPA staff only 12:30-2:15 Deliberations
2:15-2:30 BREAK
2:30-3:00 Board Business (not site-specific)
3:00-5:00 Write and Review Board Recommendations
5:00 ADJOURN
Appendix C
RECOMMENDED OUTLINE
FOR THE BOARD PRESENTATION

Recommended Outline for the Board Presentation
The main emphasis of the presentation, which typically runs one hour in length, should be on the preferred alternative. Hard copies ofthe presentation should be provided for all Board members at the meeting (preferably two slides per page).
Although not reconunended for the presentation, site managers should have key figures available (electronically ifpossible) from the RJJFS and site infonnation package in case of questions during the discussions.
The following suggested times should be used as a guide but are not mandatory:

Site Summary & Risk Summary-I 0


RAO & Description ofAlternatives-I5


Preferred Alternative-25


Stakeholder Views or Presentation-I 0

I) Site Summary

Orientation to the key features of the site and surrounding area (including maps)


On site and surrounding land use


Brief site contamination history, and facility operational history


Identify media and primary COCs addressed by this proposed action


List the other operable units at the site and the media addressed by each

2) Risk Summary

Identify by medium and operable units, the cumulative risk (if applicable), and land use scenario(s)


Identify by medium and operable units, if applicable, the primary risk drivers

3) Remedial Action Objectives and PRGs

Present the basis and rationale for RAOs and PRGs (e.g., current and reasonably
anticipated future land use and potential beneficial groundwater use)


Describe how the RAOs and PRGs address risks identified in the risk assessment (e.g., how will the risks driving the need for action be addressed by the response action?)


Identify any key ARARs that are driving the remedy selection

4) Description of Alternatives Describe in bullet fonnat the following for each medium and operable unit (if applicable):

Briefly identify key components of all remedial alternatives evaluated and associated costs


Identify risk reduction and expected time to achieve cleanup levels

5) Preferred Alternative

Provide a brief summary table or figure that compares all the alternatives, clearly
illustrating the commonality and differences between each alternative


For the preferred alternative, identify for each medium and operable unit: -The rationale and key factors that led to the selection of the preferred alternative -The remedy and estimated costs ofmajor activities

Expected time to achieve cleanup levels
Major technical and other unresolved issues

6) Stakeholder views .

State’s position on the proposed action


Other stakeholder views

Appendix D

QUESTIONS FREQUENTLY ASKED
BY BOARD MEMBERS

Appendix D -Questions Frequently Asked by the NRRB Members
1) NRRB discussion guide
General Groundwater Soil Sediment
Land/Water Use What are future use assumptions for the site? Are the bases for these assumptions clear? Are these assumptions consistent with state/local designations? Have efforts been made to discuss the future use with site owners, local government representatives, and other stakeholders? . What are future use assumptions for groundwater? What are future use assumptions for land? What are future use assumptions for surface water and flood plains?
Was reuse/beneficial use considered for land, water, or treatment residuals, as appropriate?
Exposure Scenarios/Risk Assumptions Are exposure scenarios and risk assumptions reasonable and consistent with future uses? Have the latest toxicity data been used (e.g., PCBs/dioxin)? What are the risk drivers for the site-media, pathways, contaminants? Is remedial action necessary? Has the groundwater/surface water pathway been adequately considered? Has ecological risk been adequately addressed? Has ecological risk been adequately addressed? Where contaminants are bioaccumulative, were appropriate fish/shellfish consumption rates used for risk analysis and are they reasonable?
Remedial Action Objectives & Cleanup Levels What are the RAOs and cleanup levels and do they adequately address risk drivers? Is it clear how cleanup levels were selected? Are RAOs and cleanup levels reasonable and clearly linked to each other? Is it clear whether the goal is restoration and/or containment? What is the expected time frame to meet cleanup levels for groundwater? How were cleanup levels for biota selected? What is the expected time frame to meet cleanup levels for sediment and RAOs for biota? What level of fish/shellfish consumption is the remedy expected to

achieve, and when?
Appendix D-Questions Frequently Asked by the NRRB Members
General Groundwater Soil Sediment
Were a variety of cleanup levels considered? Are the major ARARs identified and are there any special issues? Have the principal threat wastes been identified and does the proposed remedy anticipate treatment or explain why it is not appropriate? Where RAOs for biota will not be met for a long time, have interim goals or benchmarks been identified as appropriate?
Remedy Effectiveness Is the preferred alternative likely to be effective in meeting cleanup levels and RAOs? Are any existing source control actions effective and have any ongoing sources been appropriately incorporated into decision-making? If treatment is proposed, is a pilot necessary and if so, is it proposed? If institutional controls are necessary, are they likely to be effective? Should a contingency remedy be specified and if so, has it been? Does the proposed remedy include monitoring adequate to evaluate remedy effectiveness? Is DNAPL likely to be present? Ifyes: Do cleanup goals adequatel

Post

2012-06-20 – Gravatt, Dan – A look into the murky future of West Lake

West Lake Landfill: bullets for fact sheet Dan Gravatt to: Debbie Kring 06/20/2012 11:05 AM
Debbie, as you requested, here is a look into the murky future of West Lake to assist you with the fact sheet:
-PRPs have agreed to do one additional round of groundwater sampling from all usable/accessible/intact monitoring wells at the site, from OU1 and OU2. Paul Rosasco’s workplan identifies 80 wells that are definitely or probably usable/accessible/intact and will be sampled. Sampling is for uranium, thorium, and radium isotopes, plus metals, VOCs and SVOCs.
-EPA received the PRP’s workplan for the groundwater sampling on June 8, and commented on it. The final workplan is due June 28.
-The PRP’s groundwater sampling work will likely begin in July and last for about a month. Both EPA and MDNR intend to split some of the groundwater samples.
-Following the PRP’s groundwater monitoring fieldwork, EPA will mobilize to the field to re-do surface gamma scans of the OU1 cells, and conduct down-hole gamma logs of the usable/accessible/intact monitoring wells. This should happen in August.
-The PRPs also agreed on June 14th to do additional studies to supplement the SFS, including a detailed study of the partial excavation alternative, other landfill cover designs, apatite treatment evaluations, groundwater fate and transport, and an adjustment to the discount rate in the cost estimate. This work will be handled under a separate work plan (probably an addendum to the original SFS WP) that has not been scoped as yet, though we expect it will take at least a year to complete these additional studies.
-It is my understanding, based on Karl’s directions at our last briefing, that we’ll have a public availability session in December or so to describe to the public the additional sampling and studies that we have planned.
Hope this helps.
Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Pax (913) 551-7063
Principles and integrity are expensive, but they are among the very few things worth having.
D?lit \lliiii~-~ 3.o

Superfund
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Post

2012-01-25 – Legare, Amy – NRRB 2012 Meeting Schedule

{In Archive} Fw: NRRB review of Westlake Landfill Craig Smith to: Dan Gravatt 01/25/2012 03:42PM Cc: DeAndre Singletary, Audrey Asher, Robertw Jackson, Cecilia Tapia
Archive: This message is being viewed in an archive.
As Amy said, here is the current schedule of meetings:
~r-:1
FY 2012 NRRB Meeting Calendar.docx
The guidance calls for the review packages as follows, so this may influence the schedule:
“Finalize the informational site package at least four weeks before the meeting and provide the package to the relevant regional NRRB member for distribution to Board members in preparation for the site review. The package will be posted on the Board’s Quickr site so that Board members may download it at their convenience. Oversized charts, maps or tables should be mailed to the Board members. The mailing list is available from the Board’s Quickr site. Please note that two additional copies should be mailed to the Board chair for distribution to OSRTI participants.”
Let me know what looks good.
Thanks, Craig S
Craig W. Smith, P.E. Senior Engineer and Policy Coordinator Superfund Division USEPA Region 7 Kansas City
(913) 551-7683
—–Forwarded by Craig Smith/SUPR/R7/USEPAIUS on 01/25/2012 03:28PM—-.
From: Amy Legare/DC/USEPAIUS· To: Dan Gravatt/R7/[email protected], Craig Smith/SUPR/R7/[email protected] Cc: Dave Crawford/DC/[email protected], Gary Worthman/DC/[email protected] Date: 01/25/2012 12:28 PM Subject: NRRB review of Westlake Landfill
Hello all! It is my understanding that the Administrator, Region 7 RA, your DD, and my OD agree that the NRRB should review the remedial action planned for this site. We have some flexibility for when this could happen. We can hold a web conference (not video) during the week of February 13 or 20, or you can join· the already planned meeting the week of March 12 in Chicago. April is difficult due to spring break and we already have a packed meeting the week of April 23. The month of May is wide open. Let me know what works for you.
Here is the Q&A guide for the Board. It contains an outline for the review package and presentation.
§1
Finai.RPM.NRRB.Manual.12.29.11.doc

Amy R. Legare
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U.S. Environmental Protection Agency
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Superfund
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OSWER/OSRTI/ARD/SARDB 5828 Potomac Yard South MC 5204P 703-347-0124
3/28/2014

Completed Reviews
October 18, 2011 (web conference) Lava Cap OU3 -R9 (consultation)
December 6-7, 2011 -Seattle (NRRB/CST AG -full 2-day meeting) Lower Duwamish -R 1 0
Planned Reviews
March 12-16, 2012-Chicago or Denver Raritan Bay Slag-R2 MEW-R9
March 26-30, 2012-Hanford, WA Tour Hanford 1 00-K Area Hanford 200 UPI Hanford 300 Area
April23-27, 2012-HQ Gowanus Canal-R2 (joint w/ CSTAG) V elsicol -R4 Montross -R9
June 18-22,2012-Philadelphia Ringwood Mine-R2 681h Street Dump -R3 American Creosote-R4
July 23-27, 2012 Sauget Area 2 -R5 Stringfellow-R9 San Gabriel -R9
October 22-26, 2012 Lower Darby -R3 Casmalia -R9
Future Passaic River-R2 (with CSTAG, 2 day meeting) Libby OU4-R8 Portland Harbor-RIO Quendall Terminals-R 10

NATIONAL REMEDY REVIEW BOARD

Questions and Answers for
Superfund Site Managers

December 29, 20 11
1. What is the National Remedy Review Board?
In October 1995, the EPA Administrator announced a collection of initiatives designed to help control remedy costs and to promote consistent and cost-effective Superfund cleanup decisions. As one of these initiatives, the National Remedy Review Board (NRRB, the Board) reviews proposed high-cost cleanup decisions to help evaluate whether they are consistent with current law, regulations, and Agency policy and guidance.
The Board is a technical and policy review group made up of members that have experience with both regional and Headquarters perspectives in the Superfund remedy selection process. Its members include senior managers and technical experts from each EPA region, as well as senior technical and policy experts from other EPA offices. These include the Office of Superfund Remediation and Technology Innovation (OSRTI), Office ofResearch and Development, Office of Radiation and Indoor Air, Federal Facilities Restoration and Reuse Office (FFRRO), Office of Site Remediation Enforcement, and Office ofGeneral Counsel. The Board is chaired by OSRTI.
The Board generally meets quarterly to review proposed decisions that meet its cost-based review criteria. The product of the review is a memorandum sent from the Board to the regional Superfund division director that documents Board recommendations about the proposed cleanup strategy. The Board review process allows full input from EPA regional site managers and other site team members as deemed appropriate by the region whose site is under review. EPA’s site managers are asked to participate in all deliberations to ensure that the Board fully understands the circumstances influencing their proposals.
2. Which sites will the Board review?
Typically, the Board reviews cleanup strategies after the remedial investigation/feasibility study (RVFS) and before the region releases the proposed plan for comment. If necessary, the Board may review sites at other phases of cleanup, possibly before the FS is completed. The Board tries to accommodate regional preferences for scheduling reviews; however, it may not be able to meet all desired regional schedules. It is therefore imperative that site managers work closely with their Board representatives and regional management to schedule sites for review as soon as cost estimates trigger the review criteria outlined below.
Both National Priorities List (NPL) and non-NPL (e.g., “Superfund Alternative”) site actions are reviewed by the Board whenever the Agency expects the work to be done underthe Comprehensive Environmental Response Compensation and Liability Act (CERCLA), in accordance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and other relevant guidance, and when the general criteria below are met. The Board reviews
sites when EPA is directly responsible for the decision or has a concurrence role, including PRP.lead, special account-funded and federal facility-lead sites.
Board Review Criteria
The Board will typically review proposed interim and final Superfund response decisions at both NPL and non-NPL (including Superfund Alternative) sites for which the proposed:

Remedial action costs more than $25 million; or


Non-time critical removal actions (NTCRA), at sites other than a federal facility, is estimated to cost more than $25 million; or

Board reviews will also occur for NPL and non-NPL sites following changes made after the release of the proposed· plan:

A different or modified alternative (which was included in the original proposed plan) is selected by the region that costs more than 20 percent when compared to the original proposal and these costs trigger review criteria (even when the earlier proposed action had undergoneBoard review).


A new alternative is developed and the costs ofthe new alternative would trigger a review.

The Board may review (at regional discretion) sites where the proposed action’s original cost estimate increases more than 20 percent after issuance ofthe Proposed Plan due to either updated cost information or minor changes to the alternative that trigger review criteria. Examples of minor changes are presented in Chapter 7 ofA Guide to Preparing Supe1:(und Proposed Plans, Records ofDecision, and Other Remedy Selection Decision Documents, Office of Solid Waste and Emergency Response Directive No. 9200.1-23P, July 1999 (ROD guidance).
Federal Facility Sites (other than the Department ofEnergy)
Federal facility sites (including Formerly Utilized Sites Remedial Action Program-FUSRAP) follow the same review criteria above with the exception ofNTCRAs; federal facility NTCRAs do not undergo Board review unless requested by the federal facility. Decisions at Base Realignment and Closure (BRAC) sites do not undergo Board review.
Department ofEnergy Sites
The NRRB typically will review sites where the primary contaminant is radioactive waste and · the proposed remedial action costs more than $75 million. The Board will also review NPL sites with NTCRAs exceeding $30 million involving primarily radioactive waste; (per joint Department of Energy/EPA memorandum dated October 5, 1998).
3. Can Regions Request an optional early consultation?
Regions may request an optional NRRB consultation on remedial alternatives at the draft FS scoping stage or any time prior to the draft proposed plan. Regions will not be expected to respond to this early review. Regions should notify states, tribes, local governments, PRPs and local communities when a site will be the subject of an early consultation. Stakeholder, including PRPs, input (up to 10 pages) should be requested as part ofthe early consultation process. This optional consultation will not excuse a site from NRRB review at the proposed plan stage ifthe proposed remedial action meets the NRRB review criteria.
4. Can Regions Request an exemption from Board review?
Regions may request that the NRRB Chair exempt their eligible site from Board review. In addition, Regions can request an exemption in cases where the Region selects a different alternative (after the release of the Proposed Plan for public comment) which costs more than 20 percent from the original proposal and these costs trigger review. The OSRTI office director will make the ‘final exemption decision. The Regional Division Directors can appeal a decision to deny an exemption to the OSRTI Office Director. Regions should offer states, tribes, local governments, PRPs and local communities an opportunity to summarize in writing their opinion regarding the proposed exemption decision. This information will be forwarded to the Board chair along with the exemption request. Regions will not be expected to respond to these letters but will notify the commenters ofthe final decision regarding an exemption.
NRRB Exemption Request Process and Criteria
The region requesting an exemption from an NRRB review should provide a summary of the following information to the Board chair. Exemption requests should not exceed 10 pages.
1.
Site name

2.
Media to be addressed, primary contaminants of concern, preliminary remediation goals

3.
Scope and role of the operable unit or response action

a. Does this action hinge on previous actions?

4.
Risk summary

5.
Remedial action objectives

6.
Alternatives-do they address

a.
TI or MNA?

b.
Treatment of principal threat waste?

c.
Presumptive remedy?

d.
Addressing munitions? (no chemical COCs or groundwater)

7.
Tribal or state ARARs

8.
Stakeholder views

a. Congressional or community controversy?

9.
Decisions requiring headquarters coordination or consultation

a.
Non-time critical removal actions over$ 6M

b.
Remedies for lead, radionuclides, PCBs, asbestos, mercury and dioxin

10.
Concurrence ofregional division director on exemption request

After receipt of the exemption request, the Board chair will hold a conference call with the region to discuss the request. The Board ch~ir will forward the exemption request and recommendation to the OSRTI office director. If the site is a federal facility the FFRRO Board member and office director will participate in the exemption process.
The region should seek input from site stakeholders (e.g., PRPs, states, tribes, and communities) on the request for exemption from NRRB review. Stakeholders may submit up to 10 pages stating their specific issues or concerns. Submissions may be sent to the region or Board Chair at the following address:
Amy Legare
National Remedy Review Board
US EPA
1200 Pennsylvania Ave., NW MC5204P
Washington, DC 20460
Or
[email protected] gov
The OSRTI office director will make the final exemption decision after consultation with the regional division director and consideration of stakeholder input.
5. Will the Board review sites with Record of Decision amendments or Explanation of Significant Differences?
Generally, the Board reviews proposed Record of Decision (ROD) amendments where there is a change from the original remedial strategy (e.g., moving from a containment remedy to a treatment remedy) that results in remedial action costs greater than $25 million.
Generally, the Board does not review ROD amendments where the:

Original remedial strategy remains the same (e.g., where the cost increase results from an unexpected increase in contaminated soil volume), even ifthere is an appreciable change in cost (however, the region should consult with their board representative to contlnn review criteria) or


Amendment results in a cost savings.

The Board usually does not review Explanation of Significant Differences unless the region believes the site would benefit from such a review.
6. Will the Board review sites with final Record of Decision following an interim Record of Decision?
Generally, the Board will review final RODs that follow an interim ROD where there are new significant capital costs in addition to the incremental operation and maintenance (O&M) costs associated with the final ROD. When the costs of a planned final ROD (following an interim ROD) exceed the trigger criteria due to costs driven primarily by the interim remedy’s O&M (e.g., the plant is already constructed and the remaining costs are due to long term system operation), the site does not require Board review. In lieu of a Board review, the region should conduct an optimization review, consistent with EPA guidance, before the final remedy is selected. Information on remedy optimization may be found at this linlc http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm
7. Will the Board review proposed sediment actions that are also subject to Headquarters consultation or Contaminated Sediments Technical Advisory Group review under Office of Solid Waste and Emergency Response Directive 9285.6-08, Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites?
Yes. As explained in the Office of Solid Waste and Emergency Response (OSWER) Directive 9285.6-11, OSRTI Sediment Team and NRRB Coordination at Large Sediment Sites, issued on March 5, 2004, review of consultation memos by the OSRTI Sediment Team (for Tier 1 sites) and by the Contaminated Sediment Technical Advisory Group (CST A G) will be coordinated with the Board so that the region receives only one set ofcomments at the time ofthe proposed plan. This process is explained in more detail below.
Tier 1 Sites
For Tier 1 sites that will undergo a NRRB review, the region should include a draft Tier 1 Consideration Memo in the site information package sent to the Board. A copy ofthe Consideration Memo should also be sent to the appropriate OSRTI regional coordinator and to the OSRTI Sediment Team leader. The OSRTI Sediment Team will review the Consideration Memo and the site package, and will provide comments to the chair of the NRRB prior to the Board’s meeting on the site in question. If the draft Proposed Plan is available, it should also be submitted to the OSRTI regional coordinator and the Sediment Team Leader at that time. If it is not available, it should be submitted as soon as it is drafted. The Sediment Team will not submit separate comments on the Consideration Memo to the region.
As part of its response to the NRRB recommendations, the region should include a revised Tier I Consideration Memo that addresses any comments made by the NRRB related to the issues covered by the Memo. If the NRRB chair and OSRTI Sediment Team leader believe that their comments were not appropriately addressed, and after consultation with the OSRTI Regional Branch Chief, the region may be asked to make additional revisions to the Consideration Memo.
Contaminated Sediments Technical Advisory Group Sites
It is anticipated that the proposed remedy for most ofthe large sites being reviewed by the Contaminated Sediment Technical Advisory Group (CSTAG) will also meet the NRRB review requirements. Therefore, a subset ofCSTAG members will participate in the NRRB review. This subset will be selected based on expertise matching the site characteristics. When a site manager prepares the site package for the NRRB it should include a draft Tier 2 Consideration Memo. The memo should document how the region considered all 11 principles when selecting the site’s proposed remedy; the memo should normally be less than 20 pages in length. The site manager will be provided with one set of recommendations from this joint review.
8. What is the role of the Office of Superfund Remediation and Technology Innovation?
OSRTI will assign an ad hoc Board member for each review. The ad hoc member will be assigned based on the area of expertise required for the review. For example: risk assessment, contaminated sediments, radiation, groundwater contamination, or vapor intrusion. In addition, the technical regional coordinator will work closely with the Board chair on all aspects ofthe revtew.
OSRTI will also work to develop any needed policy, guidance or training materials deemed necessary after each annual review of recommendations. For additional infonnation see Question
28.
9. Will the Board review proposed remedies selected pursuant to presumptive remedy guidance?
Yes, unless the review is waived by the Board chair. Regions and regional Board members are encouraged to consult with the Board chair on presumptive remedies to ensure a productive review of t~e proposed remedy.
10. How long does a typical Board review take?
Generally, the review process takes about eight weeks, from the time the Board receives the informational site package until it transmits its recommendations to the region. Regions should consider this additional time in developing the site work plan and Superfund Comprehensive Accomplishment Plan targets. However, regions should also be aware that, in a few cases, Board recommendations may delay site decisions while the regional decision makers consider and respond to Board findings. Also, the region should allow adequate time for preparation of a comprehensive site package. The average preparation time is generally one to two months.
Board reviews are planned for the first month of each quarter of the year. Site managers should notify their regional Board member and the Board chair of the need for a review as soon as possible so the site can be added to the calendar ofplanned reviews. Generally one to two months time is needed to plan a review with travel, hotel, and meeting space accommodations.
11. What does the Board look at when it reviews a cleanup decision?
Generally, the Board analyzes proposed cleanup strategies to help ensure they are consistent with CERCLA, as amended, the NCP, and relevant EPA cleanup guidance. To assist Board members with these reviews, the region prepares a site information package for each site (see additional questions below and Attachment A for more details). Generally, the Board will not be reviewing the draft FS nor the draft decision document.
When the Board reviews a site, the members consider a variety of information, including elements ofthe RIIFS process related to the development of the alternatives and selection ofthe preferred alternative. Site-specific circumstances often influence the nature of the discussion. Please referto Appendix D for questions frequently asked by the Board.
12. What are the site manager’s responsibilities before the meeting?
As soon as the site manager becomes aware that he/she has a site that may trigger the Board’s · review criteria, the manager should notify his/her regional board member, who, in tum, should coordinate the NRRB review meeting date.
The site manager should:

Convey to the regional board member any preferences regarding review timing. The Board tries hard to accommodate the interests ofthe regions and site managers when scheduling reviews.


Provide the site-specific charging number to the Board chair as soon as possible once it has been determined that the site will come before the Board.


Contact the state and any appropriate tribes, Potentially Responsible Parties (PRPs), community groups, or federal facilities to notify them that the site triggers the review criteria. At this time, discuss with these stakeholders the procedures governing their involvement in the review process. A Community Guide is provided in Appendix E. Questions 16-21 of this packet provide additional information on the usual role ofthese parties in the review process.


Prepare a site information package that the Board will use to conduct its review . Question 13 and Appendix A present information on the package and a recommended outline.


Finalize the informational site package at least four weeks before the meeting and provide the package to the relevant regional NRRB member for distribution to Board members in preparation for the site review. The package will be posted on the Board’s Quickr site so that Board members may download it at their convenience. Oversized charts, maps or tables should be mailed to the Board members. The mailing list is available from the Board’s Quickr site. Please note that two additional copies should be mailed to the Board chair for distribution to OSRTI participants.


Prepare a presentation that summarizes the site, proposedremedy, and major issues. See Appendix C for a suggested outline forthe presentation.


Prepare for the meeting by expecting questions that probe beyond the basic information presented in the site information package (e.g., questions about important assumptions, models, peer reviews or tools used in developing key supporting information). Appendix D presents several lists ofquestions typically asked during the review and deliberations.


OPTIONAL: Participate in a pre-meeting conference call two weeks after the Board

receives the site package (i.e., two weeks before the meeting) to give the Board an opportunity to ask clarifying questions regarding the factual infonnation in the site infonnation package and to possibly request more information prior to the board meeting, or as part of the region’s presentation at the board meeting. The pre-meeting conference call should provide feedback to the region prior to the board meeting as to whether the inforn1ation provided is sufficient to support Board discussion and development of key/substantive recommendations. The Board chair and site manager will decide if a pre.call is necessary.
Recognizing that the reviews generally are part of EPA’s internal deliberative process, please label all documents “DRAFT-DELIBERATIVE.”
13. What should be in the site information package?
Appendix A contains a suggested outline for the site infonnation package.
This informational package should be written as a “stand alone” and succinct document that summarizes the key remedy selection issues faced at the site, and explains the regional rationale for choosing its preferred cleanup strategy. Additional detailed documents may be made available for review, at the region’s discretion, through Quickr or the Superfund Document Management System. The Board expects to base its review and any resulting recommendations primarily on this document. Inclusion of clear and well labeled maps, figures and tables usually are critical to the review.
Site managers should develop a site information package that tells the story and explains the rationale of the cleanup decision at the site in question. That is, the package should identify and explain the key remedy selection issues and support the preferred cleanup strategy. The exact content may vary based on site conditions. However, all packages should include summary information such as site background, contaminants and media ofconcern, site characterization, conceptual site model, key modeling land use assumptions and uncertainties, risk analysis, basis for action, the range of alternatives considered, the preferred remedy, arid the preferred remedy cost breakout. For example, if a chosen cleanup level is driven by Applicable or Relevant and Appropriate Requirements (ARARs), the information package should explain the ARAR, why the region believes it is applicable or relevant and appropriate, how it affects the remedy, etc. This information can help reduce or eliminate the need for exploring the subject during the review meeting. The package should contain a summary of the state and/or tribe position(s) on the site, and have attached any technical submissions from states/tribes, PRPs, federal facilities, Natural Resource Trustees, community groups and/or other stakeholders as appropriate. The Board expects to base its review and any resulting recommendations on this package.
The Board recommends that the site manager have the draft package reviewed by regional staff unfamiliar with the site to be sure the package is clear and consistent. Site managers should take advantage of the resources provided by their regional Board members and OSRTI’s remedy decisions branch; they can give advice on preparing for the review, assembling the package, characterizing key issues, and developing appropriate supporting information.
14. What happens at the meeting?
For each site review, the Board meeting typically lasts one full day and is broken into two stages:
i1~(ormation gathering and deliberations. The role ofthe various stakeholders is described in subsequent sections ofthis manual. The site manager should invite state and appropriate tribal representatives to participate in the information-gathering phase. Typically, these representatives do not participate in the deliberative discussion, which the Board limits to EPA personnel.
The site manager begins the information-gathering phase with a short site briefing. Generally, the briefing should not repeat in detail material already presented in the infonnation package. Rather, it should include a brief overview ofthe site and focus on orienting the Board members to the key site features and key remedy selection issues. Following this briefing; state and/or tribal representatives may present their view of key technical issues. Generally, the total length of the presentations should not exceed one hour (typically EPA 45 minutes, state/tribe 15 minutes). The Board usually spends some time after these presentations asking technical or clarifying questions (refer to Appendix 0 for examples). The site manager should be familiar with community, state/tribe, and/or PRP technical comments, as the Board will explore these as appropriate.
Following the briefings and the question/answer session, the Board deliberates for several hours, focusing on whether the proposed cleanup decision is cost effective, technically sound, and otherwise consistent with the NCP and/or supported by the most current program guidance. The Board asks the site manager and other regional staff, as determined by the region, to attend the deliberations for follow-up questions and to ensure the site manager understands the Board’s proposed recommendations. A draft memorandum normally will be developed at the meeting, detailing any Board findings and recommendations.
Following the review meeting (typically within two to four weeks), the Board chair transmits a final draft ofthe recommendations to Board members and the site manager before issuing the final recommendations memorandum documenting any recommendations or comments to the appropriate regional division director. EPA expects to post the recommendations memo on the Board’s web page within 30 days of the chair’s signature.
The Board considers the review to be an internal, deliberative, and (in certain cases) enforcement-sensitive process. Given the nature of the process, the Board defers to regional judgment with respect to releasing documents related to the reviews, and assumes that regions will comport with established relevant Agency policy. The Board expects the region to place the Board recommendations in the site administrative record at the time a proposed plan is published for comment. Regional materials used to support Board reviews (e.g., review packages, briefing materials, and stakeholder memoranda) should also be retained in the regional site-specific administrative record as appropriate.
15. What happens after the meeting?
Regional Response: Regional division directors are asked to respond in writing within a reasonable time frame to the Board chair regarding how the region has or will address board recommendations. As part of this response, the region is asked to describe how the Board’s review has impacted the cleanup process. The site manager is encouraged to submit a draft ofthe regional response to HQ to resolve any remaining issues prior to the issuance of the proposed plan. The site manager should work closely with the Board chair and OSRTI to incorporate the recommendations in the decision documents.
The Board’s existence does not change EPA’s remedy selection process as provided for in CERCLA and the NCP. The regions retain decision making authority as delineated in formal delegations of authority. The Board does not “approve” or “disapprove” regional proposals. However, the Agency expects decision makers to give Board recommendations substantial weight when finalizing cleanup decisions. Ifissues arise regarding incorporation of recommendations into decision documents, the OSRTI office director can request a discussion with the regional division director to resolve them.
Public inquiries and release ofinfonnation: The regions are expected to handle site-specific inquiries related to the reviews. It is .expected that regions will place Board recommendations and regional response memoranda in the site administrative records on or before the date that the region issues proposed plans for public comment. See question 25 for further clarification.
Record keeping: In the case ofboard-related materials, OSRTI maintains the Agency records of pertinent Board-issued documents (e.g., the board memos, operating protocol, etc.). General information, site-specific Board memoranda, and regional responses are available at: http://www.epa.gov/superfund/programs/nrrblindex.htm. EPA regional offices are responsible for retaining all documents prepared for the presentation package either in the site file or administrative record as appropriate (e.g., the site information packages, PRP and stakeholder submissions and any other information used in the Board process related to the cleanup decision in question). This record-keeping policy is consistent with established Agency guidance.
Web page: The recommendations memo will be posted on the Board’s web page within 30 days ofthe chair’s signature. The Board’s web page will also provide a link to the Superfund Site Progress Profile that will provide links to decision documents and the administrative record. PRP and stakeholder position papers should be included in the administrative record.
16. What is the role of the PRP?
The Board and its current process do not alter existing mechanisms for PRP involvement in the remedy selection process. The current process allows the PRP to work closely with the Agency in conducting the RI!FS, including appropriate, periodic meetings between EPA and the PRPs to ensure that issues such as site characterization, treatability of contaminated media, and the feasibility ofdifferent remedial options are fully considered.
When there is a PRP-lead RI!FS, the site manager should notify the PRPs of the pending review as soon as the region identifies the site as a review candidate. At this time, the region should offer the PRPs an opportunity to summarize in writing, 20 pages or less*, any technical issues they believe are pertinent to the cleanup decision, including their recommended approach and rationale for that approach. The site manager should attach the PRP’s summary to the site infonnation package submitted to the Board four weeks before the meeting. PRP submissions should be made part ofthe administrative record.
The region, at its discretion, may solicit comments from PRPs who do not conduct the RI!FS. Generally, the region may do this in cases where PRPs have been substantively involved in RI!FS work and/or remedy selection issues, or if the region believes that PRPs may offer technical comments critical to understanding key remedy selection issues at the site.
Note that those groups that have not been working closely with the Agency early in the remedy selection process will still have the opportunity to comment formally on the proposed action during the proposed plan corriment period.
PRPs are not involved in any direct discussions with the Board nor are they involved in Board meetings or pre-meeting calls. EPA is responsible for preparation of the Board’s review package.
* PRPs may submit up to 40 pages for sites where the estimated remedial action costs exceed $I OOM.
17. Can Potentially Responsible Parties or others nominate sites for Board review?
Site managers may get calls from PRPs or other stakeholders asking whether a site can be nominated for Board review. The Board expects to review only those decisions that meet the review criteria.
18. What is the role of federal facilities?
Consistent with policy established by EPA’s FFRRO, the Board generally treats federal facilities as PRPs for the purpose of Board reviews.
Please refer to “Which sites will the Board review?” for federal facility review criteria.
19. What is the role of the community?
The Board process does not alter existing mechanisms for community involvement in the remedy selection process. The current community engagement process allows the community to work closely with the Agency in conducting the RI/FS, including appropriate, periodic meetings between EPA and the community to ensure that issues such as site characterization, treatability of contaminated media, and the feasibility of different remedial options are fully considered. The site manager may provide the NRRB Community Guide (Appendix E) to interested stakeholders.
At sites where EPA has awarded a Technical Assistance Grant (TAG) or recognized a Community Advisory Group (CAG), the site manager should notify them of the pending review as soon as the region identifies the site as a review candidate. At this time, the region should offer the TAG/CAG groups an opportunity to summarize in writing, 20 pages or less**, any technical issues they believe are pertinent to the cleanup decision, including their recommended approach and rationale for that approach. The site manager should attach this summary to the site information package submitted to the Board four weeks before the meeting. Stakeholder position papers should be included in the administrative record.
Where the site manager has established close working relationships with other stakeholder groups early in the RVFS process, the site manager may offer these groups the opportunity to submit written technical comment at his/her discretion.
** Stakeholders may submit up to 40 pages for sites where the estimated remedial action costs exceed $1OOM.
Note that those groups thathave not been working closely with the Agency early in the remedy selection process will still have the opportunity to comment formally on the proposed action during the proposed plan comment period.
Community members and TAG technical advisors are not involved in any direct discussions with the Board nor are they involved in Board meetings or pre-meeting calls.
20. Are Board discussions open to the general public?
No. The meetings ofthe Board are pre-decisional, deliberative discussions and are not open to the general public. Reviews generally occur before the region issues the proposed plan. The Agency is generally at an early stage in its decision making process when the Board meets to discuss the proposed action. The intent of this early Board review is to offer a critical discussion on key remedy selection and cost effectiveness issues before the Agency formalizes its position on a preferred cleanup strategy. It is important to note that the Board process does not affect EPA’s current procedures for soliciting public comment on proposed cleanup plans.
The recommendations memo will be posted on the Board’s web page within 30 days of the chair’s signature. The Board’s web page will also provide a link to the Superfund Site Progress Profile that will provide links to decision documents and the administrative record. PRP and stakeholder position papers should be included in the administrative record.
21. How do states and tribal governments participate in the reviews?
For each site, the site manager should invite state and appropriate tribal representatives to participate in the information-gathering phase ofthe Board meeting. Typically, these representatives do not participate in the deliberative discussion, which the Board normally limits to EPA personnel; however, they may be invited to participate for a portion ofthe deliberations where the site is a state/tribe-lead fund-financed decision or state/tribe-lead enforcement decision where the state or tribe seeks EPA concurrence. Otherwise, the Board generally limits its deliberative discussion to Agency personnel.
Regional staff should contact the state or tribal representative early in planning for the Board meeting to discuss the background and purpose ofthe Board, the structure ofthe reviews, and to explain how the state/tribe might best prepare for the meeting. The site manager may also provide the Community Guide (Appendix E) to these representatives for further information. At the meeting, the state/tribe is usually offered approximately I 0-15 minutes to speak about their specific issues or concerns.
The region should also offer the state or tribal representatives an opportunity to summarize in writing, 20 pages or less***, any technical issues they believe are pertinent to the cleanup decision, including their rationale and recommended approach for site cleanup. The site manager should attach this summary to the site infonnation package submitted to the Board four weeks before the meeting. Stakeholder position papers should be included in the administrative record.
22. What is the role of contractors?
Generally, govemment contractors can help prepare presentation and package materials but do not participate in presentations or question and answer sessions at board meetings.
23. Does the region convey the Agency’s preliminary views on the remedy in question (i.e., for stakeholders to react to)?
Generally, stakeholders have an opportunity to contribute their views on remedy selection issues, consistent with the NCP and Agency guidance. Site managers should not provide stakeholders with any preliminary indication ofAgency preferences beyond that which the Agency would provide in the absence of the Board’s review.
24. When is it appropriate for Natural Resource Trustee agencies or the Agency for Toxic Substances and Disease Registry to participate in board reviews?
When a Natural Resource Trustee agency or the Agency for Toxic Substances and Disease Registry have formally provided unique or specialized site-specific teclmical or analytical support for the RIIFS in lieu of(or to supplement) regional expertise in a particular area, the region may invite representative(s) to attend the information-gathering phase ofthe review meeting but must inform the Board chair ofthis invitation.
25. When is it appropriate to release Board memoranda and meeting support materials?
The Agency considers the site-specific Board discussion materials, site names, and operable units under consideration to be deliberative and, where appropriate, enforcement confidential. EPA staff should refer questions regarding the nature ofthe Board discussions and findings to the
*** Up to 40 pages may be submitted for sites where the estimated remedial action costs exceed $1OOM.
appropriate regional board member or site manager.
The product of a Board review is typically a memorandum from the Board chair to the appropriate regional division director. While theAgency strives to be as open as possible about Board reviews, in some cases it may be appropriate for the region to withhold the Board’s recommendations memorandum until the region issues the proposed plan. At that point, the region should place the memorandum in the appropriate site administrative record. The region may release publicly its response to Board recommendations at its discretion, taking into account the internal, deliberative nature ofthe NRRB process. EPA will post the recommendations memo to the Board’s web page within 30 days of the chair’s signature. EPA expects that regions will make the regional response available publicly as soon as it is reasonable and appropriate to do so. EPA will also post the regional response on the Board’s web page.
In addition, the NRRB web page will provide the internet link to the Superfund Site Progress Profile that links to the site decision documents and administrative records containing stakeholder and PRP position papers.
26. Where can I find information about other Board reviews?
Site managers are encouraged to visit the NRRB internet site at http://www.epa.gov/superfund/programs/nrrblindex.htm. This publicly accessible site contains basic information about the NRRB and its formation, criteria that triggers NRRB review, contact information for Board members, site-specific review memoranda, and regional responses to Board recommendations. Site-specific review memoranda may also be found in the site administrative record.
27. How are Board members selected?
HQ Offices and Regions will be requested every two years to re-evaluate their representatives on the NRRB to confinn that the members have the needed expertise, experience, and time to actively participate and contribute. The chair will request this reevaluation. The qualifications for NRRB board members are:

Senior Agency managers


Senior policy experts


Senior technical experts


Areas ofexpertise

o Remedy selection

o Cost-effectiveness

o Program implementation

o National consistency

o Applicable or relevant and appropriate requirements

o CERCLA and the NCP

o Superfund policy and guidance


Available to travel at least one week per quarter to discuss proposed remedies


Ability to commit time for a detailed analysis of review packages

o Typically three review packages per quarter


Ability to reach consensus and craft recommendations to promote both consistent and cost-effective decisions at Superfund sites

28. How are recommendations used to benefit the Superfund Program?
Every year the NRRB, in consultation with the regions and OSRTI regional coordinators, will evaluate all the reviews written over that year, looking for recurring issues. OSRTI will work to develop any needed policy, guidance or training materials.
Appendix A
RECOMMENDED OUTLINE
FOR THE SITE INFORMATION PACKAGE

Recommended Outline for the Site Information Package
Inclusion of clear and well labeled maps, tables, and figures with sufficient detail are critical to the review. Time spent by the site manager in preparing the site information package, and additional regional review ofthe draft site information package, is to the advantage of everyone involved in the reviews, as complex site decisions will likely benefit from careful preparation.
It is recommended that an internal review of the draft site infom1ation package be conducted by a colleague that is unfamiliar with the site.
All reference to ROD Guidance Highlights (e.g. ROD Guidance Highlights 6-18 to 6-20) refer to examples found in OSWER Directive 9200.1-23.P, A Guide to Preparing Supe1:{imd Proposed Plans, Records ofDecision, and Other Remedy Selection Decision Documents.
A. Summary (less than five pages)
1) Site Summary

Site name and location


Site account number


Orientation to the key features ofthe site and surrounding area


On site and surrounding land use


Brief site contamination history, and facility operational history


Identify media and primary contaminants of concern (COCs) addressed by this proposed action


List the operable units addressed by this action and the media addressed by each

2) Risk Summary
Good examples ofrisk summary tables to include in the package can be found in ROD Guidance Highlights 6-18 through 6-20.

Identify by medium and operable units, the cumulative risk (if applicable), and land use scenario( s)


Identify by medium and operable units, if applicable, the primary risk drivers

3) Cleanup levels
Include a brief summary table ofremedial action objectives (RAOs) and cleanup levels. If applicable, identify by medium and operable unit (see highlight 6-21 in the ROD Guidance identified in the Risk Summary section).
4) Description of Alternatives
Describe in a brief summary table the following for each medium and operable unit (if applicable):
• Identify remedial alternatives evaluated and associated costs

Identify expected time to achieve cleanup levels 5) Preferred Alternative In bullet fonnat, include the following for each medium and operable unit, if applicable:

• Describe remedy and estimated costs of major activities


Identify expected time to achieve cleanup levels 6) Stakeholder views


State’s position on proposed action


Other stakeholder views

B.
Detailed Information

1) Site N arne, Location, and Brief Description

Include an area map and detailed site maps with well labeled key features. Include an aerial
photograph, if available.
2) Site History and Enforcement Activities
Chronological list of significant enforcement actions, including principal PRPs.

3) Scope and Role of Operable Unit or Response Action
Discuss how the operable unit or response action addressed by the proposed plan fits into the
overall site strategy. This discussion should describe the overall site cleanup strategy, including:


The planned sequence of actions


The scope of problems those actions will address


The authorities under which each action will be/has been implemented (e.g., removal, remedial final, or remedial interim)

4) Site Characteristics

Describe the Baseline Risk Assessment Conceptual Site Model (CSM) on which the risk assessment and response action are based


Provide an overview ofthe site, including the following:
Size of site (e.g., acres)

-Geographical and topographical infonnation (e.g., surface waters, flood plains, wetlands) Surface and subsurface features (e.g., number and volume oftanks, lagoons, structures, and drums on the site)
– Areas of archaeological or historical importance

Describe known or suspected sources of contamination


Describe types of contamination and the affected media (summarize in tables), including the following: -Types and characteristics of contaminants (e.g., toxic, mobile, carcinogenic,

non-carcinogenic) -Quantity/volume ofwaste -Concentrations of contaminants in each medium (see ROD Guidance Highlight 6.
15) and figures that illustrate hot spots, e.g. isopleths
-RCRA hazardous wastes and affected media


Include figures showing contaminant level changes over time


Describe location of contamination and known or potential routes of migration, including the following: Lateral and vertical extent of contamination -Current and potential future surface and subsurface routes ofhuman or environmental exposure

– Conceptual site model of the potential migration pathways of COCs in all media Human and ecological populations that are or could be affected


For sites with groundwater and surface water contamination, describe the following:

-Aquifer(s) affected or threatened by site contamination, types ofgeologic materials, approximate depths, whether aquifer is confined or unconfined Sources and source areas of groundwater and surface water contamination, including information on non-aqueous phase liquid extent, location, and characteristics
– Groundwater flow directions within each aquifer and between aquifers and groundwater discharge locations (e.g., surface waters, wetlands, other aquifers)
– Appropriate maps and cross sections showing stratigraphy and monitoring well
layout
• Identify any computer models used that served as the basis for risk, fate and transport, or ARAR compliance decisions. For non-EPA recommended model applications, list the input parameters: measured data, literature data, and default inputs used in the predicted outputs. Also, include results of model uncertainty and sensitivity analysis for key site parameters.
5) Current and Potential Future Site and Resource Uses:
Land Use

Current on-site land uses


Current adjacent/surroundingland uses


Reasonably anticipated future land uses, with expected time frames for such l!ses, and basis for future use assumptions (e.g., zoning maps, nearby development, 20-year development plans, dialogue with local land use planning officials and citizens).

Ground and Surface Water Use

Current ground/surface water uses on the site and in its vicinity


Potential beneficial ground/surface water uses (e.g., potential drinking water, irrigation, recreational) and basis for future use assumptions (e.g., Comprehensive State Groundwater Protection Plan, promulgated State classification, EPA groundwater classification guidelines)


Ifbeneficial use is an anticipated drinking water source, identify the approximate time frame ofprojected future drinking water use (e.g., groundwater aquifer not currently used as a drinking water source but expected to be utilized in future years)


Location of anticipated use in relation to location and anticipated migration of
contamination.

6) Summary ofRisk1:
Human Health Risk Assessment
• Identify potentially exposed populations in current and future scenarios (e.g., worker
currently working on site, adults and children living on site in the future)

1 The site information package should include a synopsis of the risk assessment(s). Detailed information may be provided by posting documents to the Board’s Quickr site or by providing the Superfund Document Management System document identification number.

Identify sensitive sub-populations (highly exposed and/or more susceptible) that may be exposed (e.g., farm families, children, subsistence fishermen)


Identify the routes by which each population group or sub-population group could reasonably be exposed to site contaminants (e.g., ingestion ofcontaminated groundwater for adults and children, inhalation of volatile contaminants for workers)


Include major assumptions about exposure frequency, duration, and other exposure factors that were included in the exposure assessment (e.g., exposure frequency [days/year], exposure duration [years], and body surface area for dermal exposure) could be included in an appendix


Highlight any non-standard exposure assumptions used in the baseline risk assessments


Provide a summary (preferably a table) that includes the following for all current and future land use scenarios presenting unacceptable risks: -Quantified carcinogenic risks for each COC in each exposure medium for each relevant exposure pathway -Combined carcinogenic risks reflecting total exposure to COCs in a given medium and pathway of exposure -Potential for non-carcinogenic impacts as quantified by the hazard quotient for each COC in each exposure medium for ~ach exposure pathway, as appropriate

-Potential for combined non-carcinogenic effects in each medium and pathway of exposure as expressed by hazard indices, which reflect the potential additive effects of COCs that affect the same target organ or system
– Identify key uncertainties in the baseline risk assessment
• If applicable, describe how radiological risks were calculated .
Ecological Risk Assessment (particularly where these risks drive remedy selection)

What are the assessment endpoints determined to be at risk (the foundation of the
remedial decisions, that is, the risk drivers)?


Which of these risks would require remedial action?


Which site contaminants were determined to be causal and by which exposure routes (i.e., what is the conceptual model/exposure model?).


Describe the thresholds ofexposure generating risk, and at what level ofexposure do the risk levels become severe?


What is the confidence in the risk estimates? Are there documented effects?


_Describe any site-specific data that were available


How large is the area for which ecological risks have been estimated?


Description ofkey species that could be exposed


Describe complete exposure pathways, present the conceptual site model


Monitoring or modeling data and assumptions


The ROD Guidance (Pages 6-22 to 6-25) provides summary tables that would supply the above requested information.

7) Remedial Action Objectives and Preliminary Remediation Goals

Present the basis and rationale for remedial action objectives (RAOs) & preliminary remediation goals (PRGs) (e.g., current and reasonably anticipated future land use and potential beneficial groundwater use)


Describe how the RAOs & PRGs address risks identified in the risk assessment (e.g., how will the risks driving the need for action be addressed by the response action?)


Identify any key ARARs that are driving the remedy selection


Where ecological risks drive the remedy, provide the range of protective cleanup levels and their basis.


Explain how cleanup levels are developed from these goals considering the remedy
selection criteria.


Explain the role ofbackground in the evaluation of cleanup levels.

8) Description of Alternatives:
• Provide a bulleted list and appropriate figures of the major components of each alternative. The package should include the following: -Treatment technologies and materials they will address (e.g., source materials constituting principal threats)
-Containment components ofremedy (e.g., engineering controls, cap, hydraulic barriers) and materials they will address (e.g., low concentration source materials, treatment residuals)
– Description of institutional controls and how they will be implemented and maintained and the duration -For alternatives that depend upon monitored natural attenuation, demonstrate compliance with EPA policy

Provide the total estimated capital, annual operation and maintenance (O&M), and total present worth costs, discount rate, and the number ofyears over which the remedy cost estimates are projected


Summarize the capital and annual O&M costs associated with each of the major
components of each alternative

9) Comparative Analysis of Alternatives
Provide a summary table and discussion comparing alternatives that pass the threshold criteria against the nine criteria.
1 0) Principal Threat Waste Clearly identify how source materials constituting principal threats are addressed or provide an explanation ofwhy the site does not have principal threat waste (refer to A Guide to Principal Threat and LoH’ Level Threat Wastes-OSWER 9380.3-06FS, November 1991).
11) Preferred Alternative

Clearly describe the preferred alternative and how, if appropriate, it is different from the alternatives evaluated


Describe the key factor(s) that led to selecting the preferred alternative (i.e., describe how the remedy provides the best balance oftradeoffs with respect to the balancing and modifying criteria, highlighting criteria key to the decision)

12) Applicable or Relevant and Appropriate Requirements2

List the principal ARARs for the preferred alternative


Describe the ARARs that are drivers for the remedy


For each driver, explain why it is an ARAR (versus a “to be considered”)


Where actual language of the regulation is key to the Board review, include a copy of the relevant section in an appendix to the package

13) Technical & Policy Issues
Include a discussion of technical or policy issues that require further discussion prior to implementation of the preferred alternative (data gathering, ARARs, treatability studies, modeling.
14) Cost Information4

Include sufficient information to provide an estimate of total resource costs over time

(i.e., life cycle costs) for all alternatives including (ROD Guidance Highlight 6-29) -Capital costs -Annual operations and maintenance costs -Net present value of capital and O&M costs


Cost estimate summaries should address the following: -The key cost components/elements for both Remedial Action and O&M activities -The major sources of uncertainty in the cost estimate

2 The site information package should include a synopsis of this infonnation. Detailed information may be provided by posting documents to the Board’s Quickr site or by providing the Superfund Document Management System document identification number.
– The discount rate used
-The time expected to achieve RAOs and remedial goals Periodic capital and/or O&M costs anticipated in future years ofthe project (e.g., remedy replacement or rebuild)
-The methods and resources used for preparing the cost estimate (e.g., estimating guides, vendor quotes, computer cost models)

For contingency remedy decisions, the total project costs for implementing the contingency should be provided in addition to the costs for the conditional action. This estimate should include treatability study costs, if applicable.


The assumptions used to develop the cost estimate should be consistent with the stated RAOs and remedial goals (e.g., duration of the cost estimate should match time to achieve cleanup objectives).

15) Letters from Stakeholders and State
Include in the package any technical comments provided by the state or other stakeholders.
Appendix B
SAMPLE AGENDA FOR THE BOARD MEETING

Sample NRRB Meeting Agenda
8:30-8:45 Introductions
8:45-9:45 Site Presentations (1 0-15 minutes additional time for state/tribal presentations)
9:45-10:00 BREAK 10:00-11:30 Questions & Answers 11:30-12:30 LUNCH
The following sessions are for EPA staff only 12:30-2:15 Deliberations
2:15-2:30 BREAK
2:30-3:00 Board Business (not site-specific)
3:00-5:00 Write and Review Board Recommendations
5:00 ADJOURN
Appendix C
RECOMMENDED OUTLINE
FOR THE BOARD PRESENTATION

Recommended Outline for the Board Presentation
The main emphasis of the presentation, which typically runs one hour in length, should be on the preferred alternative. Hard copies ofthe presentation should be provided for all Board members at the meeting (preferably two slides per page).
Although not reconunended for the presentation, site managers should have key figures available (electronically ifpossible) from the RJJFS and site infonnation package in case of questions during the discussions.
The following suggested times should be used as a guide but are not mandatory:

Site Summary & Risk Summary-I 0


RAO & Description ofAlternatives-I5


Preferred Alternative-25


Stakeholder Views or Presentation-I 0

I) Site Summary

Orientation to the key features of the site and surrounding area (including maps)


On site and surrounding land use


Brief site contamination history, and facility operational history


Identify media and primary COCs addressed by this proposed action


List the other operable units at the site and the media addressed by each

2) Risk Summary

Identify by medium and operable units, the cumulative risk (if applicable), and land use scenario(s)


Identify by medium and operable units, if applicable, the primary risk drivers

3) Remedial Action Objectives and PRGs

Present the basis and rationale for RAOs and PRGs (e.g., current and reasonably
anticipated future land use and potential beneficial groundwater use)


Describe how the RAOs and PRGs address risks identified in the risk assessment (e.g., how will the risks driving the need for action be addressed by the response action?)


Identify any key ARARs that are driving the remedy selection

4) Description of Alternatives Describe in bullet fonnat the following for each medium and operable unit (if applicable):

Briefly identify key components of all remedial alternatives evaluated and associated costs


Identify risk reduction and expected time to achieve cleanup levels

5) Preferred Alternative

Provide a brief summary table or figure that compares all the alternatives, clearly
illustrating the commonality and differences between each alternative


For the preferred alternative, identify for each medium and operable unit: -The rationale and key factors that led to the selection of the preferred alternative -The remedy and estimated costs ofmajor activities

Expected time to achieve cleanup levels
Major technical and other unresolved issues

6) Stakeholder views .

State’s position on the proposed action


Other stakeholder views

Appendix D

QUESTIONS FREQUENTLY ASKED
BY BOARD MEMBERS

Appendix D -Questions Frequently Asked by the NRRB Members
1) NRRB discussion guide
General Groundwater Soil Sediment
Land/Water Use What are future use assumptions for the site? Are the bases for these assumptions clear? Are these assumptions consistent with state/local designations? Have efforts been made to discuss the future use with site owners, local government representatives, and other stakeholders? . What are future use assumptions for groundwater? What are future use assumptions for land? What are future use assumptions for surface water and flood plains?
Was reuse/beneficial use considered for land, water, or treatment residuals, as appropriate?
Exposure Scenarios/Risk Assumptions Are exposure scenarios and risk assumptions reasonable and consistent with future uses? Have the latest toxicity data been used (e.g., PCBs/dioxin)? What are the risk drivers for the site-media, pathways, contaminants? Is remedial action necessary? Has the groundwater/surface water pathway been adequately considered? Has ecological risk been adequately addressed? Has ecological risk been adequately addressed? Where contaminants are bioaccumulative, were appropriate fish/shellfish consumption rates used for risk analysis and are they reasonable?
Remedial Action Objectives & Cleanup Levels What are the RAOs and cleanup levels and do they adequately address risk drivers? Is it clear how cleanup levels were selected? Are RAOs and cleanup levels reasonable and clearly linked to each other? Is it clear whether the goal is restoration and/or containment? What is the expected time frame to meet cleanup levels for groundwater? How were cleanup levels for biota selected? What is the expected time frame to meet cleanup levels for sediment and RAOs for biota? What level of fish/shellfish consumption is the remedy expected to

achieve, and when?
Appendix D-Questions Frequently Asked by the NRRB Members
General Groundwater Soil Sediment
Were a variety of cleanup levels considered? Are the major ARARs identified and are there any special issues? Have the principal threat wastes been identified and does the proposed remedy anticipate treatment or explain why it is not appropriate? Where RAOs for biota will not be met for a long time, have interim goals or benchmarks been identified as appropriate?
Remedy Effectiveness Is the preferred alternative likely to be effective in meeting cleanup levels and RAOs? Are any existing source control actions effective and have any ongoing sources been appropriately incorporated into decision-making? If treatment is proposed, is a pilot necessary and if so, is it proposed? If institutional controls are necessary, are they likely to be effective? Should a contingency remedy be specified and if so, has it been? Does the proposed remedy include monitoring adequate to evaluate remedy effectiveness? Is DNAPL likely to be present? Ifyes: Do cleanup goals adequatel

Post

2012-06-29 – PRP Sampling and Analysis Plan for Additional Groundwater Monitoring Activities

Page 1 of 1
. ”\ Final Groundwater Monitoring SAP and Responses to Comments
_
;~-} ~:ul Rosasco
Dan Gravatt, ‘Muenks, Shawn’
06/29/20 12 03: 13 PM
Cc:
“‘Merrigan, Jessie”‘, “‘Neitzel, Charlotte”‘, “‘Warren, Victoria”‘, “‘Whitby, Kathleen”‘, “‘Golian,
Steven”‘, “‘Ward Herst”‘, “Bob Jelinek”, “‘L FITZGERALD”‘
Hide Details
From: “Paul Rosasco” Sort List…

To: Dan Gravatt/R7/USEPA/[email protected], “‘Muenks, Shawn”‘

Cc: “‘Merrigan, Jessie”‘ , “‘Neitzel, Charlotte”‘

, “‘Warren, Victoria”‘ ,

‘”Whitby, Kathleen”‘ , “‘Golian, Steven”‘

, “‘Ward Herst”‘ , “Bob Jelinek”

, “‘L FITZGERALD”‘

2 Attachments
SAP-Additional Groundwater Monitoring REVISED. pdf Responses to comments on Groundwater SAP.pdf
Dan and Shawn,
Enclosed please find a revised Sampling and Analysis Plan (SAP) for the Additional Groundwater Monitoring

activities. The document has been amended to address EPA and MDNR comments received on June 18, 2012. I am
also sending each of you a hard copy of the plan via regular mail.
Also enclosed are responses to the EPA and MDNR comments.
Once we receive your approval of the SAP, we will schedule the additional groundwater monitoring activity.

Please contact me if you have any questions or would like to discuss the additional ground_water’!’onito~ing or any
other aspect of the project.
o7/t.; 11111riifiln1~
Superfund
0/401
file:/ //C:/Users/DGRA VATTIAppData/LocaVTemp/notes6D6848/-web0307 .htm 4/29/2014
ENGINEERING MANAGEMENT SUPPORT INC.

72_20 West Jefferson Ave. Suite 406 Telephone (303) 940-3426 Lakewood, CO 80235 Telecopier (303) 940-3422
June 29, 2012
U.S. Environmental Protection Agency Region 7 SUPR I MOKS 901 N. 51h Street Kansas City, Kansas 66101
ATTENTION: Mr. Dan Gravatt
SUBJECT: Sampling and Analysis Plan -Additional Groundwater Monitoring West Lake Landfill Operable Unit 1, Bridgeton, Missouri Revised June 22, 2012
Dear Dan,
During a May 10, 2012 conference call, the U.S. Environmental Protection Agency (EPA) asked the West Lake Landfill Operable Unit-1 (OU-1) Respondents to perform an additional round ofgroundwater sampling at the West Lake Landfill. Engineering Management Support Inc. (EMSI), on behalf of Cotter Corporation (N.S.L.), Bridgeton Landfill, LLC, Rock Road Industries, Inc., and the United States Department of Energy (the OU-1 Respondents), is providing this letter to serve as the Sampling and Analysis Plan (SAP) for that additional groundwater sampling.
EPA has indicated that additional groundwater monitoring is necessary to verify that current groundwater quality is consistent with that characterized during sampling performed in 1995, 1996, and 1997 as part of the Remedial Investigation and in 2004 as part of the Feasibility Study activities for OU-1. This letter describes the relevant project planning documents, proposed monitoring locations, sample collection procedures, analyte list, laboratory analyses, quality assurance/quality control samples and procedures, investigative-derived waste management, health and safety procedures, data evaluation and management procedures, and tentative schedule for the work.
Relevant Project Documents
Prior project planning documents relevant to the proposed groundwater monitoring activities include the following:
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 2

McLaren Hart, 1994, Sampling and Analysis Plan (including Field Sampling Plan and Quality Assurance Project Plan) included as Appendix A to the EPA.approved RIIFS Work Plan, August, 1994.


EMSI, 1997, Amended Sampling and Analysis Plan, February 1997.


Herst & Associates, 2003, Letter from Ward Herst (Herst & Associates) to Dan Wall EPA re: Proposed Supplemental Groundwater Sampling, West Lake Landfill Operable Unit 2, November 5, 2003,


EMSI, 2004, Letter from Paul V. Rosasco (EMSI) to Dan Wall EPA re:
Additional Groundwater Monitoring, February 2, 2004.

Copies of the relevant Standard Operating Procedures (SOPs) used by Herst & Associates for groundwater monitoring activities are included with this submittal. A Health and Safety Plan addressing the specific tasks associated with the proposed groundwater monitoring activities is being prepared by Herst & Associates for use by the field crews.
Monitoring Locations
EPA requested that all of the available OU-1 and OU-2 monitoring wells be sampled as part of this effort.
EMSI retained Herst & Associates, Inc. (Herst) to ·conduct a site inspection and well inventory to ascertain the current number of wells at the site, conditions affecting access to the wells, the condition of the surface portions (protective casing, locks, etc.) of the wells, and the depth to water, total depth and down hole conditions as best as could be determined during collection of depth to water and total depth measurements. The inspection did not include checking whether a pump or other sampling device could be lowered into the wells. Many of the wells are routinely checked by Herst for water levels as part ofongoing groundwater monitoring associated with post-closure care of the permitted solid waste landfill and thus did not need to be re-inspected as part of this effort.
Review of site documents indicated that approximately 115 wells have previously been present at the West Lake site. Figure 1 displays the locations of the various monitoring wells that historically were present at the West Lake Landfill. Table 1 summarizes the current status of the various monitoring wells at the West Lake Landfill. Sixty-eight wells could be located, accessed and appear to be in a condition that is suitable for sampling. Based on the results ofthe well inspection and review of information obtained during prior sampling activities, it was determined that 35 wells have been abandoned, destroyed, are damaged in a manner that would prevent collection of groundwater samples, or were previously reported as missing. Many (14) of these unavailable wells
Additional Groundwater Sampling West Lake Landfill OU-1
6/29/2012
Page 3
were located on property no longer owned by the landfill and subsequently developed by others. The remaining 21 wells were previously reported to have been abandoned, destroyed or lost. The areas around five of the wells that were previously reported to have been abandoned or destroyed were inspected as part of the development of this SAP; however, these inspections failed to locate these wells or any indication that these wells may still exist. Five of the wells were reported (McLaren Hart, 1994) to have been abandoned in October 1992, prior to performance of the Remedial Investigation/ Feasibility Study for OU-1 and OU-2. The areas around three of these wells were inspected and these inspections confirmed that these wells no longer exist. Eight additional wells were previously reported to have been abandoned or destroyed. The areas around these well locations were not inspected. In conjunction with performance of the groundwater sampling, the areas around these wells, and any other wells that were previously reported to have been abandoned/destroyed that were not previously inspected {Table 2), will be inspected to verify that these wells no longer exist. Three wells that were located (S-75, D-87 and MW-103) were determined to have casings that are damaged or obstructed. These three wells will be re-inspected and to the extent practical will be repaired as part of the groundwater sampling effort. The status of the remaining
12 wells could not be determined because the wells could not be located or their locations could not be accessed due to heavy vegetative growth or fencing that restricted access to offsite properties.
Based on the results of the well inspection, it is anticipated that approximately 80 or more wells (68 wells that were inspected and found to be in a condition potentially suitable for sampling plus the additional 12 wells ofunknown status plus the three wells found to have damaged casings) listed in Table 3 are proposed for additional groundwater sampling. The locations of these wells are shown on Figure 2.
Prior to conducting the groundwater sampling effort, vegetation must be cleared to allow for access to these wells. Vegetation clearing will be conducted using a skid steer with a ‘brush hog” attachment and/or manually using toppers or a chain saw as necessary.
Although this SAP anticipates that up to 83 groundwater monitoring wells may be sampled, it is possible that additional wells may be located. Alternatively, it is likely that some of the wells may not be located or may not be susceptible to sampling because of constrictions in or damage to the monitoring well casing resulting in a lesser number of wells for sampling. If such constrictions or damage are present in the above grade, or shallow, subsurface portions of the casing, an attempt will be made by the field crew to repair such damage so as to allow for collection of groundwater samples. In addition to the 83 wells listed on Table 2 and shown on Figure 2, any additional wells that can be located during the groundwater monitoring activities and that are found to be, or that can be made to be suitable for groundwater sampling will also be sampled. In any case, the field crew will endeavor to locate and sample as many of the site monitoring wells as possible.
Additional Groundwater Sampling West Lake Landfill OU-1
6/29/2012
Page4
Sample Collection
Samples will be collected from as many ofthe 83 wells listed in Table 3 that can be accessed and from which samples can be collected. Prior to sample collection, the depth to water and total depth of each well to be sampled will be measured to calculate the volume of standing water iil the well casings (casing volume).
A dedicated Waterra (or equivalent) inertial pump (http://www.waterra.com/index.html) consisting of a Waterra D-25, 2-inch diameter, acetal theimoplastic, standard flow (flow rate up to 1 gallon per minute) foot valve connected to high-density, polyethylene tubing will be installed in each monitoring well that does not already possess a bladder or other type of sampling pump. A Waterra compatible surge block (e.g., Waterra SBD-25), or equivalent, may be added to the foot valve to assist with re-development ofwells that have not been sampled in many years.
The Waterra pump will be used to purge the standing water from the well prior to sample collection. An automatic actuator may be used to produce the oscillating motion required by the Waterra pump. The volume of water removed from each well will be recorded. Purge water will be containerized at each well during well development activities and subsequently transported to and placed into a polyethylene tank(s).
Field parameters including, at a minimum, temperature, pH, and specific conductance, will be monitored using an in-line flow-through chamber during well purging at a minimum of intervals equivalent to one-half of a well casing volume. Well purging will continue until three successive sets of field parameter readings, obtained at intervals equivalent to successive one-half of a well casing volume, indicate stable water quality: specifically three successive temperature readings within 1 degree C, three successive pH readings within 0.2 pH unit, and three successive specific conductance readings within 10% of each other. A sample for laboratory analysis will then be collected regardless of the number of casing volumes removed. In the event that well stabilization cannot be achieved through continued well purging (e.g., field parameters have not stabilized after removal of five casing volumes), a field decision will be made regarding the need for continued well purging versus collection of a sample.
In the case ofmonitoring wells, if any, that are dewatered during well purging, the water level in the subject well will be allowed to recover for 24 hours at which time a sample will be collected. In the event that the water level in a well does not recover sufficiently within 24 hours, the well will continue to be checked periodically during the groundwater sampling activities for the presence of water. If the water level recovers sufficiently to allow for sample collection prior to completion of the groundwater monitoring activities, a sample will be collected from that well. In order to insure that the most important sample fractions are obtained, the order of sample fraction collection will be prioritized as follows: total radio-isotopes sample containers first, dissolved radio-isotopes sample containers second, volatile organic compound (VOC) sample containers third, total trace
Additional Groundwater Sampling West Lake Landfill OU-1
6/29/2012
Page 5
metal sample containers fourth, and dissolved metal sample containers fifth. In the event that a low producing well is selected by EPA and/or MDNR for collection of split samples, the same priority for sample fraction collection will be used with the additional criteria that the radio-isotope sample bottles for the investigative samples to be obtained by Herst & Associates on behalf of EMSI will be filled first followed by the radio-isotope bottles for the split samples to be obtained by EPA or MDNR. Collection of samples for additional analytical fractions (e.g., VOCs) will subsequently be conducted using the same prioritization.
Upon completion of sample collection, the well tubing will be pushed down inside the well and trimmed as necessary to allow for placement of the well cap and securing of the protective casing. If necessary to facilitate subsequent access to the pump tubing, a short length of rope may be secured to the top of the pump tubing with the other end of the rope secured around the inner casing, to the well cap or to the outer casing as determined by the field crew.
Groundwater samples collected for laboratory analysis will placed in the appropriate pre.preserved bottles provided by the analytical laboratories. Samples to be analyzed for dissolved trace metals and radionuclides will be subjected to field filtering prior to placement in the pre-preserved sample bottles.
Chain-of-custody forms will be completed in the field by the sampling crew to document the names of the samplers, the actual samples collected by the sampling crew, the date and time of sample collection, the number and types of sample containers obtained from each well sampled, the type ofpreservation performed on each sample container, and the requested laboratory analyses. Chain-of-custody forms will be completed for each analytical laboratory used for the groundwater monitoring effort.
Laboratory Analyses
The collected samples will be analyzed for uranium (U-238, U-235 and U-234), radium (Ra-226 and Ra-228) and thorium (Th-232, Th-230 and Th-228) isotopes, EPA Target Compund List (TCL) trace metals, TCL volatile organic compounds (VOCs), and TCL semivolatile organic compounds (SVOCs) (please see http://www.epa.gov/superfund/programs/clp/target.htm for a list ofTCL parameters). Radionuclide and trace metal samples will be analyzed for both dissolved (field filtered samples) and total (unfiltered samples) concentrations.
Radio nuclide analyses will be performed by Eberline Laboratory of Oak Ridge, Tennessee. All other analyses will be performed by Test America, either at its Earth City, Missouri laboratory or one of the other Test America laboratories depending upon laboratory capabilities and schedules at the time of sample delivery. Samples to be analyzed by Eberline will be shipped via overnight courier to the Eberline Laboratory in Oak Ridge, Tennessee. Samples to be analyzed by Test America will be delivered
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 6
directly to Test America’s Earth City laboratory for analysis there or shipment via overnight courier to another Test America laboratory, if necessary.
The samples will be analyzed using the following laboratory methods:
Analytes
Thorium isotopes
Uranium isotopes
Radium-226
Radium-228
Trace metals
Volatile organic compounds
Semi-volatile organic compounds
Quality Assurance/Quality Control Analytical Method EML Th-01 EML U-02 EPA 903.0 (Modified to Alpha
Spectroscopy) EPA 904.0 SW-846 6020 SW-846 8260B SW-846 8270C
The following quality assurance/quality control samples will be obtained in the field:

Field duplicate samples -one duplicate sample per every ten investigative samples (duplicate samples will include duplicate sample bottles for all sample analytical fractions);


VQC trip blanks-one sample per every sample container (e.g., cooler) delivered to the laboratory that contains samples for VOC analyses; and


VOC, SVOC and trace metal matrix spike and matrix spike duplicate samples.one of each for every twenty investigative samples.

Additional quality assurance/quality control samples such as method blank samples, laboratory duplicate samples, laboratory control samples, surrogate spike samples, matrix spike and matrix spike duplicate samples will be prepared and analyzed by the analytical laboratories in accordance with the requirements of the analytical methods listed above and the laboratory’s standard operating procedures.
Investigative Derived Materials
Purge water from each monitoring well will be containerized and subsequently transported to and placed into a polyethylene tank(s). Upon completion of the
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 7
groundwater sampling activities, a sample(s) will be obtained from the tank(s) and analyzed for the same analyses as used for the investigative samples plus any additional parameters required by the anticipated disposal facility(ies). It is anticipated that subject to the results of the analyses, the purge water will be collected and disposed by Heritage Environmental Services and/or discharge to the sewer system if approved by the Metropolitan Sewer District (MSD).
Solid waste generated during the sampling activities, including but not limited to well tubing remnants, paper towels, and used gloves will be disposed of at the solid waste transfer facility on site.
Health and Safety
Brush clearing and groundwater sampling activities will be performed by Herst & Associates personnel that have been trained in health and safety procedures for Hazardous Waste Operations and Emergency Response (HAZWOPER). Herst & Associates will prepare a Health and Safety Plan (HSP) that addresses the specific activities to be conducted in conjunction with the groundwater monitoring effort. A copy of the HSP will be provided for information purposes only to all personnel that are present on site in conjunction with the groundwater sampling activities; however, each organization will be responsible for developing and implementing the health and safety procedures necessary for its own personnel. Herst & Associates and EMSI will not be responsible for the health and safety of any personnel other than their own employees.
Data Evaluation and Management
The analytical data will be subject to data validation in accordance with the requirements of the most recent EPA data validation procedure for each analyte group. All of the data will be subject to a Level III data validation plus checks on the laboratory instrument calibration, continuing calibration verification, and internal standards. Based on the results of the data validation effort, additional data qualifiers beyond those applied by the laboratories may be required for the analytical data. A data validation report will be prepared documenting the results of the data validation effort.
The results of the additional groundwater monitoring will be tabulated separately and in conjunction with the results obtained during the RI sampling conducted in 1995, 1996 and 1997 and the FS sampling conducted in 2004. A brief report describing the sampling activities will be prepared and will include the analytical data summary tables described above, the well sampling and purging forms, chain of custody reports, the analytical laboratory reports, and the data validation reports.
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 8
Anticipated Schedule of Activities
One round of groundwater sampling will be performed. Brush clearing activities to provide physical access to the monitoring wells will be scheduled upon receipt of EPA approval of this SAP. Allowing for scheduling and mobilization of vegetation clearing crew, it is anticipated that it will take one to two weeks to complete the brush clearing activities. Groundwater sampling will be initiated within one week of completion of the brush clearing activities. Based on an assumed sample collection rate of five samples per day, it is anticipated that it will take three to four weeks to collect groundwater samples from the approximately 80 wells to be sampled as part of this effort. It is anticipated that it will take approximately three to four weeks for laboratory analyses of the samples. Data validation will take approximately four weeks and data evaluation and report preparation will take another two weeks. Consequently, the total estimated duration of the activities from EPA approval of this SAP until submittal of a sampling report is estimated to be approximately fourteen to seventeen weeks.
If you have any questions or desire additional information related to this SAP or any other aspect of the project, please do not hesitate to contact me.
Sincerely,
ENGINEERING MANAGEMENT SUPPORT, Inc.

ifg::
Paul V. Rosasco, ..
Attachments:

Table 1 -List of Existing and Abandoned Monitoring Wells Table 2 -Reported Abandoned/Destroyed Monitoring Wells to be Inspected Table 3 -List of Monitoring Wells Potentially Available for Sampling
Figure 1 -Current and Prior Groundwater Monitoring Wells Figure 2-Groundwater Monitoring Wells Potentially Suitable for Additional Groundwater Sampling
Herst & Associates Standard Operating Procedures
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 9
Distribution:

Shawn Muenks-Missouri Department of Natural Resources Jessica Merrigan-Lathrop & Gage Kate Whitby-Spencer Fane Britt & Browne Victoria Warren-Republic Services, Inc. Charlotte Neitzel-Bryan Cave HRO Steve Golian -U. S. Department of Energy Ward Herst-Herst & Associates, Inc.
TABLES

Table 1: List of Existing and Abandoned Monitoring Wells by Well Number, West Lake Landfill OU-1 and OU-2
Well Number General Location
S-1 Radiological Area 2
S-5 Radiological Area 1
S-8 Radiological Area 2
S-10 Radiological Area 2
S-51 Closed Leachate Pond
S-52 Closed Leachate Pond
S-53 Closed Leachate Pond
S-54 Inactive Landfill
S-61 Radiological Area 2
S-75 Inactive Landfill
S-76 Inactive Landfill
S-80 Upgradient
S-82 Radiological Area 2
S-84 Radiological Area 1
S-88 Inactive Landfill
1-2 Radiological Area 2
1-4 Radiological Area 1
1-7 Radiological Area 2
1-9 Radiological Area 2
1-11 Radiological Area 2
1-50 Upgradient
1-56 Inactive Landfill
1-58 Inactive Landfill
1-59 Radiological Area 2
1-62 Radiological Area 2
1-65 Radiological Area 2
1-66 Radiological Area 2
1-67 Closed Demolition Landfill
1-68 Radiological Area 1
1-72 Concrete/ Asphalt Plants
1-73 Concrete/ Asphalt Plants
D-3 Radiological Area 1
D-6 Radiological Area 2
D-12 Radiological Area 2
D-13 Radiological Area 2
D-14 Radiological Area 1
D-81 Inactive Landfill
D-83 Radiological Area 2
D-85 Radiological Area 1
D-87 Closed Demolition Landfill
D-89 Inactive Landfill
D-90 Upgradient
D-91 Upgradient
D-92 Closed Demolition Landfill
D-93 Radiological Area 2

Inspected?
No-area overgrown
Yes
No-area overgrown
Yes
No
No
Np
No
Yes
Yes
No
No
Yes
Yes
Yes
No-area overgrown
Yes
No-area overgrown
Yes
Yes
No
Yes
Yes
Yes
No-area overgrown
No-area overgrown
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No-area overgrown
No-area overgrown
Yes
Yes
No
No
No
Yes
Yes
Condition
Unknown
Okay
Unknown
Okay
Destroyed/Abandoned
Destroyed/Abandoned
Destroyed/ Abandoned
Abandoned 10/92
Okay
Casing damaged/obstructed
Abandoned 10/92
Destroyed/ Abandoned
Okay
Okay
Destroyed/Abandoned
Unknown-unable to locate previously
Okay
Unknown
Okay -may be incorrectly labelled
Okay
Destroyed/ Abandoned
Abandoned 10/92
Abandoned 10/92
Abandoned 10/92
Unknown
Unknown
Okay
Okay
Okay
Destroyed/ Abandoned
Okay
Okay
Okay
Okay
Okay
Destroyed/ Abandoned
Unknown
Unknown
Okay
Casing obstructed
Destroyed/Abandoned
Reported as missing in 1994
Reported as missing in 1994
Destroyed/ Abandoned
Okay-may be incorrectly labelled
Page 1 of 3

Table 1: List of Existing and Abandoned Monitoring Wells by Well Number, West Lake Landfill OU-1 and OU-2
Well Number General Location
D-94 Radiological Area 2
LR-100 Inactive Landfill
LR-101 Inactive Landfill
LR-102 Inactive Landfill
LR-103 Inactive Landfill
LR-104 Concrete/ Asphalt Plants
LR-105 Inactive Landfill
MW-101 Radiological Area 2
MW-102 Radiological Area 2
MW-103 Inactive Landfill
MW-104 Inactive Landfill
MW-105 Earth City
MW-106 Upgradient
MW-107 Upgradient
MW-1204 South Quarry
MW-1205 unknown
MW-1206 unknown
MW-FlD North Quarry
MW-FlS North Quarry
MW-F2 Inactive Landfill
MW-F3 Radiological Area 2
PZ-100-SD* North Quarry
PZ-100-SS* North Quarry
PZ-100-KS North Quarry
PZ-101-SS North Quarry
PZ-102-SS North Quarry
PZ-102R-SS North Quarry
PZ-103-SS South Quarry
PZ-104-SD* South Quarry
PZ-104-SS* South Quarry
PZ-104-KS South Quarry
PZ-105-SS* South Quarry
PZ-106-SD* South Quarry
PZ-106-SS* South Quarry
PZ-106-KS South Quarry
PZ-107-SS Inactive Landfill
PZ-108-SS* South Quarry
PZ-109-SS* South Quarry
PZ-110-SS* North Quarry
PZ-111-SD* North Quarry
PZ-111-KS North Quarry
PZ-112-AS Radiological Area 1
PZ-113-AD Closed Demolition Landfill
PZ-113-AS Closed Demolition Landfill
PZ-113-SS Closed Demolition Landfill

Inspected?
No-area overgrown
Yes
Yes
Yes
Yes
Yes
Yes
No-area overgrown
Yes
Yes
Yes
No
No
No
Yes
No
No
No
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Condition Unknown -previous report-damaged Destroyed/ Abandoned Destroyed/ Abandoned Unknown-beneath soil stockpile Okay Okay Okay Unknown Okay Casing damaged/obstructed Okay Destroyed/ Abandoned
De~royed/Abandoned
Destroyed/ Abandoned Okay Abandoned/decomissioned Abandoned/decomissioned Destroyed/ Abandoned Destroyed/ Abandoned
De~royed/Abandoned
Destroyed/ Abandoned Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay
Page 2 of 3

Table 1: List of Existing and Abandoned Monitoring Wells by Well Number, West Lake Landfill OU-1 and OU-2
Well Number General Location Inspected? Condition
PZ-114-AS* North Quarry Yes Okay
PZ-115-SS* North Quarry Yes Okay
PZ-116-SS South Quarry Yes Okay
PZ-200-SS North Quarry Yes Okay
PZ-201A-SS* South Quarry Yes Okay
PZ-202-SS South Quarry Yes Okay
PZ-203-SS South Quarry Yes Okay
PZ-204-SS South Quarry Yes Okay
PZ-204A-SS South Quarry Yes Okay
PZ-205-AS South Quarry Yes Okay
PZ-205-SS* South Quarry Yes Okay
PZ-206-SS Concrete/Asphalt Plants Yes Okay
PZ-207-AS Closed Demolition Landfill Yes Okay
PZ-208-SS North Quarry Yes Okay
PZ-300-AS Upgradient No Destroyed/Abandoned
PZ-300-AD Upgradient No Destroyed/Abandoned
PZ-300-SS Upgradient No Destroyed/Abandoned
PZ-301-SS Upgradient No Destroyed/Abandoned
PZ-302-AI Inactive Landfill Yes Okay
PZ-302-AS Inactive Landfill Yes Okay
PZ-303-AS Inactive Landfill Yes Okay
PZ-304-AI Inactive Landfill Yes Okay
PZ-304-AS Inactive Landfill Yes Okay
PZ-305-AI Concrete/Asphalt Plants Yes Okay
PZ-1201-SS South Quarry Yes Unknown-location buried beneath soil
* Included in monitoring program for the permitted solid waste landfill.

Page 3 of 3

Table 2: Reported Abandoned/Destroyed Monitoring Wells to be Inspected, West Lake Landfill OU-1 and OU-2
Well Number General Location
S-1 Radiological Area 2
S-51 Closed Leachate Pond
S-52 Closed Leachate Pond
S-53 Closed Leachate Pond
S-54 Inactive Landfill
S-76 Inactive Landfill
S-8 Radiological Area 2
S-80 Upgradient
S-88 Inactive Landfill
1-2 Radiological Area 2
1-50 Upgradient
1-56 Inactive Landfill
1-58 Inactive Landfill
1-59 Radiological Area 2
1-62 Radiological Area 2
1-65 Radiological Area 2
1-7 Radiological Area 2
1-72 Concrete/ Asphalt Plants
D-14 Radiological Area 1
D-81 Inactive La!’ldfill
D-83 Radiological Area 2
D-89 Inactive Landfill
D-90 Upgradient
D-91 Upgradient
D-92 Closed Demolition Landfill
D-94 Radiological Area 2
LR-100 Inactive Landfill
LR-101 Inactive Landfill
LR-102 Inactive Landfill
MW-101 Radiological Area 2
MW-105 Earth City
MW-106 Upgradient
MW-107 Upgradient
MW-1205 unknown
MW-1206 unknown
MW-FlD North Quarry
MW-FlS North Quarry
MW-F2 Inactive Landfill
MW-F3 Radiological Area 2
PZ-1201-SS South Quarry
PZ-300-AD Upgradient
PZ-300-AS Upgradient
PZ-300-SS Upgradient
PZ-301-SS Upgradient

Inspected?
No-area overgrown
No
No
No
No
No
No-area overgrown
No
Yes No-area overgrown No
Yes
Yes
Yes No-area overgrown No-area overgrown
No-area overgrown
No
No
No-area overgrown
No-area overgrown
No
No
No
Yes
No-area overgrown
Yes
Yes
Yes
No-area overgrown
No
No
No
No
No
No
No
Yes
No
Yes
No
No
No
No

Condition Unknown-need to clear vegetation Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Abandoned 10/92 Abandoned 10/92 Unknown-need to clear vegetation Destroyed/ Abandoned Destroyed/Abandoned Unknown-unable to locate previously Destroyed/ Abandoned Abandoned 10/92 Abandoned 10/92 Abandoned 10/92 Unknown-need to clear vegetation Unknown-need to clear vegetation Unknown-need to clear vegetation Destroyed/Abandoned Destroyed/ Abandoned Unknown-need to clear vegetation Unknown-need to clear vegetation Destroyed/ Abandoned Reported as missing in 1994 Reported as missing in 1994 Destroyed/ Abandoned Unknown-previous report-damaged Destroyed/ Abandoned Destroyed/ Abandoned Unknown-beneath soil stockpile Unknown-need to clear vegetation Destroyed/Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Abandoned/decomissioned Abandoned/decomissioned Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Unknown-location buried beneath soil Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned
Page 1 of 1

Table 3: List of Monitoring Wells Potentially Available for Sampling, West Lake Landfill OU-1 and OU-2
Well Number General Location
D-12 Radiological Area 2
D-13 Radiological Area 2
D-3 Radiological Area 1
D-6 Radiological Area 2
D-85 Radiological Area 1
1-11 Radiological Area 2
1-4 Radiological Area 1
1-66 Radiological Area 2
1-67 Closed Demolition Landfill
1-68 Radiological Area 1
1-73 Concrete/Asphalt Plants
LR-103 Inactive Landfill
LR-104 Concrete/Asphalt Plants
LR-105 Inactive Landfill
MW-102 Radiological Area 2
MW-104 Inactive Landfill
MW-1204 South Quarry
PZ-100-KS North Quarry
PZ-100-SD* North Quarry
PZ-100-SS* North Quarry
PZ-101-SS North Quarry
PZ-102R-SS North Quarry
PZ-102-SS North Quarry
PZ-103-SS South Quarry
PZ-104-KS South Quarry
PZ-104-SD* South Quarry
PZ-104-SS* South Quarry
PZ-105-SS* South Quarry
PZ-106-KS South Quarry
PZ-106-SD* South Quarry
PZ-106-SS* South Quarry
PZ-107-SS Inactive Landfill
PZ-108-SS* South Quarry
PZ-109-SS* South Quarry
PZ-110-SS* North Quarry
PZ-111-KS North Quarry
PZ-111-SD* North Quarry
PZ-112-AS Radiological Area 1
PZ-113-AD Closed Demolition Landfill
PZ-113-AS Closed Demolition Landfill
PZ-113-SS Closed Demolition Landfill
PZ-114-AS* North Quarry
PZ-115-SS* North Quarry
PZ-116-SS South Quarry
PZ-200-SS North Quarry

Inspected?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Condition
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay

Page 1 of 2

Table 3: List of Monitoring Wells Potentially Available for Sampling, West Lake Landfill OU-1 and OU-2
Well Number General Location
PZ-201A-SS* South Quarry
PZ-202-SS South Quarry
PZ-203-SS South Quarry
PZ-204A-SS South Quarry
PZ-204-SS South Quarry
PZ-205-AS. South Quarry
PZ-205-SS* South Quarry
PZ-206-SS Concrete/ Asphalt Plants
PZ-207-AS Closed Demolition Landfill
PZ-208-SS North Quarry
PZ-302-AI Inactive Landfill
PZ-302-AS Inactive Landfill
PZ-303-AS Inactive Landfill
PZ-304-AI Inactive Landfill
PZ-304-AS Inactive Landfill
PZ-305-AI Concrete/Asphalt Plants
S-10 Radiological Area 2
S-5 Radiological Area 1
S-61 Radiological Area 2
S-82 Radiological Area 2
S-84 Radiological Area 1
D-93 Radiological Area 2
1-9 Radiological Area 2
D-81 Inactive Landfill
D-83 Radiological Area 2
1-62 Radiological Area 2
1-65 Radiological Area 2
1-7 Radiological Area 2
MW-101 Radiological Area 2
S-1 Radiological Area 2
S-8 Radiological Area 2
LR-102 Inactive Landfill
PZ-1201-SS South Quarry
D-94 Radiological Area 2
1-2 Radiological Area 2
S-75 Inactive Landfill
D-87 Closed Demolition Landfill
MW-103 Inactive Landfill

Inspected?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No-area overgrown
No -area overgrown
No-area overgrown
No-area overgrown
No-area overgrown
No-area overgrown
No-area overgrown
No-area overgrown
Yes
Yes
No -area overgrown
No -area overgrown
Yes
Yes
Yes
Condition
Okay
Okay
Okay
Okay
Okay
Okay

Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay -may be incorrectly labelled
Okay -may be incorrectly labelled
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown-beneath soil stockpile
Unknown-buried beneath soil
Unknown-previous report-damaged
Unknown-unable to locate previously
Casing damaged/obstructed
Casing obstructed
Casing damaged/obstructed
* Included in monitoring program for the permitted solid waste landfill.
Page 2 of 2

FIGURES

STANDARD OPERATING PROCEDURES

Standard Operating
Procedures for Groundwater
Sample Collection

Herst & Associates, Inc.
SOP-GW
Revision 4.2

Revised
June 25, 2012

/_ c-[v

~ERST & ASSOCIATES, INC.·l!’
‘.

4631 North St. Peters Parkway St. Charles, Missouri 63304 Telephone: (636) 939-9111 Facsimile: (636) 939-9757
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25.2012 Paqei
TABLE OF CONTENTS

1.0 INTRODUCTION ……………………………………………………………………………………………….. 1

2.0 STATIC GROUNDWATER LEVEL, MONITORING WELL DEPTH, AND MONITORING WELL VOLUME 1
I I I I I I I I!!!!!!!!! I I I I I I I I !IllIll I I I I I I I I I I I I I !Ill I I I I I I I I I IIIII I I I I I I I I I I I II !Ill I I I I I I
2.1 Facility-Wide Depth to Groundwater Measurements …………………………………………… 1

2.2 Monitoring Well Casing Volume Determination ………………………………………………….. 2

3.0 MONITORING WELL PURGING …………………………………………………………………………. 2

3.1 Low Flow Purging ……………………………………………………………………………………………. 3

3.2 Pump Purging …………………………………………………………………………………………………. 3

3.3 Bailer Purging …………………………………………………………………………………………………. 3

4.0 GROUNDWATER SAMPLE COLLECTION …………………………………………………………. 4

5.0 EQUIPMENT CLEANING …………………………………………………………………………………… 5

5.1 Electronic Water Level Indicator Decontamination ……………………………………………… 5

5.2 Non-Dedicated Submersible Impeller Pump Decontamination …………………………….. 5

5.3 Non-Dedicated Submersible Bladder Pump Decontamination …………………………….. 5

6.0 SAMPLE HANDLING …………………………………………………………………………………………. 6

7.0 SAMPLE DOCUMENTATION AND CHAIN-OF-CUSTODY ………………………………….. 6

8.0 FIELD QUALITY CONTROL (QC) SAMPLES ………………………………………………………. 7

8.1 Trip Blank Samples …………………………………………………………………………………………. 7

8.2 Field Blank Samples ………………………………………………………………………………………… 7

8.3 Equipment Blank Samples ……………………………………………………………………………….. 7

8.4 Field Duplicate Samples ………………………………………………………………………………….. 7

8.5 Matrix Spike I Matrix Spike Duplicate Samples …………………………………………………… 8

9.0 FIELD SHEETS I FIELD LOG BOOKS ………………………………………………………………… 8

LIST OF APPENDICES
Appendix A Example Groundwater Elevation Measurements Form Appendix B Example Monitoring Well Condition Report Appendix C Example Field Information Log
Standard Operating Procedures for Groundwater Sample Collection Herst &Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Page1

1.0 INTRODUCTION

The following guidelines describe groundwater sample collection and handling procedures for the Herst & Associates, Inc. personnel. The intent of the Standard Operating Procedures described herein is to provide procedures designed to yield representative and comparable analytical data from each site during each sampiing event.
There are three (3) principal steps in collecting groundwater samples from monitoring wells:
.,. Measuring static groundwater levels;
.,. Evacuating or purging well casings; and
;.. Collecting and preserving samples.
These steps are discussed more completely below.

2.0 STATIC GROUNDWATER LEVEL, MONITORING WELL DEPTH, AND MONITORING WELL VOLUME
2.1 Facility-Wide Depth to Groundwater Measurements
Static depths to groundwater and total depths will be measured at applicable facility monitoring wells and piezometers on the same day, if possible, and prior to purging and sampling of monitoring wells during each monitoring event. Depths to static groundwater levels will be measured from the surveyed mark at the top of the inner casing of each monitoring well. If there is no surveyed mark available at the top of the inner casing, the measurement will be performed on the same side as of the well as the lock on the exterior protective casing. Measurements of depth to groundwater and measurements of total monitoring well depth will be performed with an electronic water level indicator that is graduated in increments of one one-hundredth (1/100) of a foot and provides an audible and visual indication of water contact. Each measurement for depth to groundwater and each measurement for total depth will be performed twice (double-checked) to minimize the potential for false readings. Parts of water level measuring devices that contact groundwater will be thoroughly washed with a non-phosphate detergent (e.g. LiquiNox® or equivalent) followed by a rinse with deionized water or distilled water immediately after each use to minimize the potential for cross-contamination of monitoring wells.
Results of the facility-wide measurements of depth to groundwater will subsequently be used for generation of a potentiometric surface map for the monitoring event. The groundwater elevation in each monitoring well will be determined by subtracting the measured depth to groundwater from the top-of-inner-casing elevation. Appendix A presents an example Groundwater Elevation Measurements form. Additionally, while measuring facility-wide static groundwater depths, Herst & Associates, Inc. personnel will perform an evaluation of each monitoring well and piezometer and record the results of each evaluation on a Monitoring Well Condition Report. Appendix B presents an example Monitoring Well Condition Report.
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Paqe2

2.2 Monitoring Well Casing Volume Determination
The depth to groundwater will be measured immediately prior to monitoring well purging in order to calculate each well’s initial groundwater volume. The difference between the measured total monitoring well depth and depth to static groundwater level is the stabilized height of the groundwater column in the monitoring well. These measurements, taken from the same location on the inner casing described in Section 2.1 during each sampling event, will be used to determine the static monitoring well volume (in gallons) of groundwater in each well per the two (2)-step method described below.
1) The height (H) of the groundwater column is determined by measuring the total depth (TD) of the well and subtracting the measured depth to static water level (MSD).
H (feet) = TD (feet)-MSD (feet)
2) Use the following formula to calculate the static well volume of groundwater:
V =5.875 X 02 X H
Where:
V =Well volume (gallons);
D = Inside well diameter (feet); and
H = Height of groundwater column (feet).

3.0 MONITORING WELL PURGING

Purging monitoring wells prior to sample collection is necessary to remove stagnant groundwater, which may not be representative of in-situ conditions.
Purge parameters including pH, temperature, and specific conductance are monitored I recorded via either flow through cell or via field meters while purging. These purge parameters are measured periodically until purge parameter stabilization is attained according to the following guidelines:
Purge Parameter Stabilization Criteria
pH ± 0.2 standard pH units for 3 successive readings
Specific Conductance + 1 0% for 3 successive readings
Temperature ± 1.0 degree Celsius for 3 successive readings

Additionally, field turbidity will be measured during purging for informational purposes. If non.dedicated pumping equipment is used, the non-dedicated equipment will be cleaned (see Section 5.0, Equipment Cleaning) between use at each monitoring well.
In the event low-flow purging is impractical (limited availability of equipment, etc.), three (3) to five (5) well casing volumes will be purged (if possible) using either pumps or disposable
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Page3
bailers per the procedures described below. Purge parameters will be monitored I recorded similarty to the method described previously. If a monitoring well purges to a point precluding practical sampling (little or no available groundwater), the monitoring well will be completely evacuated of groundwater and allowed to recover for up to twenty-four (24) hours prior to sampling.
If containerization of purged groundwater is not required, then purged groundwater will be discharged to the ground at least fifteen (15) feet away and downslope of the monitoring well. If containerization of purged groundwater is required, then purged groundwater and spent equipment decontamination water (Section 5.0) will be containerized for disposal.
3.1 Low Flow Purging

Low-flow purging (also known as micropurging) is a purging method that has become widely utilized and may be applicable to purging of monitoring wells. This method involves using a pneumatic pump capable of low pumping rates (approximately one (1) liter per minute or less). Low flow purging eliminates the requirement for multiple well casing volume evacuation. Pump discharge rates are regulated and I or controlled to prevent turbulent flow (sample aeration), prevent damage to monitoring well components, and to minimize introduction of sediments into the monitoring well. Monitoring wells purged using low flow purging techniques will be purged as follows:
)or Record pH, specific conductance, and temperature.
)or Periodically monitor the change in groundwater depth in the well and maintain I adjust the pumping rate to minimize drawdown in the well, to the extent practical.
)or Continue pumping at a rate of approximately one ( 1) liter per minute or less until field parameters have stabilized as described in Section 3.0.

3.2 Pump Purging

When a non-dedicated pump is used to either purge three (3) to five (5) well casing volumes from a well or to evacuate the well of groundwater prior to sampling, purging with non.dedicated pumps will proceed as follows:
~ Continue purging groundwater from the well until a minimum of three (3) well casing volumes have been removed and field parameters stabilize.
~ Record the actual volume of groundwater removed.
~ Continue pumping low-recharge wells until at least one (1) well casing volume has been removed and field parameters have stabilized as described in Section 3.0, or until the well is dry.

3.3 Bailer Purging

When a bailer is used to purge a well, disposable polyethylene bailers will be used along with clean rope (nylon I polyester blend or equivalent). Wells will be purged with bailers as follows:
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Page 4
~ Slowly lower the bailer through the water column until the top of the bailer is below the groundwater surface.
).> Retrieve the bailer slowly up the water column and out of the well.
~ Continue removing groundwater from the well until a minimum of three (3) well casing volumes are purged and field parameters stabilize.
~ Record the actual volume of groundwater removed.
).-Continue bailing low-recharge wells until at least one well ( 1) casing volume has been removed and field parameters have stabilized as described in Section 3.0, or until the well is dry.
~ If bailing is selected as the purging and sampling method, one (1) disposable bailer will be used per monitoring well.
4.0 GROUNDWATER SAMPLE COLLECTION

Groundwater monitoring wells will be purged and sampled during each monitoring event by purging and sampling the least impacted well first, followed by the next least impacted well, and proceeding until the most impacted well is sampled last. Determination of which monitoring wells are impacted will be based upon recent historical analytical results for each monitoring well and will be performed prior to Herst &Associates, Inc. mobilization to the site.
For low-flow sampling, samples will be collected after achieving stabilization. For pump sampling and bailer sampling, samples will be collected at monitoring wells that yield three (3) to five (5) casing volumes after achieving stabilization. For a monitoring well that purges dry, samples will be collected as soon as the monitoring well has recharged sufficiently and within 24 hours after the monitoring well has been purged. Regardless of sampling methodology employed (bailers or pumps), care will be taken to avoid sample disturbance and to minimize aeration of samples or groundwater in the wellbore (casing and annulus). Bailers will be retrieved slowly through the water column and carefully emptied directly into the appropriate sample container(s).
Entrained air in sample containers or vials will be eliminated when collecting samples for analyses of Volatile Organic Compounds (VOCs).
Samples are collected in pre-preserved containers provided by the analytical laboratory in order of decreasing sensitivity of each analyte to volatilization. The recommended order of sample collection is listed below.
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Paqe5
Relative Sensitivity
Of Typical Groundwater Quality Constituents

Sample Container Preparation Example Analytes
Hydrochloric Acid Preserved* Decreasing sensitivity VOCs
Nitric Acid Preserved Metals
Sulfuric Acid Preserved 1 Chemical Oxygen Demand
Non-preserved Nutrients

* Samples to be analyzed for VOCs can be collected in unpreserved containers, but doing so reduces the laboratory holding time from fourteen (14) days to seven (7) days.
Collected samples will be immediately placed in insulated coolers with ice. Samples will be maintained with ice until delivered to the analytical laboratory.
5.0 EQUIPMENT CLEANING

The electronic water level indicator will be decontaminated between each monitoring well. Additionally, if utilized, non-dedicated, non-disposable purging and sampling equipment, including bailers and pumps, will be cleaned between wells.
5.1 Electronic Water Level Indicator Decontamination
The electronic water level indicator described in Section 2.0 will be decontaminated between monitoring wells by thoroughly wiping the graduated tape and water-sensing probe tip with a paper towel wetted with a solution of deionized or distilled water mixed with LiquiNox® (or equivalent) followed by thoroughly wiping the graduated tape and water-sensing probe tip with a paper towel wetted with deionized or distilled water. Wiping the water level indicator will be accomplished during removal of the graduated tape and probe tip assembly from the monitoring well.

5.2 Non-Dedicated Submersible Impeller Pump Decontamination
If a non-dedicated submersible impeller-style pump (e.g. Grundfos Redi-flo 2 or equivalent) is used for purging and sampling, the pump body, pump support cable, and sealed electrical wiring will be decontaminated using a three (3) step wash. The first wash will consist of a vessel containing a solution of deionized or distilled water mixed with LiquiNox® (or equivalent). The second and third washes will consist of vessels containing only deionized or distilled water (e.g. first rinse and second rinse). New, disposable polyethylene groundwater discharge tubing for the impeller-style pump will be used to purge and sample each monitoring well. Groundwater discharge tubing will not be decontaminated or reused.

5.3 Non-Dedicated Submersible Bladder Pump Decontamination
If a non-dedicated submersible bladder pump is used for purging and sampling, the pump body and pump support cable will be decontaminated using a three (3) step wash as
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Page6
described above. A new, disposable polyethylene bladder, downhole compressed air conveyance tubing, and groundwater discharge tubing will be used to purge and sample each monitoring well. Disposable bladders, downhole compressed air conveyance tubing, and groundwater discharge tubing will not be decontaminated or reused.

6.0 SAMPLE HANDLING

Sample handling and preservation techniques depend on the parameters to be analyzed. Groundwater samples will be collected, preserved and containerized in their order of sensitivity to volatilization (most sensitive to least sensitive). The purpose of sample preservation is to stabilize parameters of concern by retarding chemical or biological changes. Methods of preservation are generally limited to pH adjustment, chemical addition, and cooling. The order of sample collection is as follows: Volatile Organic Compounds (VOCs), samples preserved with nitric acid (metals), samples preserved with sulfuric acid (Chemical Oxygen Demand) and non-preserved samples (nutrients). Proper preservation will help ensure that samples are representative of the groundwater conditions. Field measurements for indicator parameters (pH, temperature, and specific conductance) will be performed on a portion of the sample that has been placed in a separate container, and not submitted for analyses of other parameters. This procedure avoids cross-contamination of laboratory samples by field instrumentation.
Collected groundwater samples will be maintained on ice in insulated coolers until shipment via courier (e.g. Federal Express) or until direct delivery to the laboratory. Chain-of-custody documentation (described in Section 7.0) will be shipped inside a cooler (if multiple coolers are shipped) to the laboratory. Each cooler shipped or directly delivered to the laboratory will be sealed with a Custody Seal (to verify no sample tampering has occurred) over the cooler opening and enclosed by clear packing tape wrapped several times around the cooler.
7.0 SAMPLE DOCUMENTATION AND CHAIN-OF-CUSTODY
Documentation that accompanies groundwater samples to the analytical laboratory generally includes the following:
~ Chain-of-Custodv lCOC) Records: COC records document in a legally defensible.
manner the history of collection, transport, and transfer of each sample. The
individual who is responsible for the samples from the time of collection to the time of
sample receipt by the laboratory will be documented in the Chain-of-Custody record.
Chain-of-Custody records allow documented tracing of the possession and handling
of individual samples from the time of field collection through laboratory analysis.
Chain-of-Custody documentation will present collected samples in chronological
order.
~ Sample Labels -Prevent misidentification of samples. Sample labels will include the
site name, sampler’s name, well designation, date and time of sample collection,
preservative added, and analysis requested.

In addition, field sheets and/or a field log book are used to document information concerning the collection of each sample from each monitoring point in the groundwater monitoring program. Information in the field sheets and/or field log book, described in Section 9.0,
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Paqe7
include dates and times of sample collection, well development methods used, weather conditions at the time of sample collection, condition of the wells, and remarks noting any unusual circumstances encountered.
8.0 FIELD QUALITY CONTROL (QC) SAMPLES

Field Quality Control (QC) samples will be collected to verify that sample collection and handling procedures were properly performed and that the procedures have not affected the quality of the groundwater samples. Field QC samples will consist of Trip Blank samples, Field (atmospheric) Blank samples, Equipment Blank samples, Field Duplicate samples, and potentially Matrix Spike I Matrix Spike Duplicate samples.
8.1 Trip Blank Samples

Trip blanks will be analyzed for VOCs only and consist of deionized water samples prepared in appropriate containers by the laboratory and received prior to mobilizing to the site. The trip blank samples then accompany the groundwater samples back to the laboratory for analysis. Preparation and analysis of trip blanks for VOCs indicates if site samples have been affected by transport-induced contamination, and can also be used to assess potential laboratory contamination. One ( 1) trip blank will be included for analysis with each sample shipment containing samples for VOC analysis during each monitoring event.
8.2 Field Blank Samples

Field (atmospheric) blank samples consist of deionized water samples collected in containers at the site during the sampling event and under the same environmental conditions as the monitoring well samples. The analysis of field blank samples can detect the influence of ambient site conditions that may bias the sample suite. One ( 1) field blank sample will be collected per twenty (20) or fewer collected groundwater samples (minimum 5% sample coverage) during each monitoring event.
8.3 Equipment Blank Samples

If non-dedicated, non-disposable purging and sampling equipment is used, the effectiveness of cleaning and decontamination procedures will be verified by the collection and analysis of equipment blank samples. After equipment decontamination is performed, an equipment blank sample is prepared by filling the purging and sampling device(s) with deionized water, followed by collection of the water into sample containers. Equipment blanks will be handled and analyzed in the same manner as collected groundwater samples. Equipment blank samples are not required if either dedicated purging and sampling equipment is used or disposable equipment (e.g. disposable bailers) is used. If non-dedicated purging and sampling equipment (e.g. non-dedicated pump) is used, one (1) equipment blank will be collected per twenty (20) or fewer collected groundwater samples (minimum 5% sample coverage) during each monitoring event.
8.4 Field Duplicate Samples

A field duplicate sample is collected from a monitoring well concurrently with collection of the primary groundwater sample from that well, and in an identical fashion. Analysis of field
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 PageS
duplicate samples provides an indication of the variability in analytical results associated with sample collection procedures and laboratory procedures. One ( 1 ) field duplicate sample will be collected per twenty (20) or fewer collected groundwater samples (minimum 5% sample coverage) during each monitoring event:
8.5 Matrix Spike I Matrix Spike Duplicate Samples
Matrix Spike I Matrix Spike Duplicate (MS I MSD) samples are collected from a monitoring well concurrently with collection of the primary groundwater sample from that well, and in an identical fashion. Alternatively, the analytical laboratory may elect to split a received primary groundwater sample into multiple portions and perform MS I MSD analysis on a separate portion of the sample. Once received by the analytical laboratory, a known quantity of target analyte is added to the MS I MSD samples by the laboratory analyst prior to analysis. Analysis of MS I MSD samples provides an indication of the effects of the groundwater matrix on analytical results. One (1) MS I MSD sample pair will be collected per twenty (20) or fewer collected groundwater samples (minimum 5% sample coverage) during each monitoring event.

9.0 FIELD SHEETS I FIELD LOG BOOKS

Field sheets (also called Field Information Logs) and I or field log books will be maintained during each groundwater sampling event. Field Information Logs I field log books will include field observations and well developing, well purging, and well sampling details. Additionally, the following information will be documented on Field Information Logs I field log books:
.,. Site name;
);. Site well designation;
, Sample collector’s name and affiliation (i.e., landfill, laboratory, or contract personnel);
J;> Weather conditions encountered during sampling (such as rain) that could affect
sample quality;
.,_ Pre-purging depth to water, measured from top of inner casing;
.,_ Total depth of well installation, measured from top of inner casing;
J;> Wetted casing or borehole volume;
);. Starting and ending times for well purging;
};> Purging rate (if low-flow purging or pump purging);
.,_ Depth to water measurement after sample collection; and,
.,_ Sample collection date and time.

A blank example field sheet is provided as Appendix C.

Global Presence Personal Attention
·~RST & ASSOCIATES, INC.
GROUNDWATER ELEVATION MEASUREMENTS
Site:
Personnel:

Page of
Herst & Associates, Inc. 4630 South Highway 94 -North Outer Road, St. Charles, MO 63304 (636) 939-9111 (636) 939-9757 fax

Global Presence
Personal Attention

#,_RST & ASSOCIATES, INC.’

GROUND WATER MONITORING WELL CONDITION REPORT

Field Certification:_….,…—-“~–:———-“””””:;~——-‘———-=–:——-.Signed Title Date
Herst & Associates, Inc. 4630 South Highway 94-North Outer Road, St. Char1es, MO 63304 (636) 939-9111 (636) 939-9757 fax

Global Presence Personal Attention
~RST& ASSOCIATES, INC’

FIELD INFORMATION LOG Part 1
Sample Point ID:
Facility: —————-.Location: Sampler(s): Sample Matrix: Top of Casing (ft, msl)
PURGE INFORMATION:
Method of Well Purge: Dedicated Equipment: Yes ___ No ___
DatefTime Initiated: Casing Diameter (inches):
Initial Water Level (feet): One Casing Volume (gal):
Initial Water Level Previous Event (feet): _______ One Casing Volume Previous Event (gal):
Ground Water Elevation (ft, msl): Total Yolume Purged (mL):
Ground Water Elevation Previous Event (ft, msl): —-Purged Dry?: Yes ___ No
Well Total Depth (feet): Water Level after Purge (feet):
Well Total Depth Previous Event (feet): DatefTime Completed:
PURGE DATA:
Time !-‘urge Kate (Hz/gpm) cumu1at1ve Volume (!lall Temp c·c> pH (std units) conductlvJty

Post

2012-07-10 – Monthly Status Report – June 2012 West Lake Landfill Operable Unit 1, Bridgeton, Missouri

ENGINEERING MANAGEMENT SUPPORT INC.

7220 West Jefferson Avenue, Suite 406 Telephone (303)940-3426
Lal

Post

2012-07-13 – Comments on Draft Gamma-Scanning QAPP review

Re: West Lake Landfill: Draft gamma-scanning QAPP for review CharlesA Hooper to: Dan Gravatt 07/13/2012 03:33PM
Dan,
Here are some things to consider, and I’ve got the track changes on to see the changes I had to the QAPP:
Looks like you’ve got a good number of background wells-good. But I see there’s no groundwater sampling?
Also, On the surface scan you might add traversing one way at a certain distance along parallel lines, and then traverse at a 90 degree angle to that so you get a more complete scan. There’s also probably areas that someone will have to walk amongst thick brush,etc. In those areas you might not get a good gps read, but that’s to be expected in the brush.
Consider sending the QAPP to Gregg Dempsey (ORIA-Las Vegas) and Stuart Walker before its final, it might be a good idea to touch base with them before the field work. Gregg may even have some staff that can participate. There cost is usually only travel.
Is there going to be a water level measurement? I’m not sure if the water level will impact the count rate, it shouldn’t, but I just don’t know.
Are there any known or anticipated contaminants in these wells of a chemical or toxic nature from the old landfill that would warrant using any additional ppe or decon methods? E.g., is there a need to check PID readings at wells, etc?
I’ve noted on page 7 to take a 6-sec counts for each 1-foot measurement. That way the measurement is 1/1 Oth of a 1-min count. Just something to consider, it might be easier to do that instead of waiting for a number on the meter to stop jumping around.
Hope this is helpful, -Chuck
~
West Lake Gamma Scan QAPP _CH.doc
Chuck Hooper Radiation Safety Officer US EPA, Region 7 901 North 5th Street Kansas City, Kansas 66101
(913) 551-7271 office Hooper.CharlesA@epa.gov
—————··-· -· -··–.
Dan Grav!’!_t!_______ ·-·-···–Diar1e, Chuck,_DeAndre, Att_<3~he_d)? adraftQA... o7t11t?o1?_o:3:33:1 oPM From: Dan GravatUR7/USEPA/US To: Dianee Harris/R7/USEPAIUS@EPA, CharlesA Hooper/R7/USEPAIUS@EPA, DeAndre Singletary/SUPR/R7/USEPAIUS@EPA Date: 0711112012 03:33 PM Subject: West Lake Landfill: Draft gamma-scanning QAPP for review 071 tt 11~~~~~ii~m1 Superfund Diane, Chuck, DeAndre, Attached is a draft QAPP to cover the upcoming in-house gamma scanning fieldwork at West Lake. Please review and comment. Sincerely, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063 Principles and integrity are expensive, but they are among the very few things worth having. [attachment "West Lake Gamma Scan QAPP.doc" deleted by CharlesA Hooper/R7/USEPAIUS] Al -Title and Approval Quality Assurance Project Plan Surface Gamma Scans and Down-hole Gamma Logs West Lake Landfill OUl Bridgeton, Missouri July, 2012 Diane Harris Date: Quality Assurance Manager DeAndre Singletary, Chief Date: MOKS Branch SUPR Division, EPA Region 7 Dan Gravatt, RPM Date: MOKS Branch SUPR Division, EPA Region 7 A2 -Table of Contents A 1. Title and Approval A2. Table of Contents A. Project Management .................................................................................................................. 3 A3. Distribution List ......................................................................................................•.... 3 A4. Project/Task Organization ............................................................................................ 3 AS. Problem Definition/Background .................................................................................. 3 A6. Project/Task Description ............................................................................................. .4 A7. Quality Objectives and Criteria for Measurement Data ............................................... 5 AS. Special Training Requirements/Certification ............................................................... 6 A9. Documentation and Records ........................................................................................ 6 B. Measurement/Data Acquisition .................................................................................................. 6 B1. Sampling Process Design ............................................................................................. 6 B2. Sampling Methods Requirements ................................................................................ 7 B3. Description ofDecontamination Procedures for Sampling Equipment.. ..................... 7 B4. Sample Handling and Custody Requirements .............................................................. 7 B5. Analytical Methods Requirements ............................................................................... 7 B6. Quality Control Requirements ...................................................................................... 8 B7. Instrument/Equipment Testing, Inspection, and Maintenance Requirements .............. 8 BS. Instrument Calibration and Frequency ......................................................................... 8 B9. Inspection/Acceptance Requirements for Supplies and Consumables ........................ 8 BlO. Data Acquisition Requirements ................................................................................. 8 B11. Data Management ...................................................................................................... 8 C. Assessment/Oversight ................................................................................................................ 8 C1. Assessments and Response Actions ............................................................................. 8 C2. Reports to Management ............................................................................................... 9 D. Data Validation and Usability ...................................................................... : ............................. 9 Dl. Data Review, Validation, and Verification Requirements ........................................... 9 D2. Validation and Verification Methods ........................................................................... 9 D3. Reconciliation with User Requirements ......................................................9 Abbreviations and Acronyms Figure 1: OU1 Extents and Monitoring Well Locations Appendix A Field SOPs A. Project Management A3. Distribution List This quality assurance project plan (QAPP) is prepared for the West Lake Landfill site in Bridgeton, Missouri, and is submitted as documentation of the protocols and procedures to be followed during collection of surface and down-hole gamma scans at the site. Distribution of this plan will be as follows: Dan Gravatt, RPM, MOKS/SUPR, U.S. EPA Region 7 Diane Harris, RQAM/ENSV, U.S. EPA Region 7 A4. Project/Task Organization This project is being managed and administered by EPA Region 7 according to the responsibilities described below: Dan Gravatt, RPM Project Manager MOKS Branch/SUPR Division (913) 551-7324 Responsibilities: Project Management; Field Team Leader; Field Data Collection Project Design and Implementation OSCs (to be determined) ERNB and/or ERSB branches Responsibilities: Field data collection AS. Problem Definition/Background The purpose of this QAPP is to support the collection of surface and down-hole gamma scans. The objective of this work is to collect additional data on the distribution ofradionuclides within Operable Unit 1 (OU1). Surface gamma scans and down-hole gamma scans ofboreholes were conducted as part of the Remedial Investigation (RI) for the site in the late 1990s, and the data was summarized in the RI Report (EMSI, April 2000). Work under this QAPP will re-scan the surfaces ofboth areas of OU 1 for gamma emissions, as well as scanning all accessible monitoring wells at the site for gamma emissions. Some ofthe monitoring wells were previously scanned (as boreholes, prior to their completion as wells) during the RI, and some have never been scanned. Gamma scanning field work will be performed by the RPM and OSCs using field.portable scanning instruments. No samples of any media will be collected. A6. Project/Task Description The objective of this study is to collect additional data on the distribution ofradionuclides within OUl. This QAPP addresses field procedures to collect the surface and down-hole gamma scan data. The measurement and data acquisition methods specified below have been selected to meet this objective. Figure 1 illustrates the site layout and monitoring well locations for down.hole scans. The data from this study will be assembled and provided to Dan Gravatt, RPM, MOKS/SUPR Division, U.S. EPA Region 7. A6.1 Work to be performed The scope offield activities to be performed for these gamma scans includes the following: • Scanning the surface ofOUl with a Ludlum Model2241-3 and Nal Tl detector; and • Scanning all accessible and intact monitoring wells associated with OU1 and OU2 with a Ludlum Model2241-3 and Ludlum 44-62 Nal probe to the maximum depth of the well or 150 feet, whichever is lessgreater. (1) Measurements (a) Areas and monitoring wells to be sampled All accessible portions of the surface ofOUl will be scanned with the Ludlum Model 2241-3 and its Nal Tl detector. It is anticipated that vegetation or rubble piles may prevent scanning of portions of Area 2 of OU1. All accessible and intact monitoring wells on-site capable ofpassing the Ludlum 44-62 Nal down-hole probe will be scanned. (b) Analyses Both the Ludlum Model2241-3 with Nal Tl detector and the Ludlum 2241-3 with 44-62 Nal probe will collect real-time data on gamma intensity. No laboratory samples will be collected or analyzed. (2) Standards/Criteria As gamma scanning is a semi-quantitative data collection technique that does not yield specific concentrations of any radioisotopes in environmental media, there are no applicable thresholds or criteria for determining whether a particular gamma count value is acceptable or unacceptable. This data will be used to qualitatively update EPA's knowledge of the distribution of radionuclides at the site. (3) Personnel/Equipment Requirements All personnel performing activities covered by this QAPP shall comply with the Occupational Safety and Health Act, as well as EPA regulations for worker health and safety. Personnel requirements are discussed in Section A8. Level D PPE consisting of steel-toed boots, appropriate gloves, long pants and long-sleeved shirt at a minimum will be required for field personnel. Additional PPE for operating EPA's utility terrain vehicles will include full-face helmets and eye protection. (4) Assessment Techniques Field instrumentation will be calibrated and demonstrated to be working properly as described in B.7 below. (5) Project Schedule The anticipated schedule for this sampling effort will consist ofone field scanning mobilization in August, 2012. The field work is anticipated to take one week. (6) Documentation Data collection activities will be documented with the following (more detailed descriptions of the documentation is provided in Sections A9, B 10, and C2 of this QAPP): Field records; Data Summary tables; and Data Summary figures. A7. Quality Objectives and Criteria for Measurement Data The purpose of this investigation is to obtain additional gamma scans of the surface and down-hole gamma logs of accessible monitoring wells. No samples of any media will be collected. As gamma scanning is a semi-quantitative data collection technique that does not yield specific concentrations of any radioisotopes in environmental media, the following quality objectives are generally in a narrative form. Representativeness will be addressed by proper calibration and use of the gamma scan probes for the surface and down-hole measurements, so that the instrument .readings correlate to the distribution of gamma-emitting radionuclides at the site. Comparability expresses the confidence with which one set of analytical data may be compared with another. Comparability will be qualitatively addressed by comparing the results of the surface gamma scan with the results ofthe previous RI surface gamma scan; however, due to differences in the methodologies used, differences in the two scan results will not necessarily indicate any change in conditions at the site~ Completeness is a measure of the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under nonnal conditions. Field completeness is a measure of the amount ofvalid measurements obtained from the measurement taken in the project. The field completeness objective for this project will be 80%. 100% completeness is not required for the data to be useable for its intended purpose. Accuracy and precision will be addressed by proper calibration and use of the gamma scan probes for the surface and down-hole measurements, so that the instrument readings accurately measure gamma emission rates at the site. A8. Special Training Requirements/Certification All personnel who will be on-site performing field activities associated with this investigation must have successfully completed an initial 40-hour hazardous waste operations training course and, thereafter, an annual 8-hour refresher course. The training must comply with Occupational Safety and Health Administration (OSHA) regulations found in 29 Code of Federal Regulations (CFR) 1910.120(e). Personnel must also have had advanced radiation safety training, and will be required to wear a thennoluminescent dosimeter and electronic personal dosimeter while on-site. Personnel must be trained and certified to operate EPA's utility terrain vehicles, which will be used for the surface gamma scan. A9. Documentation and Records The project manager will be responsible for ensuring the most current version of the QAPP is available and distributed to all involved parties, and that data collected during this field work is properly stored and reported to stakeholders. B. Measurement/Data Acquisition B1. Sampling Process Design The surface gamma scan will be conducted with a Ludlum Model2241-3, with a 3-by 3.inch Nal Tl scintillator probe. The scan will be conducted in a serpentine pattern across each area of OU1, with a-spacing between scan lines of 30 feet. Less spacing is appropriate in elevated areas in order to provide detail along contour lines (the RI QAPP specified a 30' grid). The detector will be held approximately twelve inches above the ground surface while the surveyor moves the detector at a constant speed approximating walking pace, and the system will collect a reading every two seconds. Global Positioning System (GPS) data will be simultaneously collected, and the resulting gamma results will be mapped. Prior to scanning the site, background gamma levels will be established at a nearby uncontaminated area (the RI QAPP specified "Local background will be established by taking a measurement off-site on the open field east of the site and east of the St. Charles Rock Road entrance to the site"). The down-hole gamma scan will be conducted with a Ludlum Model 2241-3, with a 44.62 detector. The detector will be lowered to the bottom of each accessible well or to a maximum depth of 150 feet, whichever is lessgreater. The detector will then be raised in one-foot increments, and measurements will be recorded at each interval using the scaler set for a 6.second countas soon as the reading on the instrument appears stable. Wells PZ-103SS,PZ-104SS, PZ-105SS, PZ-108SS, PZ-111 SD and PZ-116SS are designated as background wells to represent naturally-occurring gamma emissions in the subsurface geologic materials. These wells were selected for their depth ( 150 feet or more), their distance from the OU 1 cells, and their lack of any historical detections of radionuclides in groundwater above applicable standards. B2. Sampling Methods Requirements Standard operating procedures for the gamma scanning instrument and detectors will be followed. These SOPs are included in Appendix A. The utility terrain vehicle will be driven at a speed appropriate to generate a thorough density of data points and to prevent the generation ofdust. The EPA field team leader will determine the need for any change in sampling method or locations, if field personnel note difficult site conditions. Any corrective actions required during the implementation of field sampling activities will be documented by the field team leader. B3. Description of Decontamination Procedures for Sampling Equipment The down-hole gamma probe shall be decontaminated prior to logging the first well and between each well by washing with a soap solution (such as Alconox) and rinsing with potable water. The rinse water will be poured onto the ground away from the well after use. The surface gamma scan instrument does not contact the land surface and does not require decontamination. The utility terrain vehicles, field personnel boots, and any other equipment potentially contaminated by soil will be decontaminated by dry brushing to remove the material. Equipment will then be scanned with a Ludlum Model44-9 Geiger-Muller "pancake probe" to ensure that any radioactive contamination has been removed down to a level ofthree times the background count rate with the pancake probe. Any solid investigation-derived waste such as gloves or paper towels will be bagged and surveyed prior to disposal disposed of at the solid waste transfer facility on-site. B4. Sample Handling and Custody Requirements No samples of any media will be collected during this work. B5. Analytical Methods Requirements No analytical methods will be used for this work. B6. Quality Control Requirements Quality control will be maintained during the field work by operating the instruments in accordance with the manufacturer's instructions and EPA's SOPs. B7. Instrument/Equipment Testing, Inspection, and Maintenance Requirements The field equipment testing, inspection, and maintenance will be performed in accordance with the manufacturer's recommendations. B8. Instrument Calibration and Frequency Field equipment calibrations will be performed in accordance with the manufacturer's recommendations prior to mobilization and as needed while on-site. B9. Inspection/Acceptance Requirements for Supplies and Consumables No supplies or consumables will be required for this work. B 10. Data Acquisition Requirements Data acquired from the surface gamma scan instrument and its GPS tracker will be downloaded to EPA computer systems and mapped as necessary to support program goals. Data from the down-hole gamma scanner will be recorded by hand in field logbooks and transcribed into an EPA computer system, or entered directly into an EPA l~ptop in the field in real time. B11. Data Management Data will be stored and backed up on EPA computer systems, filed in the Records Center, and distributed to stakeholders as needed. C. Assessment/Oversight 0. C1. Assessments and Response Actions The EPA QA manager or their designee may conduct an audit of the field activities for this project if requested by the EPA project manager. The EPA QA manager will have the authority to issue a stop work order upon finding a significant condition that would adversely affect the quality and usability ofthe data. The EPA project manger will have the responsibility for initiating and implementing response actions associated with findings identified during the on-site audit. Once the response actions have been implemented, the EPA QA manger will perform a follow-up audit to verify and document that the response actions were implemented effectively. C2. Reports to Management A report of the field work and analytical results will be prepared by the project manager and copies shared with the state and other stakeholders. This report will also include information on any performance evaluations, audits, and significant QA problems, as applicable. D. Data Validation and Usability Dl. Data Review, Validation, and Verification Requirements The EPA Project manager will be responsible for overall validation and final approval of the data in accordance with project purpose and us~ ofthe data. D2. Validation and Verification Methods As the data collected by the planned field work is semi-quantitative, no additional data validation or verification methods are planned. D3. Reconciliation with User Requirements Once the data results are compiled, the EPA project manager will review the data results to determine ifthey fall within the acceptance limits as defined in this QAPP. Completeness will be evaluated to determine if the completeness goal for this project has been met. If the completeness objective has not been met, the EPA project manager will determine an appropriate course of action. Failure to meet the completeness objective will not necessarily require re.sampling. Upon compilation of the data, the RPM will review the data in relation to the quality objectives and criteria for measurement, to identify any limitations on the use ofthe data. The RPM will evaluate data to ensure the information sufficiently characterizes the distribution of gamma-emitting radionuclides at the site, and assess the degree to which the Quality Objectives in A. 7 and the Quality Control measures in 8.6 have been met. If the RPM determines data quality indicators do not meet the project requirements, then the data may have to be discarded and re-sampling may be required. CFR EPA GPS osc OSHA ou PPE QA QAPP QC RI RPM RQAM SOP sow Abbreviations and Acronyms Code ofFederal Regulations U.S. Environmental Protection Agency Global Positioning System On-scene commander Occupational Safety and Health Administration operable unit personal protective equipment quality assurance quality assurance project plan quality control remedial investigation Remedial project manager regional quality assurance manager standard operating procedure statement of work

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2012-07-24 – EPA request for conference call to discuss upcoming activities and community outreach

Re: Conference Call Request Hattie Thomas to: Huckstep, Ramona 07/24/201211:19AM “Doster Branden” “Zamarripa Ruben” “Muenks Shawn” Debbie
Cc· ‘ ‘ ‘ ‘ ‘ ‘
· Kring, Dan Gravatt, DeAndre Singletary
Good morning-Thanks for the email and voice mails. Debbie Kring and I will touch base with you once she returns from site travel. Thanks -HL T
Hattie L. Thomas
Deputy Director
Office of Public Affairs EPA Region 7
901 N. Fifth Street Kansas City, KS 66101 Ph: 913-551-7762, Fax: 913-551-7066
“Huckstep, Ramona” I was just following up from our telephone con … 07/24/2012 09:39:52 AM
From: “Huckstep, Ramona”
To: Hattie Thomas/R7/USEPAIUS@EPA
Cc: “Muenks, Shawn” , “Zamarripa, Ruben” , “Doster, Branden”
Date: 07/24/2012 09:39AM
Subject: Conference Call Request
I was just following up from our telephone conversation last week regarding West Lake Landfill and our request to have a conference call with you and your team regarding upcoming activities at the site and how these may include community outreach.
These activities include:
1.
Groundwater sampling at the landfill starting August 6th -As a Community Involvement Coordinator I will be touring the site

2.
Missouri Coalition for the Environment Public Meeting focusing on West Lake Landfill

3.
Upcoming potential presentation by EPA to the Bridgton City Council

4.
Updates to our MDNR website -per a request from Kay Drey, we have posted the Sampling and Analysis Plan for Groundwater Sampling .http://dnr.mo.gov/env/hwp/fedfac/westlakelandfill-ffs.htm

We would appreciate the opportunity to coordinate with your team on these items and
any other items you would like to discuss. We were hoping to speak with you and your team before the August 6th sampling event begins, if possible. Thank you for your time and consideration of these topics.
Ramona Huckstep, M.S., M.P.A. Community Involvement Coordinator
Hazardous Waste Program Missouri Department of Natural Resources
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573-522-1540 ramona.huckstep@dnr.mo.gov

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2012-06-21 – Gravatt, Dan, Kring, Debbie – Revised SFS Report questions

Your requested information for WLF fact sheet Dan Gravatt to: Debbie Kring 06/21/2012 03:25PM
Debbie, the Final SFS report was approved with comments in a letter dated November 14, 2011 -see attached. The PRPs submitted a revised final report on December 28, 2011 that addressed all of EPA’s comments from the November 141etter. No additional letter to the PRPs was sent in response to the December 28 revised final SFS report. After I verified that all comments were addressed, the revised final report was then posted to EPA’s webpage on December 29th.
Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063
Principles and integrity are expensive, but they are among the very few things worth having.
Westlake Final SFS approval with comments.pdf
DUO/

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 7

901 NORTH 5TH STREET KANSAS CITY, KANSAS 66101
NOV I 4 2011
CERTIFIED MAIL
RETIJRN RECEIPT REQUESTED

Paul Rosasco, P .E.
Engineering Management Support, Inc.
7720 West Jefferson Avenue, Suite 406
Lakewood, Colorado 80235

Dear Mr. Rosasco:
Re: Approval with Request for Modifications ofFinal Supplemental Feasibility Study
The U.S. Environmental Protection Agency has reviewed the Final Supplemental Feasibility Study received on October 3, 2011. Pursuant to paragraph 40 of section VIII (Work to be Performed) of Administrative Order on Consent, VII-93-0005, as amended, and the recaptioned Administrative Settlement Agreement and Order on Consent, the EPA hereby approves the Final Supplemental Feasibility Study with request that the modifications identified below be made and submitted as changed pages to the subject document.
1.
Section 1.1, page 16: Use the exact language from pages xi and xii in the Record ofDecision instead ofitems 1 through 5.

2.
Section 1.1, page 17: In the first paragraph on this page, include the actual language for the OSRTI “Performance Standards” memorandum as follows:


The proposed cap should meet UMlRCA guidance for a 1,000-year design period including an additional thickness to prevent radiation emissions.


Air monitoring stations for radioactive materials should be installed at both on-site and off-site locations.


Groundwater monitoring should be implemented at the waste management unit boundary and also at off-site locations. The groundwater monitoring program needs to be designed so that it can be determined whether contaminants from the landfill have migrated across the waste management unit boundary in concentrations that exceed drinking water Maximum Contaminant Levels. The groundwater monitoring program needs to measure for both contaminants that have historically been detected in concentrations above MCLs (e.g., benzene, chlorobenzene, dissolved lead, total lead, dissolved arsenic, total lead, dissolved radium and total radium) and broader inclicators ofcontamination (e.g., redox potential, alkalinity, carbonates, pH and sulfates/sulfides).


Flood control measures at the site should meet or exceed design standards for a 500-year storm event under the assumption that the existing levee system is breached.

In addition, section 5.2 should show how each ofthese additions is now incorporated into the design.
3.
Section 1.1, page 17: In the first paragraph, delete the phrase ” … which would be incorporated into the remedial design phase of implementation ofthat remedy.” It is likely that a decision document will be appropriate for all significant and/or fundamental changes.

4.
Section 2.1.4, last paragraph, page 26: Change the fourth sentence to read “An agreement was reached between the St. Louis Airport Authority and Bridgeton Landfill, LLC, whereby the Bridgeton Sanitary Landfill ceased disposal ofmunicipal waste, organic waste and putrescible waste in 2005 in order to reduce potential bird impacts to aircraft operations.”

5.
Section 2.3, second paragraph, page 40: This section states that radon flux from Areas 1 and 2 measured during the Remedial Investigation did not exceed the 20 pCi!m2s UMTRCA criterion; however, the third paragraph of section 3.1.1.3 states that the radon flux did slightly exceed this value. These sections must be reconciled.

6.
Sections 3 .1.2.1 0 and 3 .1.2.11, pages 61-65: These two sections state that the September 20, 2010, letter from the St. Louis Airport Authority to the EPA and the minutes ofthe September 7, 2010, meeting between the St. Louis Airport Authority and the EPA are included in Appendix A; however, these documents are missing from Appendix A and must be included.

7.
Section 3.1.2.11, fifth paragraph, page 64: The text ofthis section, beginning with “On September 7, 2010 … “should be replaced with the following, more concise text:

On September 7, 2010, representatives of Bridgeton Landfill, LLC, and the EPA
met with representatives ofthe St. Louis Airport Authority and the U.S.
Department ofAgriculture to follow up on concerns raised that the Restrictive
Covenant entered into between landfill owners and STLAA would prohibit
construction ofthe “on-site cell” evaluated as part ofthe SFS. The EPA provided
a summary ofthe alternatives considered in the SFS. S’ILAA and USDA stated
that an excavation remedy would create risks that they could not even calculate,
and that monitoring and management ofrisks created by wildlife would be
impossible. STLAA noted that under the ROD-selected remedy, the site will
present no risk to human health or the environment and said that creating new
risks by implementing an excavation remedy did not seem advisable.

· STLAA further stated that an excavation remedy would necessitate FAA review
and likely result in objections from airlines as well as the FAA. STLAA was
particularly concerned that either excavation alternative would take years to

perform. .
2

The EPA asked whether the airport’s concerns would be alleviated by excavation ofonly Area 2 (outside the 10,000-foot range). The response was no, the entire area is within tlie Restrictive Covenant and subject to FAA review if”new · landfilling operations” were to occur. In particular, STLAA explained that construction ofan on-site disposal cell would not qualify as an expansion or change to an existing landfill becauSe the Bridgeton Sanitary Landfill was already in closure mode, but would instead constitute “new operations” at the site and therefore would trigger FAA review. STI..AA could not predict the changes that any excavation activities would cause to the migratory patterns ofbirds and could
not take the risk that wch changes would increase the local bird population.
STLAA stated that its 2006 letter, submitted dming.the public comment period on the ROD for Operable Unit 1, still reflected its position.
Notes ofthis 2010 meeting were provided to the EPA and are included in
Appendix A.

By letter dated September 20,2010, (Appendix A), the city ofSt. Louis Airport
Authority provided written comments on the SFS Work Plan. The letter identified ··
the West Lake Landfill as a hazardous wildlife attractant for the airport. The city
stated that the excavation (“complete rad removal”) alternatives would adversely
affect wildlife mitigation measures taken by the airport to protect aircraft from
bird strikes~ thereby placing the city in violation ofthe FAA ROD requiring that
such mitigation efforts be undertaken and maintained. The city also stated that
implementation ofthe excavation altemati.ves would violate the Restrictive
Covenant. The city specifically identified creation ofan on-site engineered
disposal cell as a direct vi elation ofparagraph 1 ofthe Restrictive Covenant. The
city further indicated that the proposed location for the on-site engineered
disposal cell would be approximately 8,000 feet from the airport and is
incompatible with state and federal regulations that prohibit placement ofa new
solid waste disposal site within a 10,000-foot radius of an active runway.
8.
Section 3.4, first paragraph, page 75: This section still refers to the uranium cleanup level as “50 pCilg plus background” despite a comment on the draft SFS report (additional cominent 40) requesting that this Cleanup level be expressed as a single concentration which includes background. This change must be made throughout the document. In addition, the reference to section 2.1.2 ofthe SLAPS ROD is incorrect; the correct reference appears to be section 2.8.2.1.

9.
Section 5.2.1.1.2, page 109: This section states”… implementation ofthe ROD-selected remedy without performing any waste regarding (cutting) is not considered feasible” without discussing the reasons for this determination. This section must briefly summarize the reasons and limitations that led to this determination.

10.
Section 5.2.1.1.3, page 112: The negative easement may apply to the ”management ofmaterials during·recontouring” and this section should either state that it may apply o~: explain why it would not.

11.
Section 5.2.1.3, fourth paragraph, page 114: This section states that the ROD-specified cover design would have sufficient thickness and characteristics to be protective against gamma radiation and radon emissions and references Appendix F for the calculations behind this statement. Appendix F calculates radon fluxes but does not appear to quantitatively assess gamma shielding. Section 6.2.1; 1, second paragraph, states that the two feet ofclay proposed for the cap would provide gamma radiation shielding but does not provide any calculations to support this statement. Gamma shielding calculations must be added to Appendix F.

12.
Section 5.2.2:1, last sentence, page 123: Financial assurance would need to be provided in
perpetuity. Delete the reference to a “Consent Decree.”

13.
Section 5.3.2.12, last paragraph, page 134: See comment 12 above.

14.
Section 6.2.2.5.1, page 191: The EPA provided feedback on this section in response to a comment on the draft SFS report (specific comment 33) requesting that text be inserted in this section to justify excluding risks from loose RIM released during truck and rail transport. The requested text was not included in the final SFS and must be included.

15.
Figure 2: The EPA previously commented on Figure 3 ofthe draft SFS report asking for adjacent agricultural land and nearby residential areas to be labeled. In the final SFS report, Figure 2 has the trailer park and Spanish Village labeled but does not include a label for the agricultural/residential property south ofthe on-site storm watel· pond. This property must be labeled on the figure.

16.
Figure 4: The·contour intervals and contour elevations are missing or too small to be readable on this figure. The figure should be made larger so this information is readable.

17.
Figure 35: The.con,tour intervals and contour elevations are missing or too small to be readable on this figure. The figure should be made larger so this information is readable.

18.
Appendix B, section 3, page 4: In the second-to-last paragraph, the second sentence must make it clear that the results being discussed apply to Area 2.

19.
Appendix B, table 5: The apparently erroneous result of4.4 billion pCilg for boring PVC-21 has not been corrected as requested in the EPA additional comment .47 on the draft SFS report. This must be corrected.

20.
Appendix G, section 3.1: This “section must briefly describe how the baseline gamma radiation monitoring mentioned here will be conducted .

.21. Appendix H, section 10: The EPA’s RiskAs~ssment comment 36 on the dra.fl’SFS report
(pertaining to Risk Assessment section 9.3.5} requested that this section evaluate risks due to exposure to RIM which may fall from trucks during transport. Yom response to the EPA’s specific comment 33 on the draft SFS report provided a justification for excluding these risks from the risk assessment, and this justification should be included here.
4

Plea8e submit the changed pages required QY the corrections above within fifteen (15) days ofyour receipt ofthis letter. Ifyou have any questions, you may contact me~(913) 551-7324.
Daniel R Gravatt Remedial Project Manager Missouri/Kansas .Remedial Branch Superfund Division
cc: Mr. Shawn Muenks, Project Manager, Missouri Department ofNatural Resources Ms. Victoria Warren, Facility Representative, Republic Services Mr.DougAmmon, Branch Chief, EPA Headquarters (email only) Ms. Charlotte Neitzel, Attorney, Holme Roberts & Owen (email only) Ms. Christina Richmond, Attorney, U.S. DOl for US DOE (email only) Ms. Kate Whitby, Attorney, Spencer Fane Britt &.Browne (email only) Mr.Bill Beck, Attorney, Lathrop & Gage {email oniy) .
5

Post

2012-07-05 – Meter settings for down-hole probes – Ludlum 2200 or Ludlum 2350

Information and SOPs for gamma scanning instruments Dan Gravatt to: CharlesA Hooper 07/05/2012 10:15 AM
Chuck, I’m putting together a QAPP for the upcoming gamma scan work. Some questions came up which I hope you can help me with:
-Are there SOPs for the “RAT” (Ludlum model 2221 with 3×3″ Nal Tl detector, in a baby carriage) and/or the down-hole probe and its instrument? If so, I need to append them to my QAPP.
-What is the model number on the down-hole probe and the instrument the down-hole probe will be connected to? Previous down-hole scans used a Ludlum 2200 or 2350 with an energy threshold of 100 keV and an open energy window-I hope that means something to you.
-What’s a reasonable speed to move the RAT across the surface, and a reasonable distance between the sensor and the ground surface? I assume we will mount it on one of the UTVs for this work due to the large area.
-What rad safety or other certifications I training are appropriate for folks doing this work?
-What are your thoughts on personnel and equipment (primarily the UTV) decontamination for this work?
-Should you be a signatory on this QAPP?
Thanks, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063
Principles and integrity are expensive, but they are among the very few things worth having.
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Post

2012-07-06 – Senator McCaskill inquiry for a status update on West Lake Landfill

Re: ACTION REQUIRED: Sen. McCaskill inquiry for a status update on West Lake Landfill Dan Gravatt to: LaTonya Sanders 07/06/2012 01 :26PM
Cc: Audrey Asher, Debbie Kring
LaTonya,
The summary document you attached on West Lake is somewhat out of date now. Rather than updating it, I suggest you coordinate with Debbie Kring to use the Fact Sheet she’s been developing for the site. Both Audrey and I reviewed and commented on Debbie’s draft fact sheet just last week. It is my understanding that Karl wanted OPA to develop this fact sheet for his use in briefing the congressionals , so it would probably be better if they all got the same message at the same time.
Sincerely, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063
Principles and integrity are expensive , but they are among the very few things worth having.
LaTonya Sanders Hi Dan, I received a call today from Sen. McCas … 07/06/2012 12:53:25 PM
From: LaTonya Sanders/R7/USEPNUS To: Dan Gravatt/R7/USEPNUS@EPA Cc: Audrey Asher/R7/USEPNUS@EPA Date: 07/06/2012 12:53 PM Subject: ACTION REQUIRED: Sen. McCaskill inquiry for a status update on West Lake Landfill
Hi Dan,
I received a call today from Sen. McCaskill’s DC office, requesting a status update on West Lake Landfill.
Attached is an update I shared with congressional staff when I performed courtesy visits in May.
Is this update still current to share with Sen . McCaskill? Is there new or additional information to share?
Please advise.
Thanks.

[attachment “Westlake Landfill Update.docx” deleted by Dan Gravatt!R7/USEPA/US]

~T~E..~
U.S. Environmental Protection Agency, Region 7 Office of the Regional Administrator Office of Public Affairs 901 N. 5th Street Kansas City, KS 66101
PH: 913-551-7555 FX: 913-551-7066 EM: sanders.latonya@epa.gov

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Get -tips -to prO”teC”t Children’s heal-th a-t http:lfwww.epa.gov/region7/Ci-tizens/childrens_heal-th.h”trn

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2012-07-09 – Revised West Lake Landfill Update Fact Sheet

IMPORTANT: Revised Westlake Landfill Update Fact Sheet-Please Review as soon as possible Debbie Kring to: Dan Gravatt, Audrey Asher, DeAndre Singletary 07/09/2012 06:19PM Cc: Rich Hood, Hattie Thomas, Christopher Whitley
History: This message has been replied to.
I am attaching the revised Westlake Fact Sheet that you have each weighed in on. I have made most of the changes you recommended, but updated to reflect your preferences, using some slight modifications, i.e., in one paragraph, you want the statement, “the decision selected ….. “-decisions don’t select, people do -so that’s an example of something that keeps the same reference context, but modifies the grammatical tone.
I would like to put this through concurrence in the next day, and I know LaTonya would like to use in her call to Sen. McCaskill’s office tomorrow, so please look over. I am not tied to anything in particular, but want to keep the tone consistent with the use of verbs 🙂
Thanks.
Debbie
lt~•.•…J.•. WestlakelandfiiiUpdateFSJuly2012 .doex
Debra L. Kring Public Affairs Specialist/Local Elected Officials Liaison EPA-Region 7, Office of Public Affairs 901 North 5th Street Kansas City, Kansas 66101 (913).551-7725 or toll-free@ 1-800-223-0425
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Region 7 Fact Sheet
Iowa
Kansas
Missouri
Nebraska

Nine Tribal Nations July 2012
Update on Activities Supporting the Record of Decision (ROD)
Amendment for the Westlake Landfill Superfund Site
Bridgeton, Missouri

INTRODUCTION
The U.S. Environmental Protection Agency (EPA) Region 7 has been working in the Bridgeton community to address environmental issues at the Westlake Landfill over a multi-year period. The Westlake Landfill is comprised of two (2) operable units (OUs). OU-1 contains a mixture of radiologically-contaminated soils, municipal refuse and construction/demolition debris. OU-2 includes several sanitary landfill cells containing municipal refuse and construction/demolition debris.
After conducting extensive investigations, holding numerous public forums, and responding in detail to public comments, EPA signed a Record of Decision (ROD) for QU-lin May 2008. This decision document outlined the selected remedy, which included the placement of an engineered cover system over the radiologically-contaminated areas, long-term groundwater monitoring, and the adoption of institutional controls to restrict access.
After the ROD was signed, EPA continued to receive public comments about the selected remedy. In response to those comments, EPA tasked the potentially-responsible parties (PRPs) to conduct a Supplemental Feasibility Study (SFS) for OU-1 that further evaluated the ROD-selected remedy, as well as full-scale excavation of the radiologically.contaminated landfill material and disposal either at a permitted off-site facility or in a new, on-site engineered disposal cell.
The SFS Work Plan was released to the public in June 2010. After reviewing several draft versions of the document, EPA approved and released the SFS Report to the public in December 2011. The estimated costs defined for each alternative in the SFS Report exceeded the threshold, which triggered a formal review and evaluation by EPA’s National Remedy Review Board (NRRB). Between January 2012 and the present time, the NRRB has weighed in with numerous draft comments and recommendations on the SFS Report. The NRRB recommended that EPA, Region 7: evaluate additional groundwater sampling to refresh the data; conduct a more detailed study of the partial excavation alternative; and conduct a more detailed analysis of potential treatment technologies for the radiologically.contaminated landfill material. EPA, Region 7, then tasked the PRPs to conduct some ofthis work as an amendment to its original Consent Order.
In response to more general NRRB recommendations, EPA, Region 7 also decided to update gamma scans ofthe surface ofOU-1 and conduct vertical gamma scans ofmonitoring wells at the site. EPA, Region 7 will perform the gamma scans.
The work will be conducted by PRPs under EPA
oversight, with the following proposed 2012/2013
schedule:
July ’12 -Groundwater sampling (PRPs to conduct, EPA & MDNR will take splits);
August’ 12-Gamma scan evaluation to further rtrfine distribution of radiologically-impacted wastes (EPA staffto conduct);
Summer ’12-’13 -Additional studies to address the NRRB draft comments. (PRPs to perform).
In coordination with its stakeholders, EPA will host a public availability session near the end of2012 in Bridgeton to: convey updated data results; discuss the scope ofthe PRP additional studies; and take questions about the next steps in the ROD.Amendment process.
Communications about the Westlake Landfill
Superfund Site will be addressed through a combination of venues, including, but not limited to: ads in the local newspaper; fact sheets; EPA’s website; and local and regional records centers. Community members and other interested persons, can also contact EPA’s Community Involvement Coordinator, Debbie Kring, via telephone or e-mail as listed below.

AVAILABILITY OF DOCUMENTS
The SFS Report is available online at: http://www.epa.gov/region7/cleanup/npl_files/west_l ake landfill/index.htm
The administrative record, and other site-related documents for the Westlake Landfill Superfund Site are available for review at the following locations:
The Bridgeton Trails Branch of the St. Louis County Library 3455 McKelvey Road Bridgeton, Missouri
AND . EPA Region 7 Records Center

901 North 51h Street
Kansas City, Kansas
1-800-223-0425

ADDITIONAL INFORMATION
If you have questions about this Fact Sheet, or need additional infonnation about the Westlake Landfill Superfund Site, please contact:

Debbie Kring
Community Involvement Coordinator
Office of Public Affairs

U.S. EPA-Region 7
901 North 51h Street
Kansas City, Kansas 66101

(913) 551-7725 or toll-free
1-800-223-0425
kring.debbie@epa. gov

2

Post

2011-12-28 – Supplemental Feasibility Study Radiological-Impacted Material Excavation Alternatives Analysis West Lake Landfill Operable Unit-1

Supplemental Feasibility Study
Radiological-Impacted Material Excavation Alternatives Analysis West Lake Landfill Operable Unit-1
Prepared for
The United States Environmental Protection Agency Region VII

Prepared on behalf of
The West Lake Landfill OU-1 Respondents

Prepared by
Engineering Management Support, Inc. 7220 West Jefferson Avenue, Suite 406 Lakewood, Colorado 80235

In association with
Feezor Engineering, Inc. 406 E. Walnut Street Chatham, Illinois 62629
and
Auxier & Associates, Inc. 9821 Cogdill Road, Suite 1 Knoxville, Tennessee 37932
September 30, 2011 Revised December 16, 2011 Final December 28, 2011

Table of Contents
1 Introduction …………………………………………………………………………………………………………….. 1

1.1
Scope of the SFS ………………………………………………………………………………. 1

1.2
SFS Approach ………………………………………………………………………………….. 3

1.3
Report Organization …………………………………………………………………………..

2 Site Conditions………………………………………………………………………………………………………… 7

2.1
Site Location and Surrounding Area……………………………………………………. 7

2.1.1
Historic Landfill Operations and Disposal Areas ………………………………….. 8

2.1.2
Superfund Operable Units………………………………………………………………….. 9

2.1.3
Current Site Uses……………………………………………………………………………..

2.1.4
Site Zoning, Use Restrictions, and Easements…………………………………….. 11

2.1.5
Surrounding Land Uses……………………………………………………………………. 12

2.1.6
Missouri River Floodplain ……………………………………………………………….. 12

2.2
Nature and Extent of Radionuclide and Chemical Occurrences in OU-1… 14
2.2.1
Source of the Radionuclides………………………………………………………………

2.2.2
General Locations and Lateral Extent of RIM Occurrences in Areas 1 and 2 ……………………………………………………………………………………………………… 16
2.2.3
Vertical Extent of RIM Occurrences in Areas 1 and 2 …………………………. 17

2.2.4
Estimated Volume of RIM……………………………………………………………….. 17

2.2.5
Radiological Occurrences on the Buffer Zone and Crossroad Property….. 19
2.2.6
Radiological Characterization of the RIM …………………………………………..

2.2.7
Radionuclide Decay and Ingrowth…………………………………………………….. 22

2.2.8
Principal Threat Wastes …………………………………………………………………… 22

2.2.9
Occurrences of Non-Radiological Chemical Constituents in Soil/Waste… 22
2.2.9.1.1 Trace Metal Occurrences in Soil……………………………………………………….. 23

2.2.9.1.2 Total Petroleum Hydrocarbons in Soil……………………………………………….. 23

2.2.9.1.3 Volatile Organic Compounds in Soil …………………………………………………. 23

2.2.9.1.4 Semi-Volatile Organic Compounds in Soil…………………………………………. 24

2.2.9.1.5 Pesticides and Polychlorinated Biphenyls in Soil………………………………… 24

2.2.9.1.6 Potential for Occurrences of Hazardous Wastes…………………………………..

2.2.9.1.7 Asbestos Containing Materials in Soil/Waste……………………………………… 25

2.3
Radionuclide Occurrences in Air………………………………………………………. 26

2.4
Groundwater Conditions ………………………………………………………………….. 26

2.4.1
Geology…………………………………………………………………………………………. 27

2.4.2
Hydrogeology…………………………………………………………………………………. 27

2.4.3
Occurrences of Radionuclides in Groundwater …………………………………… 29

2.4.4
Occurrences of Chemical Constituents in Groundwater………………………..

2.5
Baseline Risk Assessment………………………………………………………………… 31

2.5.1
Human Health Risk Assessment ……………………………………………………….. 31

2.5.2
Ecological Risk Assessment …………………………………………………………….. 33

3 Potential ARARs and Remedial action Objectives………………………………………………………

3.1
Potential Applicable or Relevant and Appropriate Requirements ………….. 35

3.1.1
Potential Chemical-Specific ARARs …………………………………………………. 35

i

Table of Contents (continued)

3.1.1.1
Health and Environmental Protection Standards for Uranium and Thorium Mill Tailings…………………………………………………………………………………… 35
3.1.1.2
Standards for Cleanup of Contaminated Land – 40 CFR 192.12(a)……….. 36

3.1.1.3
Radon Emissions Standards – 40 CFR 192.02(b)………………………………… 38

3.1.1.4
Groundwater Protection Standards – 40 CFR 192 Subparts A and B……… 39

3.1.1.5
Other Potential Chemical-Specific ARARs ………………………………………… 40

3.1.1.6
National Emissions Standards for Hazardous Air Pollutants…………………. 40

3.1.1.7
Missouri Radiation Regulations for Protection Against Ionizing Radiation ……………………………………………………………………………………………………… 40
3.1.1.8
Missouri Maximum Contaminant Levels……………………………………………. 41

3.1.2 Potential Location-Specific ARARs ………………………………………………….. 41

3.1.2.1 Floodplain Management…………………………………………………………………… 42

3.1.2.2 Missouri Solid Waste Management Regulations – Site Selection………….. 43

3.1.2.3 Missouri Solid Waste Regulations – Airport Safety…………………………….. 44

3.1.2.4 Missouri Solid Waste Management Regulations – Floodplains …………….. 45

3.1.2.5 Missouri Solid Waste Management Regulations – Wetlands………………… 45

3.1.2.6 Missouri Solid Waste Management Regulations – Seismic Impact Zones. 45
3.1.2.7 Missouri Solid Waste Management Regulations – Unstable Areas………… 46

3.1.2.8 Missouri Solid Waste Management Regulations – Plans ……………………… 46

3.1.2.9
Missouri Solid Waste Management Regulations – Base of Landfill ………. 47

3.1.2.10
FAA Guidance ……………………………………………………………………………….. 47

3.1.2.11
Airport Negative Easement and Restrictive Covenants………………………… 49

3.1.3 Potential Action-Specific ARARs……………………………………………………… 51

3.1.3.1
Health and Environmental Protection Standards for Uranium and Thorium Mill Tailings…………………………………………………………………………………… 52
3.1.3.2
Missouri Solid Waste Management Regulations …………………………………. 52

3.1.4 RCRA Subtitle C Regulations…………………………………………………………… 54

3.2
Additional Requirements Associated with Off-site Disposal ………………… 55

3.2.1 CERCLA Off-site Rule……………………………………………………………………. 55

3.2.2 Off-site Transportation Requirements………………………………………………… 56

3.2.3 Waste Acceptance Criteria for Off-site Disposal…………………………………. 57

3.2.3.1
U.S. Ecology, Grandview, Idaho ………………………………………………………. 57

3.2.3.2
Clean Harbors, Deer Trail, Colorado …………………………………………………. 58

3.2.3.3
EnergySolutions, Clive Utah…………………………………………………………….. 59

3.2.3.4
Other Off-site Disposal Facilities………………………………………………………. 60

3.3
Remedial Action Objectives …………………………………………………………….. 60

3.4
Cleanup Levels……………………………………………………………………………….. 61

4 Technology Screening ……………………………………………………………………………………………. 66

4.1
Technologies Evaluated in the FS Report…………………………………………… 67

4.2
Additional Technology Evaluations/Revisit Previously Eliminated Technologies ………………………………………………………………………………….. 69
4.3
Descriptions of Additional Technologies……………………………………………. 71

4.3.1 Monitoring……………………………………………………………………………………… 71

ii

Table of Contents (continued)

4.3.1.1 Long-term Performance Monitoring………………………………………………….. 71

4.3.1.2 Short-term Monitoring During Construction ………………………………………. 71

4.3.2 Containment …………………………………………………………………………………… 72

4.3.2.1 Capping and Covers ………………………………………………………………………… 73

4.3.2.2 Land Encapsulation…………………………………………………………………………. 73

4.3.2.2.1 On-Site: New Cell…………………………………………………………………………… 73

4.3.2.2.2 Off-Site Licensed Facility………………………………………………………………… 73

4.3.2.3
Cryogenic Barriers ………………………………………………………………………….. 76

4.3.2.4
Vertical Barriers ……………………………………………………………………………… 77

4.3.2.4.1 Slurry Wall…………………………………………………………………………………….. 77

4.3.2.4.2 Grout Curtain …………………………………………………………………………………. 77

4.3.2.4.3 Sheet Pile Cutoff Wall …………………………………………………………………….. 77

4.3.3 Physical/Chemical Treatment …………………………………………………………… 78

4.3.3.1 Solidification/Stabilization……………………………………………………………….. 78

4.3.3.2 Chemical Separation ……………………………………………………………………….. 79

4.3.3.3 Physical Separation …………………………………………………………………………. 80

4.3.3.3.1 Dry Soil Separation…………………………………………………………………………. 80

4.3.3.3.2 Soil Washing ………………………………………………………………………………….. 82

4.3.3.3.3 Flotation ………………………………………………………………………………………… 82

4.3.3.4
Vitrification……………………………………………………………………………………. 83

4.3.4 Biological Treatment……………………………………………………………………….. 84

4.3.5 Removal ………………………………………………………………………………………… 84

4.3.5.1
Excavation……………………………………………………………………………………… 85

4.3.5.2
Storm Water Management ……………………………………………………………….. 85

4.3.5.3
Bird Nuisance Mitigation…………………………………………………………………. 86

4.3.6 Transportation ………………………………………………………………………………… 87

4.3.6.1
Hauling of Wastes and Construction Materials – On-site, Off-road and Off-site, On-road Trucks………………………………………………………………………… 87
4.3.6.2
Hauling of Waste Material -Rail ………………………………………………………. 88

4.4
Implementability Screening of Remediation Technologies and Process Options ………………………………………………………………………………………….. 89
4.4.1 Dry Soil Separation…………………………………………………………………………. 89

4.4.2 Temporary Structure to Enclose an Excavation…………………………………… 91

4.5
Evaluation of Remediation Technologies and Process Options …………….. 92

5 Remedial Action Alternatives………………………………………………………………………………….. 93

5.1
Remedial Alternatives Evaluated in FS ……………………………………………… 93

5.2
ROD-Selected Remedy ……………………………………………………………………. 94

5.2.1 Engineering Components of the ROD-Selected Remedy ……………………… 97

5.2.1.1
Regrading of the Landfill Surface for the ROD-Selected Remedy…………. 98

5.2.1.2
Removal of Radiologically-Impacted Soil from the Buffer Zone/Crossroad Property……………………………………………………………………………………….. 102
5.2.1.3
Engineered Landfill Cover for the ROD-Selected Remedy…………………. 103

5.2.1.4
Rock Armoring/Flood Protection of the Toe of the Landfill ……………….. 104

iii

Table of Contents (continued)

5.2.1.5 Stormwater Management/Surface Water Runoff Control……………………. 105

5.2.1.6 Landfill Gas Monitoring and Control ………………………………………………. 107

5.2.1.7 Management of Subsurface Liquids During Construction …………………… 108

5.2.1.8 Regulated Materials Management During Construction……………………… 108

5.2.1.9 Long-Term Operations and Maintenance for the ROD-Selected Remedy109
5.2.1.10 Environmental Monitoring for the ROD-Selected Remedy…………………. 110

5.2.2 Non-Engineered Components of the ROD-Selected Remedy ……………… 111

5.2.2.1
Institutional Controls Included in the ROD-Selected Remedy…………….. 111

5.2.2.2
Five Year Reviews ………………………………………………………………………… 112

5.3
Additional “Complete Rad Removal” Remedial Action Alternatives…… 113
5.3.1 RIM Occurrences, Extents and Volumes………………………………………….. 113

5.3.2 RIM Excavation and Associated Activities ………………………………………. 114

5.3.2.1 RIM Excavation Procedure and Sequencing……………………………………… 115

5.3.2.2 Material Handling …………………………………………………………………………. 116

5.3.2.3 Material Stockpiling………………………………………………………………………. 117

5.3.2.4
Radiological Surveys during RIM Excavation ………………………………….. 119

5.3.2.5
Application of Daily Soil Cover ……………………………………………………… 120

5.3.2.6
Removal of Radiologically-Impacted Soil from the Buffer Zone/Crossroad Property……………………………………………………………………………………….. 121
5.3.2.7
Management of Subsurface Liquids During RIM Excavation ……………… 121

5.3.2.8
Regulated Materials Management During RIM Excavation………………… 121

5.3.2.9
Radiological Surveys after RIM Excavation……………………………………… 122

5.3.2.10
Stormwater and Landfill Gas Monitoring and Control……………………….. 122

5.3.2.11
Baseline Monitoring for “Complete Rad Removal” Alternatives…………. 123

5.3.2.12
Long-Term Operations, Maintenance and Monitoring and Non-Engineered Components………………………………………………………………………………….. 123
5.3.3 “Complete Rad Removal” with Off-site Disposal Alternative …………….. 124

5.3.4 “Complete Rad Removal” with On-site Disposal Alternative……………… 128

5.3.4.1 Siting of On-site Cell …………………………………………………………………….. 129

5.3.4.2
General Configuration of On-site Cell……………………………………………… 131

5.3.4.3
Liner Construction – On-site Cell……………………………………………………. 133

5.3.4.4
Filling of On-site Cell with RIM……………………………………………………… 135

5.3.4.5
Cover Construction – On-site Cell…………………………………………………… 136

5.3.4.6
OM&M Components – On-site Disposal in Engineered Cell Alternative 137

5.3.5 Closure Construction -Remaining Solid Waste Areas of Areas 1 and 2.. 138
6 Detailed Analysis of Alternatives …………………………………………………………………………… 139

6.1
Description of Evaluation Criteria …………………………………………………… 140

6.1.1 Overall Protection of Human Health and the Environment …………………. 140

6.1.2 Compliance with ARARs……………………………………………………………….. 140

6.1.3 Long-Term Effectiveness and Permanence ………………………………………. 141

6.1.4 Reduction of Toxicity, Mobility or Volume through Treatment ………….. 142

6.1.5 Short-Term Effectiveness……………………………………………………………….. 143

6.1.6 Implementability …………………………………………………………………………… 144

iv

Table of Contents (continued)

6.1.7 Cost …………………………………………………………………………………………….. 145

6.1.7.1 Capital and Operation, Maintenance, and Monitoring Costs……………….. 146

6.1.7.2 Contingency Costs ………………………………………………………………………… 148

6.1.7.3 Present Worth and Non-discounted Constant Dollar Costs …………………. 151

6.1.8
State Acceptance …………………………………………………………………………… 151

6.1.9
Community Acceptance …………………………………………………………………. 152

Detailed Analysis of Alternatives ……………………………………………………. 152

6.2.1
Regrading and Enhanced Capping (ROD-Selected Remedy)………………. 152

6.2.1.1 Overall Protection of Human Health and the Environment …………………. 154

6.2.1.2 Compliance with ARARs……………………………………………………………….. 155

6.2.1.2.1
Missouri Solid Waste Rules for Sanitary Landfills…………………………….. 155

6.2.1.2.2
Environmental Protection Standards for Uranium and Thorium Mill Tailings………………………………………………………………………………………… 156
6.2.1.2.3
National Emissions Standards for Hazardous Air Pollutants (NESHAPs)158
6.2.1.2.4
Clean Water Act……………………………………………………………………………. 158

6.2.1.2.5
Safe Drinking Water Act………………………………………………………………… 158

6.2.1.2.6
Missouri Radiation Regulations for Protection Against Ionizing Radiation ……………………………………………………………………………………………………. 158
6.2.1.2.7
Missouri Well Construction Code……………………………………………………. 158

6.2.1.2.8
Missouri Storm Water Regulations………………………………………………….. 159

6.2.1.3 Long-Term Effectiveness and Permanence ………………………………………. 159

6.2.1.3.1 Magnitude of Residual Risks ………………………………………………………….. 159

6.2.1.3.2 Adequacy and Reliability of Controls………………………………………………. 160

6.2.1.4 Reduction of Toxicity, Mobility or Volume through Treatment ………….. 161

6.2.1.5 Short-Term Effectiveness……………………………………………………………….. 162

6.2.1.5.1 Protectiveness of the Community During Remedial Actions ………………. 162

6.2.1.5.2 Protectiveness of Workers During Remedial Actions ………………………… 163

6.2.1.5.3 Environmental Impacts ………………………………………………………………….. 163

6.2.1.5.4 Ability to Monitor Effectiveness……………………………………………………… 164

6.2.1.5.5 Time Until Remedial Action Objectives are Achieved……………………….. 164

6.2.1.6 Implementability …………………………………………………………………………… 164

6.2.1.6.1 Ability to Construct and Operate the Technology ……………………………… 165

6.2.1.6.2 Reliability of the Technology………………………………………………………….. 165

6.2.1.6.3 Ease of Undertaking Additional Remedial Actions, if Necessary ………… 166

6.2.1.6.4
Ability to Monitor Effectiveness of Remedy…………………………………….. 167

6.2.1.6.5
Ability to Obtain Approvals from Other Agencies …………………………….. 167

6.2.1.6.6
Coordination with Other Agencies…………………………………………………… 167

6.2.1.6.7
Availability of Off-site Treatment, Storage and Disposal Services and Capacity……………………………………………………………………………………….. 169
6.2.1.6.8
Availability of Necessary Equipment and Specialists ………………………… 169

6.2.1.6.9
Availability of Prospective Technologies …………………………………………. 169

6.2.1.7 Cost …………………………………………………………………………………………….. 169

6.2.2 “Complete Rad Removal” with Off-site Disposal Alternative …………….. 170

6.2.2.1 Overall Protection of Human Health and the Environment …………………. 172

v

Table of Contents (continued)

6.2.2.2 Compliance with ARARs……………………………………………………………….. 173

6.2.2.2.1 CERCLA Off-site Rule………………………………………………………………….. 173

6.2.2.2.2 Off-site Transportation Requirements………………………………………………. 173

6.2.2.2.3 Waste Acceptance Criteria (WAC) for Off-site Disposal……………………. 174

6.2.2.2.4 Missouri Solid Waste Rules for Sanitary Landfills…………………………….. 174

6.2.2.2.5
Clean Water Act……………………………………………………………………………. 175

6.2.2.2.6
Safe Drinking Water Act………………………………………………………………… 175

6.2.2.2.7
Missouri Radiation Regulations for Protection Against Ionizing Radiation ……………………………………………………………………………………………………. 175
6.2.2.2.8
Missouri Well Construction Code……………………………………………………. 175

6.2.2.2.9
Missouri Storm Water Regulations………………………………………………….. 175

6.2.2.3 Long-Term Effectiveness and Permanence ………………………………………. 176

6.2.2.3.1 Magnitude of residual risk ……………………………………………………………… 176

6.2.2.3.2 Adequacy and reliability of controls………………………………………………… 177

6.2.2.4 Reduction of Toxicity, Mobility or Volume through Treatment ………….. 178

6.2.2.5 Short-Term Effectiveness……………………………………………………………….. 180

6.2.2.5.1 Protection of the Community During Remedial Actions…………………….. 180

6.2.2.5.2 Protection of Workers During Remedial Actions ………………………………. 182

6.2.2.5.3 Environmental Impacts ………………………………………………………………….. 183

6.2.2.5.4 Ability to Monitor Effectiveness……………………………………………………… 183

6.2.2.5.5 Time Until Remedial Action Objectives are Achieved……………………….. 184

6.2.2.6 Implementability …………………………………………………………………………… 185

6.2.2.6.1 Ability to Construct and Operate the Technology ……………………………… 186

6.2.2.6.2 Reliability of the Technology………………………………………………………….. 188

6.2.2.6.3 Ease of Undertaking Additional Remedial Actions, if Necessary ………… 189

6.2.2.6.4 Ability to Monitor Effectiveness of Remedy…………………………………….. 190

6.2.2.6.5 Ability to Obtain Approvals from Other Agencies …………………………….. 190

6.2.2.6.6 Coordination with Other Agencies…………………………………………………… 192

6.2.2.6.7 Availability of Off-site Treatment, Storage and Disposal Services and … 194
6.2.2.6.8 Availability of Necessary Equipment and Specialists ………………………… 195

6.2.2.6.9 Availability of Prospective Technologies …………………………………………. 195

6.2.2.7 Cost …………………………………………………………………………………………….. 196

6.2.3 “Complete Rad Removal” with On-site Disposal Alternative……………… 197

6.2.3.1 Overall Protection of Human Health and the Environment …………………. 199

6.2.3.2 Compliance with ARARs……………………………………………………………….. 199

6.2.3.3 Long-Term Effectiveness and Permanence ………………………………………. 200

6.2.3.3.1 Magnitude of residual risk ……………………………………………………………… 200

6.2.3.3.2 Adequacy and reliability of controls………………………………………………… 201

6.2.3.4 Reduction of Toxicity, Mobility or Volume through Treatment ………….. 202

6.2.3.5 Short-Term Effectiveness……………………………………………………………….. 203

6.2.3.5.1 Protection of the Community During Remedial Actions…………………….. 203

6.2.3.5.2 Protection of Workers During Remedial Actions ………………………………. 205

6.2.3.5.3 Environmental Impacts ………………………………………………………………….. 205

6.2.3.5.4 Ability to Monitor Effectiveness……………………………………………………… 206

vi

Table of Contents (continued)
6.2.3.5.5
Time Until Remedial Action Objectives are Achieved……………………….. 206

6.2.3.6 Implementability …………………………………………………………………………… 207

6.2.3.6.1
Ability to Construct and Operate the Technology ……………………………… 209

6.2.3.6.2
Reliability of the Technology………………………………………………………….. 212

6.2.3.6.3
Ease of Undertaking Additional Remedial Actions, if Necessary ………… 213

6.2.3.6.4
Ability to Monitor Effectiveness of Remedy…………………………………….. 214

6.2.3.6.5
Ability to Obtain Approvals from Other Agencies …………………………….. 214

6.2.3.6.6
Coordination with Other Agencies…………………………………………………… 216

6.2.3.6.7
Availability of Off-site Treatment, Storage and Disposal Services and Capacity……………………………………………………………………………………….. 218
6.2.3.6.8
Availability of Necessary Equipment and Specialists ………………………… 218

6.2.3.6.9
Availability of Prospective Technologies …………………………………………. 219

6.2.3.7 Cost …………………………………………………………………………………………….. 219

7 Comparative Analysis of Alternatives…………………………………………………………………….. 221

7.1
Threshold Criteria …………………………………………………………………………. 221

7.1.1 Overall Protection of Human Health and the Environment …………………. 221

7.1.2 Compliance with ARARs……………………………………………………………….. 222

7.1.2.1 Chemical-Specific ARARs. ……………………………………………………………. 222

7.1.2.2 Location-Specific ARARs. …………………………………………………………….. 223

7.1.2.3 Action-Specific ARARs…………………………………………………………………. 224

7.1.2.4 Remedy Selection Absent ARAR Compliance………………………………….. 225

7.2
Primary Balancing Criteria …………………………………………………………….. 226

7.2.1 Long-Term Effectiveness and Permanence ………………………………………. 226

7.2.2 Reduction of Toxicity, Mobility or Volume through Treatment ………….. 228

7.2.3 Short-Term Effectiveness……………………………………………………………….. 229

7.2.3.1 Protection of the Community………………………………………………………….. 229

7.2.3.2 Worker Protection …………………………………………………………………………. 231

7.2.3.3 Environmental Impacts ………………………………………………………………….. 231

7.2.3.4 Time to Achieve Remedial Action Objectives (RAOs)………………………. 232

7.2.4 Implementability …………………………………………………………………………… 233

7.2.5 Cost …………………………………………………………………………………………….. 239

7.3
Modifying Criteria ………………………………………………………………………… 242

8 References…………………………………………………………………………………………………………… 243

vii

Table of Contents (continued)
Appendices
A. Existing Institutional Controls, City of St. Louis -Negative Easement and Restrictive Covenant on West Lake Landfill, and FAA ROD, MOU, and Advisories
B. Identification and Quantification of the Volume of RIM above Cleanup Levels
C. Off-site Disposal Facilities – Waste Acceptance Criteria
D. Evaluation of Trench Shoring Applicability
E. Evaluation of Regrading Options for ROD-Selected Remedy
F. Required Cover Thicknesses Calculations
G. Conceptual Environmental Monitoring Plan
H. Evaluation of Potential Risks Associated with the Proposed Remedial Alternatives
I. Estimated Greenhouse Gas Emissions Associated with the Alternatives
J. Estimated Project Schedules for the Remedial Alternatives
K. Estimated Costs for the Remedial Alternatives
List of Tables
1.
Summary Comparison of Results from Proximately Located RI and NRC Soil Borings

2.
Summary of Thorium-230 Decay and Radium-226 In-Growth Over Time

3.
Summary Comparison of Soil Sample Results to RCRA Toxicity Characteristic Regulatory Levels

4.
Summary of Calculated Risks for Current and Future Potential Receptors

5.
Preliminary Identification of Potential Chemical-Specific ARARs and TBC Criteria

6.
Preliminary Identification of Potential Location-Specific ARARs and TBC Criteria

7.
Preliminary Identification of Potential Action-Specific ARARs and TBC Criteria

8.
Comparison of USEI Waste Acceptance Criteria (WAC) to Projected OU-1 RIM Concentrations

9.
Summary of Estimated Costs

10.
Comparative Analysis of Alternatives

List of Figures
1.
General Location Map

2.
Site Area

3.
Site Features

4.
Site Topography

5.
Site and Adjacent Property Ownership

6.
Landfill and Adjacent Property Zoning

7.
Existing Environmental Easements and Land-Use Covenants

8.
Setback from Airport Runway

9.
Geologic Map

10.
Extent of Geomorphic Flood Plain

11.
Extent of Radiologically-Impacted Materials

viii

Table of Contents (continued)
List of Figures (cont.)
12.
Comparison of Areal Extent of RIM from NRC, RI and SFS Studies

13.
Locations of NRC and RI Soil Borings

14.
Buffer Zone/Crossroad Property Sampling Locations

15.
Ingrowth of Radium Over Time

16.
Groundwater and Surface Water Dissolved Radium Results

17.
Groundwater and Surface Water Total Radium Results

18.
Groundwater and Surface Water Dissolved Arsenic Results

19.
Groundwater and Surface Water Total Arsenic Results

20.
Groundwater and Surface Water Dissolved Lead Results

21.
Groundwater and Surface Water Total Lead Results

22.
Groundwater and Surface Water Benzene Results

23.
Groundwater and Surface Water Total Chlorobenzene Results

24.
Technology Implementability Screening of Remediation Technologies and Process Options

25.
Locations of Potential Off-Site Disposal Facilities and Rail Points

26.
Waste Volume/Size Reduction and Separation Equipment

27.
Evaluation of Remediation Technologies and Process Options

28.
Conceptual Cross-section of the ROD Remedy

29.
Potential Material Stockpile Areas

30.
On-Site Treatment of Contact Stormwater and Leachate

31.
RIM Excavation Sequencing

32.
Conceptual Alignment of On-Site Rail Spur

33.
Proposed Location New On-Site Cell

34.
Profile of On-site Disposal Cell Liner and Cover

35.
Final Closed Topography Areas 1 and 2

36.
Area 2 Waste Excavation Intersection with OU-2 Boundaries

37.
Profile of Area 2 Waste Excavation Intersection with OU-2 Boundaries

ix

List of Acronyms

AC Advisory Circular
ACM asbestos containing materials
AEC Atomic Energy Commission
amsl above mean sea level
AOA air operations area
AOC Administrative Order on Consent
ARAR Applicable or Relevant and Appropriate Requirements
ARRA American Recovery and Reinvestment Act
ASTM American Society of Testing Materials
bcy bank cubic yard
BDAT Best Demonstrated Available Technology
bgs below ground surface
Bi Bismuth
BMP Best Management Practices
BRA Baseline Risk Assessment
C&D Construction and demolition
CERCLA Comprehensive Environmental Recovery, Compensation, and Liability Act
cf cubic feet
CFR Code of Federal Regulations
cm centimeter
CM Construction Manager
cm/sec centimeter per second
COCs Chemicals of concern
COD Chemical Oxygen Demand
CoPC constituent of potential concern
CQA construction quality assurance
CSR Code of State Regulations
cy, or cu yd cubic yard
DAF Dilution-Attenuation Factor
DCGL Derived concentration guideline
DOD Department of Defense
DOE United States Department of Energy
DOT United States Department of Transportation
DQO data quality objective
dtrs daughters
ea each
ecy embankment cubic yards
EDTA ethylenediaminetetraacetic acid
EMSI Engineering Management Support, Inc.
ENR CCI Engineering News Record Construction Cost Index
EPA United States Environmental Protection Agency
EPC Exposure point concentration
ERA Ecological Risk Assessment
x

List of Acronyms (continued)

FAA Federal Aviation Administration FEMA Federal Emergency Management Agency FIRM Flood Insurance Rate Map FRTR Federal Remediation Technologies Roundtable FS Feasibility Study FUSRAP Formerly Utilized Sites Remedial Action Program ft feet gm, or g gram GM Geiger Mueller gpm gallons per minute GRA General Response Action HAZMAT hazardous materials HDPE high density polyethylene HHRA Human Health Risk Assessment HI Hazard Index HP health physics hr hour IC Institutional Control IP industrial packaging IRIS Integrated Risk Information System K Potassium kg kilogram L liter LAACC Large Area Activated Charcoal Canisters lbs pounds lcy loose cubic yard LDPE low density polyethylene LDR Land disposal restrictions LEL lower explosive limit lf linear foot LFMR Landfill mining and reclamation Li Lithium LLRW Low level radioactive waste LoMR Letter of Map Revision LPGAC Liquid Phase Granular Activated Carbon LSA low specific activity MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MCA Multi-channel analyzer MCL Maximum contaminant level MCLG Maximum contaminant level goal MDA Minimum detectable activity MDOT Missouri Department of Transportation MDNR Missouri Department of Natural Resources MECA Missouri Environmental Covenants Act
xi

List of Acronyms (continued)

m meter MeV Million electron volts mg milligram mm millimeter mo ` month MOU Memorandum of Understanding mrem millirem msf thousand square feet MSD Metropolitan St. Louis Sewer District MSWLF Municipal Solid Waste Landfill MTG Migration to Groundwater Na Sodium NARM Naturally-Occurring and Accelerator-Produced Radioactive Material NCP National Oil and Hazardous Substance Pollution Contingency Plan NEPA National Environmental Policy Act NESHAPs National Emissions Standards for Hazardous Air Pollutants NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System NRC Nuclear Regulatory Commission NORM Naturally occurring radioactive material NPL National Priorities List O Oxygen O&M operation and maintenance OM&M operation, maintenance, and monitoring OMB Office of Management and Budget OSHA Occupational Safety and Health Administration OSR Off-site Rule OSTRI Office of Superfund Technology Research and Innovation OSWER Office of Solid Waste and Emergency Response OU Operable Unit Pa Protactinium PAH Poly-nuclear aromatic hydrocarbon Pb Lead PCB Poly-chlorinated biphenyl pCi pico Curie PFLT Paint filter liquids test Po Polonium POTW Publicly-Owned Treatment Works PPE personal protective equipment ppm Parts per million PRG Preliminary Remediation Goal PUF Poly-urethane foam R Roentgen RD Remedial design
xii

List of Acronyms (continued)

RA Remedial action
Ra Radium
RACM Regulated asbestos-containing material
RAECOM Radiation Attenuation Effectiveness and Cover Optimization with Moisture Effects computer program
RAO Remedial Action Objective
RCRA Resource Conservation and Recovery Act
RD Remedial Design
RDWP Remedial Design Work Plan
rem roentgen equivalent in man
RESRAD RESRAD – CHEM: A computer code for chemical risk assessment
RI Remedial Investigation
RIM Radiologically Impacted Material
RMC Radiation Management Corporation
RML radioactive material license
ROD Record of Decision
RSMo Revised Statutes of Missouri
SAP Sampling and Analysis Plan
sec, or s second
sf or sq ft square feet
SFS Supplemental Feasibility Study
Si Silocon
SLAPS St. Louis Airport Site
SLDS St. Louis Downtown Site
STLAA St. Louis Airport Authority
SOW Statement of Work
SVOC Semi-Volatile Organic Compound
SWMP Solid Waste Management Program
SWPP Stormwater Pollution Prevention Plan
t ton
TBC To Be Considered
TCLP Toxicity Characteristic Leaching Procedure
TENORM Technologically Enhanced Naturally Occurring Radioactive Materials
Th Thorium
TS Transfer Station
TSDF Treatment, storage, and disposal facility
TSS Total Dissolved Solids
U Uranium
ug microgram
UMTRCA Uranium Mill Tailings Radiation Control Act
uR microRoentgen
U.S.C. United States Code USACOE United States Army Corps of Engineers USCS Unified Soil Classification System
xiii

List of Acronyms (continued)
USDA United States Department of Agriculture USEI US Ecology Idaho UTS Universal treatment standards VOCs Volatile Organic Compounds VCA Verification of current acceptability WAC Waste Acceptance Criteria WL Working Level yr Year
xiv

1 INTRODUCTION
As a result of internal deliberations by the United States Environmental Protection Agency (EPA) and its further consideration of certain comments provided by interested community members, EPA determined that a Supplemental Feasibility Study (SFS) is warranted. This SFS will be added to the Administrative Record for this Site.
1.1 Scope of the SFS
This SFS has been performed to provide additional evaluation of a select group of potential remedial alternatives for Operable Unit 1 (OU-1) at the West Lake Landfill Site. EPA determined that additional work was necessary to accomplish the objectives of the RI/FS for OU.
1. Specifically, EPA requested the OU-1 Respondents to perform an SFS consisting of an engineering and cost analysis of the ROD-selected remedy, and two remedial alternatives that would remove all material containing radionuclides at levels greater than those that would allow for unrestricted use (relative to the presence of radionuclides) of the radiologically-contaminated areas (Areas 1 and 2 and the Buffer Zone/Crossroad properties) in OU-1; referred to by EPA as “complete rad removal”.
The ROD-selected containment remedy for OU-1 would protect human health and the environment by providing source control and institutional controls for the landfilled waste materials. A description of and reasons for selection of this remedy are presented in EPA’s Record of Decision (ROD) for OU-1 (EPA, 2008a). The source control and institutional control methods prevent human receptors from contacting the waste material. The source control method mitigates contaminant migration to air and restricts infiltration of precipitation into the landfill, which contributes to protection of groundwater quality. The description and basis for the selected remedy was documented in the ROD. The components of the ROD-selected remedy include the following:
1.
Install landfill cover meeting the Missouri closure and post-closure care requirements for sanitary landfills, including enhancements consistent with the standards for uranium mill tailing sites, i.e., armoring layer and radon barrier;

2.
Consolidation of radiologically contaminated surface soil from the Buffer Zone/Crossroad Property to the containment area;.

3.
Apply groundwater monitoring and protection standards consistent with requirements for uranium mill tailing sites and sanitary landfills;.

4.
Surface water runoff control;

5.
Gas monitoring and control including radon and decomposition gas as necessary;

6.
Institutional controls to prevent land and resource uses that are inconsistent with a closed sanitary landfill site containing long-lived redionuclides; and

7.
Long-term surveillance and maintenance of the remedy.

Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 1
Performance standards for each of the remedy components are specified in the ROD. As a result of subsequent discussions between EPA Region 7 and EPA’s Office of Superfund Remediation and Technology Innovation (OSRTI), the following additional performance standards were identified for the ROD-selected remedy:

The proposed cap should meet UMTRCA guidance for a 1,000-year design period
including an additional thickness to prevent radiation emissions.


Air monitoring stations for radioactive materials should be installed at both on-site and off-site locations.


Groundwater monitoring should be implemented at the waste management unit boundary and also at off-site locations. The groundwater monitoring program needs to be designed so that it can be determined whether contaminants from the landfill have migrated across the waste management unit boundary in concentrations that exceed drinking water Maximum Contaminant Levels. The groundwater monitoring program needs to measure for both contaminants that have historically been detected in concentrations above MCLs (e.g., benzene, chlorobenzene, dissolved lead, total lead, dissolved arsenic, total arsenic, dissolved radium and total radium) and broader indicators of contamination (e.g., redox potential, alkalinity, carbonates, pH and sulfates/sulfides).


Flood control measures at the site should meet or exceed design standards for a 500-year storm event under the assumption that the existing levee system is breached.

This SFS analysis incorporates those additional performance standards and refines the description and evaluation of the containment remedy that was selected in the ROD.
In a January 11, 2010, letter (EPA, 2010a) and Statement of Work (SOW) (EPA, 2010b) requesting that the Respondents perform this SFS, EPA identified the two “complete rad removal” alternatives that EPA directed be developed and evaluated in addition to the ROD-selected remedy:
1.
Excavation of radioactive materials with off-site commercial disposal of the excavated materials (referred to as “complete rad removal” with off-site disposal alternative in this SFS); and

2.
Excavation of radioactive materials with on-site disposal of the excavated materials in an on-site engineered disposal cell with a liner and cap if a suitable location outside the geomorphic flood plain can be identified (referred to as “complete rad removal” with on-site disposal alternative in this SFS).

EPA indicated (EPA, 2010a) that “complete rad removal” was defined to mean attainment of risk-based radiological cleanup levels specified in OSWER Directives 9200.4-25 and 9200.4-18. Although these new alternatives have been termed “complete rad removal,” it must be
Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 2
recognized that implementation of either of these alternatives would not result in complete removal of all radionuclides from the landfill, but instead would remove radionuclides from Areas 1 and 2 to the degree feasible such that additional engineering and institutional controls would not be required based on the radiological content of these areas. Because these areas would still contain solid wastes after removal of the radiologically-impacted materials, regrading, capping and establishment of institutional controls related to the presence of solid wastes would still be required.
As described in the SOW (EPA, 2010b), EPA required the two “complete rad removal” alternatives to be evaluated along with the ROD-selected remedy. The two “complete rad removal” alternatives along with the ROD-selected remedy were evaluated using the threshold and primary balancing criteria set forth in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR § 300.430 (EPA, 2009a). These criteria include the following:

Threshold Criteria: -Overall Protection of Human Health and the Environment; -Compliance with applicable or relevant and appropriate requirements of other

regulations (ARARs).


Primary Balancing Criteria:
-Long-term Effectiveness and Permanence;
-Reduction of Toxicity, Mobility, or Volume through Treatment;
-Short-term Effectiveness;
-Implementability; and
-Cost.

Additional descriptions of these criteria are presented in Section 6 of this SFS.
The NCP also requires remedial alternatives to be evaluated in terms of Modifying Criteria which include State and community acceptance. State and community acceptance will be evaluated by EPA as part of any decision process that may be undertaken by EPA after completion of the SFS and are not considered in this document.
1.2 SFS Approach
This SFS has been developed pursuant to a January 11, 2010, letter from EPA to the OU-1 Respondents (EPA, 2010a), an EPA-developed Statement of Work (SOW) (EPA SOW, 2010b) attached to the January 11 letter, and the EPA-approved Work Plan for the Supplemental Feasibility Study (SFS Work Plan) (EMSI, 2010a).
The engineering and cost analyses of the “complete rad removal” alternatives and the ROD-selected remedy performed for this SFS are based primarily on existing information provided in the Remedial Investigation (RI) (EMSI, 2000), Baseline Risk Assessment (BRA) (Auxier, 2000), Feasibility Study (FS) (EMSI, 2006), and the ROD for OU-1. These analyses also consider the
Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 3
results of a supplemental evaluation prepared by EPA subsequent to the ROD (TetraTech, 2009). Additionally, information was obtained from representatives of the United States Army Corps of Engineers (USACE), the United States Department of Energy (DOE), and various vendors of equipment, materials and services as necessary to develop and evaluate the potential effectiveness, implementability and cost of the “complete rad removal” alternatives. Additional field investigations or laboratory testing were not included in the scope of this effort and were not performed.
This report has been prepared to address the requirements of the SOW, EPA-approved Work Plan, and the NCP, in accordance with EPA’s Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (EPA, 1988a) and other EPA FS-related guidance documents (e.g., EPA, 1991a; EPA, 2000). This SFS:

provides a summary discussion of site conditions and other information presented in the RI for OU-1 (EMSI, 2000);


addresses findings in United States Nuclear Regulatory Commission (NRC) reports that evaluated the radiological disposal areas at the West Lake Landfill site;


provides additional characterization of the dimensions of radiologically impacted materials in the two radiological disposal areas;


summarizes the characterization of potential site risks presented in the BRA for OU-1 (Auxier, 2000);


provides further information and evaluation pertaining to a negative easement on the property held by the City of St. Louis, and its potential impacts on remedy implementation for OU-1;


provides additional information about environmental monitoring during remedy implementation and long-term maintenance and operations;


evaluates potential treatment technologies for the radiologically impacted materials; and


evaluates potential ARARs and remedial technologies, and descriptions of the remedial alternatives previously presented and evaluated in the site FS (EMSI, 2006).

Where necessary for the evaluation of the “complete rad removal” alternatives, or as otherwise
appropriate for completion of the SFS, brief summaries or tabulations of the results of prior site
evaluations are provided; however, the prior reports should be reviewed or consulted for
additional details and specific information relative to those evaluations.
Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 4
1.3 Report Organization
This report is organized as follows:
Section 1: Introduction – Presents information regarding the scope and approach used to complete the SFS.
Section 2: Site Conditions – Summarizes information regarding site conditions as they relate to the alternatives evaluated in the SFS. Detailed information about site conditions was presented in the RI report for OU-1 (EMSI, 2000) and a summary discussion of site conditions related to the development and evaluation of remedial alternatives was presented in the FS report for OU-1 (EMSI, 2006). This section provides a description of occurrences of radionuclides in soil/waste, air and groundwater at the site. In addition, this section describes the nature, general locations, and overall lateral and vertical extent of Radiologically-Impacted Materials (RIM). This section also provides a summary of the occurrences of chemical constituents in soil/waste and groundwater. Lastly, this section provides a brief summary of the results of the Baseline Risk Assessment (Auxier, 2000).
Section 3: ARARs – Summarizes information regarding potential ARARs and remedial action objectives (RAOs) as they relate to the additional alternatives evaluated in the SFS. Additional, detailed information about potential ARARs and RAOs was presented in the FS report for OU-1 (EMSI, 2006).
Section 4: Remedial Technologies – Summarizes information regarding additional remedial technologies that may be potentially applicable to the “Complete Rad Removal” alternatives evaluated in the SFS. Additional, detailed information about potentially applicable technologies was presented in the FS report for OU-1 (EMSI, 2006).
Section 5: Remedial Alternatives – Provides descriptions of the ROD-selected remedy and the “complete rad removal” alternatives that are the subject of the detailed evaluations presented in Sections 6 and 7. Descriptions of other remedial alternatives previously developed and evaluated for OU-1 were presented in the FS report for OU-1 (EMSI, 2006) and are not repeated in this SFS report.
Section 6: Detailed Analysis of Alternatives – Presents a detailed analysis of the ROD-selected remedy and the “complete rad removal” alternatives relative to the threshold and balancing criteria defined by the NCP.
Section 7: Comparative Analysis of Alternatives – Presents a summary comparison of the ROD-selected remedy and the two “complete rad removal” alternatives in terms of the threshold and balancing criteria defined by the NCP.
Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 5
Section 8: References – Provides a list of references cited in this report.
This SFS also includes the following appendices:
Appendix A: Existing Institutional Controls affecting the Site, the City of St. Louis Negative Easement and Restrictive Covenant on West Lake Landfill, and FAA ROD, MOU and Advisory Circulars
Appendix B: Identification and Quantification of the Volume of RIM above
Cleanup Levels Appendix C: Off-site Disposal Facilities – Waste Acceptance Criteria Appendix D: Evaluation of Potential Application of Shoring Technology Appendix E: Evaluation of Area 1 and 2 Regrading Options Appendix F: Required Cover Thicknesses Calculations Appendix G: Conceptual Environmental Monitoring Plan Appendix H: Evaluation of Potential Risks Associated with the Proposed
Remedial Alternatives
Appendix I: Estimated Greenhouse Gas Emissions Associated with the

Alternatives Appendix J: Estimated Project Schedules for the Remedial Alternatives Appendix K: Estimated Costs for the Remedial Alternatives.
Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 6
2 SITE CONDITIONS
The purpose of this Section 2 is to provide information necessary to support the evaluation of remedial technologies and alternatives presented in Sections 4, 6, and 7. Therefore, this section summarizes certain site-specific information from the existing Administrative Record in order to present a summary of the site conditions at the West Lake Landfill.
This Section 2 is divided into five subsections:

Section 2.1 provides information regarding the West Lake landfill and the surrounding area including discussions and/or descriptions of historical landfill operations and disposal areas; Superfund Operable Units (OUs) on the site; current site uses; site zoning, use restrictions and easements; surrounding land uses; and potential impacts or consequences from the landfill’s proximity to the Missouri River floodplain.


The nature and extent of radionuclide occurrences in OU-1 are discussed in Section 2.2 including the source of the radionuclides; general locations and lateral extent of radiologically-impacted materials (RIM); vertical extent of RIM occurrences in Areas 1 and 2; estimated volume of RIM; radiological occurrences on the Buffer Zone and Crossroad Property; radiological characterization of the RIM in Areas 1 and 2; projected radionuclide decay and ingrowth of the RIM; and the evaluation of principal threat wastes. Section 2.2 also includes information regarding the occurrence of non-radiological hazardous substances (trace metals, petroleum hydrocarbons, volatile and semi-volatile organics, pesticides and PCBs) in soil samples collected from Areas 1 and 2 as well as discussions regarding the potential for occurrences of hazardous wastes and asbestos-containing materials in the landfill matrix.


The presence of radionuclides in air is discussed in Section 2.3.


Brief descriptions of the site geology and hydrogeology and the nature and extent of radionuclide and chemical occurrences in groundwater near Areas 1 and 2 are provided in Section 2.4.


Finally, Section 2.5 includes summaries and conclusions from the baseline human health and screening-level ecological risk assessments.

2.1 Site Location and Surrounding Area
The West Lake Landfill is located within the western portion of the St. Louis metropolitan area on the east side of the Missouri River floodplain approximately two miles east of the river (Figure 1). The landfill is located approximately one mile north of the intersection of Interstate 70 and Interstate 270 within the city limits of the City of Bridgeton in northwestern St. Louis County.
Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 7
The site is bounded to the east and northeast by St. Charles Rock Road (State Highway 115) (Figure 2). Commercial and industrial properties bound the site immediately to the north, across St. Charles Rock Road to the north and east, and to the south. The site is bounded on the west by Old St. Charles Rock Road (vacated) and the Earth City Industrial Park (Earth City) stormwater/flood control pond. The Earth City commercial and industrial complex continues to the west and north of the stormwater/flood control pond and extends from the site to the Missouri River. Earth City is separated from the river by an engineered levee system owned and maintained by the Earth City Flood Control District.
2.1.1 Historic Landfill Operations and Disposal Areas
The West Lake Landfill is an approximately 200-acre parcel containing multiple areas of past operations. The site was used agriculturally until a limestone quarrying and crushing operation began in 1939. The quarrying operation continued until 1988 and resulted in two quarry pits, the North Quarry Pit and the South Quarry Pit (Figure 3), which were excavated to maximum depth of 240 feet below ground surface (bgs) (Herst & Associates, 2005).
The West Lake Landfill is the site of several areas where solid wastes have been disposed. Beginning in the early 1950s or perhaps the later 1940s, portions of the quarried areas and adjacent areas were used for landfilling municipal refuse, industrial solid wastes, and construction/demolition debris. These operations predated state laws and regulations governing such operations. Landfill activities conducted after 1974 within the quarry areas were subject to permits obtained from the Missouri Department of Natural Resources (MDNR). In 1974 landfilling began in the portion of the site described as the North Quarry Pit. Landfilling continued in this area until 1985 when the landfill underwent expansion to the southwest into the area described as the South Quarry Pit (Herst & Associates, 2005). In August 2005, the Bridgeton Sanitary Landfill stopped receiving waste pursuant to an agreement with the City of St. Louis to reduce the potential for birds to interfere with airport operations. The Bridgeton Sanitary Landfill is inactive and closure and post-closure activities are proceeding under MDNR supervision.
In addition to the Bridgeton Sanitary Landfill north and south quarry pits currently in the process of closure/post-closure, the West Lake Landfill property contains four other areas where solid wastes were disposed (Figure 3):

Area 1 where solid wastes and radiologically-impacted materials were disposed;


Area 2 where solid wastes and radiologically-impacted materials were disposed;


A closed demolition landfill; and


An inactive sanitary landfill.

Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 8
2.1.2 Superfund Operable Units
Superfund-program remedial action at the site is divided into two operable units (OUs). OU-1 is comprised of the solid wastes and RIM disposed in Areas 1 and 2 and portions of an adjacent property, formerly described as the Ford Property and now called the Buffer Zone/Crossroad Property. OU-2 consists of the other landfill areas that are not impacted by radionuclides and includes the inactive sanitary landfill located adjacent to Area 2, the closed demolition landfill, and the Bridgeton Sanitary Landfill located in the North and South Quarry Pits. The closed demolition landfill and the Bridgeton Sanitary Landfill, while designated as part of OU-2, are regulated by the MDNR pursuant to State of Missouri solid waste regulations and are not being actively addressed by the Superfund program. To the extent that the presence of or activities associated with these OU-2 areas potentially impact OU-1 and the remedial alternatives considered by this SFS, those impacts are discussed in the appropriate SFS section.
OU-1 Area 1 is situated on the northern and western slopes of a topographic high within the overall West Lake landfill property. Ground surface elevation in Area 1 varies from 490 feet above mean sea level (AMSL) on the south to 452 feet AMSL at the roadway near the transfer station entrance (Figure 4). OU-1 Area 2 is situated between a topographic high of landfilled materials on the south and east, and the Buffer Zone/Crossroad Property on the west. The highest topographic level in Area 2 is about 500 feet AMSL on the southwest side of Area 2, sloping to approximately 470 feet AMSL near the top of the landfill berm (Figure 4). The upper surface of the berm along the western edge of Area 2 is located approximately 20 to 30 feet above the adjacent Buffer Zone/Crossroad Property and approximately 30 to 40 feet higher than the water surface in the flood control channel located to the south-west of Area 2. A berm on the northern portions of Area 2 controls runoff to the adjacent properties.
No contemporaneous reports, drawings or other records from the former site operators exist regarding the construction of the disposal units or the overall types and amounts of wastes that were disposed in the Area 1 and Area 2 landfills during their operation. Based on the RI investigations, it appears that these areas were filled using an “area-fill” approach whereby waste materials consisting primarily of munic

Post

2012-07-09 – Gravatt, Dan – PRP Questions on Scope of Work

West Lake Landfill: PRP Questions on Scope of work Dan Gravatt to: Paul Rosasco 07/09/2012 08:45AM Cc: victoria warren
Paul,
Have you had a chance to formulate or assemble questions from the West Lake OU 1 PRPs on scoping the additional work to respond to the NRRB comments? Once we get your questions, we will forward them to the NRRB to get their input and ensure we conduct the SSFS in a way that addresses their comments.
Thanks, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063
Principles and integrity are expensive, but they are among the very few things worth having.

07111 3.. 0
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Superfund
OL.t 01

Post

2012-01-05 – Earth City Levee District Chair – John Basilico – Past Flooding Events and Valuation of Properties

{In Archive} Fw: My Conversation with John Basilico -Earth City Levee
District Chair
Dan Gravatt to: Cecilia Tapia 01/05/2012 11:12 AM
Cc: DeAndre Singletary Archive: This message is being viewed in an archive.
Cecilia, here is the information from the Earth City Levee District responding to Karl’s questions. Note that none of the flood events mentioned below and on the website breached or overtopped the levee.
Sincerely, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063
Principles and integrity are expensive , but they are among the very few things worth having. -Forwarded by Dan Gravatt/R7/USEPAIUS on 01/05/2012 11:10 AM-
From: Debbie Kring/R7/USEPAIUS To: Dan Gravatt/R7/USEPAIUS@EPA, Audrey Asher/R7/USEPAIUS@EPA Date: 01105/2012 10:48 AM Subject: My Conversation with John Basilica -Earth City Levee District Chair
Per your request to get information about the Earth City Levee System & past flooding events, I have the following to report:
1) The valuation of properties within the Levee system (as of 2007) showed a market value of $1,235,000,000. This included structures and roadways. For purposes of looking at a comparable valuation for 2011 , John stated the value should be deduced by 20%, making the 2011 valuation in the range of $950,000,000-$1,100,000,000.
2) The Levee system was constructed in the summer of 1972. John indicated he is aware of 2-3 flooding events, but most importantly noted the event of 1993. He also stated that the following website would be a great resource for additional questions like this: www.earthcityld.com
I also checked EPA’s Responsiveness Summary, where it states on page 6 (top) that four (4) major floods have occurred since the levy was built.
Debbie
Debra L. Kring Public Affairs Specialist/Local Elected Officials Liaison EPA-Region 7, Office of Public Affairs 901 North 5th Street Kansas City, Kansas 66101
(913) 551-7725 or toll-free@ 1-800-223-0425
l’l 40447607 b ~
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Superfund

Post

2012-01-09 – Bridgeton December 2011 Monthly Progress Report

Page 1 of2
FW: Bridgeton December 2011 Monthly Progress Report iana Howarth
Dan Gravatt
01/09/2012 11:32 AM
Cc:
“Victoria Wan-en”, “Paul Rosasco”, “Randal Bodnar”, “Shawn Muenks”, “Dave Vasbinder”,
“Jessica Merrigan”
Hide Details
From: “Diana Howarth” Sort List…

To: Dan Gravatt/R7/USEPA/US@EPA

Cc: “Victoria Warren” , “Paul Rosasco”

, “Randal Bodnar” , “Shawn

Muenks” , “Dave Vasbinder”

, “Jessica Merrigan”

1 Attachment
• ” . “ffi
•.’to.]
01-09-12 Bridgeton – December 2011 Monthly Progress Report.pdf
I apologize for the wording in the original email, it is an email form that I use and I didn’t edit it properly.
This is the Bridgeton Monthly Progress Report for Decernber 2011
Please let me know if you have any questions or comments.

Thanks, Diana
From: Diana Howarth [mailto:dhowarth(g)herstassociates.coml Sent: Monday, January 09, 2012 11:30 AM To: Dan Gravatt (Gravatt.Dan@epamail.epa.gov) Cc: Victoria Warren (vwarren@hrtc.net); Paul.Rosasco (paulrosasco@emsidenver.com); Randal Bodnar
(rbodnar@cecinc.com); Shawn Muenks (shawn.muenks@drir.mo.gov); Dave Vasbinder
(dvasbinder@republicservices.com); Jessica Merrigan (JMerrigan@LathropGage.com)
Subject: Bridgeton December 2011 Monthly Progress Report:
40359761
Norfolk Monthly Report Final email distribution . Eric Ballenger. i lli il l
II I i IIII 11 I I I IIIII

Superfund file://C:\Documents and Settings\DGRAVATT\Local Settings\Temp\notes87944B\~webl 1… 1/9/2012
Page 2 of 2
Attached is the MONTH YEAR Norfolk Monthly Progress Report.
Please contact Ward Herst of our office ifyou have any questions or comments regarding this report.

Attached is the December 2011 Bridgeton Monthly Progress Report.
Please contact Ward Herst of our office if you have any questions or comments regarding this report.

Thank you,
Diana Howarth
Herst & Associates, Inc.

(636)939-9111
Information contained in this communication is CONFIDENTIAL and intended for the use ofthe addressee only. Ifyou havereceived this communication in error, please notify the sender, [f you are not the intended recipient of this communication, be advised that disclosure, copying, use or dissemination ofthe contents of this communication is prohibited.
file://C:\Documents and Settings\DGRAVATT\Local Settings\Temp\notes87944B\~webl 1… 1/9/2012
Global Presence Personal A ttention HERST & ASSOCIATES, INC.
Mr. Dan Gravatt
U. S. Environmental Protection Agency Region VH 901N5″‘Sl Kansas City, Kansas 66115
.January 9, 2012
Dear Mr. Gravatt:
Monthly Progress Report – December 2011,
West Lake (Bridgeton) LandfUl, Operable Unit 2 Remedial Design

On behalf of Respondent Bridgeton Landfill, LLC (Bridgeton), successor in interest to Laidlaw Waste Systems (Bridgeton), Inc., Herst & Associates, Inc. lias prepared the foUowing progress report in accordance wili Section XID, Paragraph 39 ofthe Administrative Order on Consent (Consent Order), EPA Docket No. vn-94-F-0025 as modified by the Third Amendment to Settlement Agreement and Order oh Consent dated October 16, 2008, and as indicated in Section VI ofthe Statement of Work .Remedial Design. The progress repoit describes activities conducted in December.
I. ACTIONS TAKEN TO COMPLY WITH THE CONSENT ORDER
A monthly progress report was submitted on December 8,2011.
U. WORK PLANNED DURING JANUARY AND FEBRUARY 2012
Responses to MDNR and EPA comments on the Remedial Design Work Plan are anticipated to be prepared upon receipt offinal comments.
IU. MATERIAL PROBLEMS ENCOUNTERED OR ANTICIPATED MATERIAL DELAYS
No material problems or delays were encountered in December and none are anticipated for Januaiy or February 2012.
4631 North Sl. Peters Parkway Telephone (636) 939-9111 St. Charles, IWissouri 63304 Fax (636) 939-9757
Mr. Dan Gravatt Januarv9.2Q12 ] Page 2
If you have any questioiis or comments, please contact Ms. Victoria Warren, the Respondent’s designated Project Coordinator, or the undersignai.
Sincerely,
HERST & ASSOCIATES, INC.
Ward E. Herst, CPHG, CEM Managing Partner
cc: Jessica Merrigan – Lathrop & Gage, LLP Victoria Warren – Republic Services, Inc. David Vasbinder – Bridgeton Landfill, LLC. Shawn Muenks – Missouri Department of Natural Resources Paul Rosasco – Engineering Management Support, Inc. Randal Bodnar – Civil & Environmental Consultants, Inc.

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2012-01-09 – Cecilia Tapia does not think community interviews should be conducted during this stage of the Superfund process

Just Spoke with Cecilia about Westlake Landfill-and Ramona Debbie Kring to: Hattie Thomas, Dan Gravatt Cc: Rich Hood, Cecilia Tapia 01/09/2012 02:21 PM
From: To: Deb~ie Kring/R7/USEPA/US Hattie Thomas/R7/USEPAIUS@EPA, Dan Gravatt/R7/USEPA/US@EPA
Cc: Rich Hood/R7/USEPA/US@EPA, Cecilia Tapia/R7/USEPA/US@EPA

Hattie & Dan:
I just spoke to Cecilia as she walked by enroute to the MDNR Call in the RA Conference Room at 2:00
p.m. She is fully supportive of CPA’s role at Westlake and also does not think “community interviews” should be conducted during this phase of the Superfund process. She does not have an opinion about Ramona’s role at the site, but indicated that MDNR (Ramona) should not be lobbying on anyone’s behalf, i.e., the city, community members, et al and that is why she asked for her to be removed from the site to begin with.
I briefly explained what our call will entail (at 3:00 p.m. today) with Brandon of MDNR. She is supportive!
As a historical reference, Ramona and her management made several comments to my updated Community Involvement Plan (CIP)P (done last summer). Some of the comments I chose to incorporate (because they made the plan better). Some of the comments were not applicable, and a few of them were not even implementable. Ramona offered her assistance to EPA Hqtrs. when it was working on the Community Engagement Initiative, so feels like she should be in charge of every aspect of community activities that involve EPA. Please note ………… MDNR comments to the CIP were suggestions only.
When we (EPA officials & MDNR) toured Westlake Landfill on October 4, 2011, we discussed the CIP and possible next steps for community interaction. The dialogue went well, Ramona was not present for that tour.
They are insistent that community interviews be conducted, RIGHT NOW! I don’t disagree that we need the community’s view of past and current EPA activities and their affects on the community-at-large. However, I believe that once the SFS activities get finalized and we move to the next phase of community meeting·s and additional activity, that would be the appropriate time to conduct the community interviews. I plan to perform these interviews in the spring of 2012.
Stay tuned ……………. l’ll keep you apprised of next steps. If you need any more information regarding this history of this site or EPA’s interactions with MDNR, please don’t hesitate to ask. Dan and I have a conference call coming up within the hour.
Debbie
Debra L. Kring Public Affairs Specialist/Local Elected Officials Liaison EPA-Region 7, Office of Public Affairs 901 North 5th Street Kansas City, Kansas 66101
(913) 551-7725 or toll-free@ 1-800-223-0425
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IIIII~ 11111111111111111111111111111111111111111 Superfund
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2012-01-09 – EPA discussion of next steps for community outreach per MDNR request

{In Archive} EPA Call with MDNR Re: Westlake Landfill-Next Steps for
Community Outreach
Debbie Kring to: Hattie Thomas, Dan Gravatt 01/09/2012 04:30PM
Cc: Rich Hood, Cecilia Tapia, DeAndre Singletary
Archive: This message is being viewed in an archive.
Dan & I called MDNR (Branch Chief Brandon Doster) at his request to discuss next steps for community outreach activities at the Westlake Landfill Superfund Site in Bridgeton, MO.
MDNR would like EPA to conduct community interviews in support of the most recent Community Involvement Plan update (fall of 2011 ). They would also like these interviews to be done subsequent to the upcoming public meeting EPA will hold to release the Supplemental Feasibility Study (SFS) to guage interest community-wide. While EPA concurs with the need to get current perspectives from community members about the progress of Westlake Landfill, doing interviews during this particular phase of the Superfund process is poor timing. EPA has made it clear that the SFS process is NOT a public comment process or period. Conducting interviews at the same time considerations are being made about the SFS gives the community mixed messages about what EPA is asking.
We conveyed to MDNR that EPA would prefer to conduct these interviews in the spring of 2012, not only to alleviate confusion within the public domain, but also because EPA’s EJ program would like to begin conducting Healthy Homes assessments near Westlake Landfill in the spring as well. I believe those two activities positively parallel each other and give the community a more clarified direction .
MDNR asked Dan and I if they could conduct their own community interviews prior to the SFS being released to the public. I specifically asked Brandon, what they would do with the comments received, since we are NOT in a public comment period. He appeared to understand and thanked Dan and I for our time.
If you need additional information about this call or any other facet of the Westlake Landfill site, please call Dan or I.
Debbie
Debra L. Kring Public Affairs Specialist/Local Elected Officials Liaison EPA-Region 7, Office of Public Affairs 901 North 5th Street Kansas City, Kansas 66101
(913) 551-7725 or toll-free@ 1-800-223-0425
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40450119
11111111111111111111111111111111111111111111111111
Superfund
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2012-01-09 – EPA EJ program would like to begin conducting Healthy Homes assessmens near West Lake Landfill

{In Archive} EPA Call with MDNR Re: Westlake Landfill-Next Steps for
Community Outreach
Debbie Kring to: Hattie Thomas, Dan Gravatt 01/09/2012 04:30PM
Cc: Rich Hood, Cecilia Tapia, DeAndre Singletary
Archive: This message is being viewed in an archive.
Dan & I called MDNR (Branch Chief Brandon Doster) at his request to discuss next steps for community outreach activities at the Westlake Landfill Superfund Site in Bridgeton, MO.
MDNR would like EPA to conduct community interviews in support of the most recent Community Involvement Plan update (fall of 2011 ). They would also like these interviews to be done subsequent to the upcoming public meeting EPA will hold to release the Supplemental Feasibility Study (SFS) to guage interest community-wide. While EPA concurs with the need to get current perspectives from community members about the progress of Westlake Landfill, doing interviews during this particular phase of the Superfund process is poor timing. EPA has made it clear that the SFS process is NOT a public comment process or period. Conducting interviews at the same time considerations are being made about the SFS gives the community mixed messages about what EPA is asking.
We conveyed to MDNR that EPA would prefer to conduct these interviews in the spring of 2012, not only to alleviate confusion within the public domain, but also because EPA’s EJ program would like to begin conducting Healthy Homes assessments near Westlake Landfill in the spring as well. I believe those two activities positively parallel each other and give the community a more clarified direction .
MDNR asked Dan and I if they could conduct their own community interviews prior to the SFS being released to the public. I specifically asked Brandon, what they would do with the comments received, since we are NOT in a public comment period. He appeared to understand and thanked Dan and I for our time.
If you need additional information about this call or any other facet of the Westlake Landfill site, please call Dan or I.
Debbie
Debra L. Kring Public Affairs Specialist/Local Elected Officials Liaison EPA-Region 7, Office of Public Affairs 901 North 5th Street Kansas City, Kansas 66101
(913) 551-7725 or toll-free@ 1-800-223-0425
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2012-07-06 – MDNR requests special consideration given to fugitive dust control

Page 1 of2
_” -~~ ;ai ) ~~~~:’s~:~:dwater Monitoring SAP and Responses to Comments
\p;;”_::J ~~~ul Rosasco’
07/06/2012 12:00 PM
Cc:
“Doster, Branden”, Dan Gravatt
Hide Details
From: “Muenks, Shawn”

To: “‘Paul Rosasco”‘ Cc: “Doster, Branden” , Dan Gravatt/R7/USEPAIUS@EPA
Paul,
MDNR asks that special consideration be given to fugitive dust control during vegetation clearing and any other vehicular traffic on OU-1 during this sampling event given the extremely dry conditions we are experiencing this summer. Please respond with your plans to address this issue.
Thanks,
Shawn Muenks, P.E.
071 ~ IMIWiiDiiiiYil~lil
Missouri Department of Natural Resources Superfund
P.O. Box 176, Jefferson City, MO 65102-0176 Ph: (573)751-3107 OI.A 0 I email: shawn.muenks@dnr.mo.gov
From: Paul Rosasco [mailto:paulrosasco@emsidenver.com]
Sent: Friday, June 29, 2012 3:13PM
To: ‘Dan Gravatt’; Muenks, Shawn
Cc: ‘Merrigan, Jessie’; ‘Neitzel, Charlotte’; ‘Warren, Victoria’; ‘Whitby, Kathleen’; ‘Golian, Steven’; ‘Ward Herst’;
Bob Jelinek; ‘L FmGERALD’
Subject: Final Groundwater Monitoring SAP and Responses to Comments

Dan and Shawn,

Enclosed please find a revised Sampling and Analysis Plan (SAP) for the Additional Groundwater Monitoring
activities. The document has been amended to address EPA and MDNR comments received on June 18, 2012.
am also sending each of you a hard copy of the plan via regular mail.

Also enclosed are responses to the EPA and MDNR comments.

file:/1/C:/Users/DGRAVATT/AppData/Local/Temp/notes6D6848/~web4719.htm 5/6/2014
Page 2 of2
Once we receive your approval of the SAP, we will schedule the additional groundwater monitoring activity.
Please contact me if you have any questions or would like to discuss the additional groundwater monitoring or any other aspect of the project.
file:///C:!Users/DGRA VATT/AppData/Local!Temp/notes6D6848/~web4719.htm 5/6/2014

Post

2012-07-25 – Comments on START contract support for radiation survey at West Lake

Re: Fw: westlake rad survey work CharlesA Hooper to: Dan Gravatt 07/25/2012 11 :43 AM
I think we could do it, but it won’t be as fast as START can do. They run the system at each of the Wichita sites and I haven’t put the system together in over a year. I’d just as soon let them do it if that’s not a problem.
40458937
3; 9
Chuck Hooper
Radiation Safety Officer
I1\\111\1\11\\Ill\1\\1\11\1~II\1\1\\IIIII1\\11\\1 Superfund
US EPA, Region 7 901 North 5th Street Kansas City, Kansas 66101 OlfVI
(913) 551-7271 office Hooper.CharlesA@epa.gov
Dan Gravatt Randy, I talked with DeAndre about the possibilit. .. 07/25/2012 09:44:42 AM
From: Dan Gravatt/R7/USEPAIUS To: Randy Schademann/SUPR/R7/USEPA/US@EPA Cc: CharlesA Hooper/R7/USEPAIUS@EPA Date: 07/25/2012 09:44AM Subject: Fw: westlake rad survey work
Randy, I talked with DeAndre about the possibility of a Start task order and he will look into it with Bob Jackson. As far as ERT personnel, who would you suggest that could assist with the RAT if we can’t or don’t get contractor support? Also, what kinds of problems does the system experience in the field? I’m pretty sawy with electronic systems and might be able to keep it running, if I knew what I was up against. If you have any operating manuals or SOPs for running the RAT I’d like to see them.
Thanks, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063
Principles and integrity are expensive, but they are among the very few things worth having. –Forwarded by Dan Gravatt/R7/USEPA/US on 07/25/2012 09:40AM—.
From: Mary Peterson/SUPR/R7/USEPAIUS To: Dan Gravatt/R7/USEPAIUS@EPA Cc: DeAndre Singletary/SUPR/R7/USEPAIUS@EPA, CharlesA Hooper/R7/USEPAIUS@EPA, Randy
Schademann/SUPR/R7/USEPA/US@EPA, Don Lininger/R7/USEPA/US@EPA, Kenneth
Buchholz/R7/USEPAIUS@EPA, Scott Hayes/R7/USEPAIUS@EPA Date: 07/24/201211 :17 AM Subject: Re: westlake rad survey work
Dan,
I spoke with Randy. It sounds like he is available the week of Sept 10 for this project. Randy will call you today or very soon to coordinate plans. Evidently we do not have sufficient expertise to run the RAT system entirely independently and will likely need either contract support from START or support from ERT. I will let you and Randy work out the details.
Mary P. Peterson, Chief Planning and Preparedness South Section Emergency Response and Removal South Branch Superfund Division
(913) 551-7882 Mobile: (816) 398-3945
Dan Gravatt Mary, I am looking at a tentative field mob date o .. . 07/23/2012 08:03:45 AM
Mary Peterson Dan, Do you have a schedule for when this work .. . 05/15/2012 01 :43:01 PM


ENGINEERING MANAGEMENT SUPPORT INC.
7720 West Jefferson Avenue. Suite 406 Telephone (303) 940..3426 lakewood, CO 80235 Telecopier (303) 940..3422
April 24, 2009
U.S. Environmental Protection Agency
Region VII
90 I N. 51h Street

40330551
Kansas City, KS 661 0 I

ATTENTION: Mr. Dan Wall
SUBJECT: Prevention of Soil Erosion during Vegetation Clearing prior to Surveying West Lake Landfill OU-1 Remedial Design
Dear Mr. Wall,
On behalf of Cotter Corporation (N.S.L.), Bridgeton Landfill, LLC, Rock Road Industries, Inc., and the United Sates Department of Energy (the “Respondents”), Engineering Management Support Inc. (EMSI) is submitting this letter to supplement the Vegetation Sampling Plan (Woodford and Associates, 2009) to further describe the actions to be taken to prevent erosion during the vegetation clearing effort. Vegetation clearing is necessary prior to conducting the ground and aerial surveys of Areas·! and 2. The ground-truthed aerial survey will be used to produce a current topographic base map needed lor use in development of the design of the landfill cover component ofthe remedy.
Vegetation clearing will conducted over the area shown on the attached Figure I .Clearing Area Plan. The vegetation clearing procedure will involve an operator using a FECON Bull Hog® wood shredder attached to a skid steer loader (e.g., Bobcat®) to cut and shred brush, shrubs, small trees (6 to 8 inches in diameter or less), and stumps. The wood shredder attachment will be set to cut the vegetation to a level slightly above the ground surface, leaving the roots such that the existing vegetative cover remains intact and erosion is prevented. Photographs of a Bobcat® skid steer and the Bull Hog® wood shredder are provided in Figure 2. The skid steer will have the versatility to maneuver between the larger trees that will remain in place during the remedial design. Use of the small skid steer machine will minimize the number and depth of ruts that would result from use of a larger bulldozer or front-end loader machine, thus helping to minimize erosion.
The shredded bmsh, shrub, and tree mulch will be deposited in place, which will further assist with erosion control. To minimize the arnount of shredded vegetation that might become airborne during the clearing effort, settings on the wood shredder will be adjusted such that a coarse-sized mulch is deposited. Also, as mentioned in the Vegetation Sampling Results Summary report (Woodford and Associates, 2009), the
.•

Mr. Dan Wall
Prevention ofSoil Erosion during
Vegetation Clearing prior to Surveying
West Lake Landfill OU-1 Remedial Design
Page 2
slated for clearing has a very high moisture content and therefore will not readily become airborne.
To prevent transport ofany shredded material offsite, silt fences will be installed at the toe of the slopes of Areas I and 2. The toe of the slopes for each area arc shown on Figure I and an example ofsilt fence installation is provided on Figure 2. The silt fences will be inspected periodically during the vegetation clearing effort and will remain in.place until the remedy is implemented.
Ifyou have any questions or desire additional information regarding the vegetation clearing effort with respect to erosion control, please do not hesitate to contact me.

Attachments:
Figure I -Clearing Area Plan Figure 2-Vegetation Shredder and Silt Fence Installation Details
References:
Woodford and Associates, 2009, Vegetation Sampling Plan in Support of Health and Safety Plan for Vegetation Clearing and Grubbing, West Lake Landfill OU-1, Bridgeton, MO, March 9.
Woodford and Associates, 2009, Vegetation Sampling Results Summary in Support of Health and Safety Plan for Vegetation Clearing and Grubbing, West Lake Landfill OU-1, Bridgeton, MO, March JO.
Distribution:
Shawn Muenks-Missouri Dept ofNatural Resources Victoria Warren -Allied Waste Industries, Inc. Michael Hockley-Spencer Fane Britt & Browne Charlotte Neitzel -Holme Roberts & Owen William Spurgeon-U. S. Department of Energy Ward Herst-Herst & Associates, Inc. Dan Feezor-Feezor Engineering, Inc. Tim Woodford, T.A. Woodford and Associates, LLC

———-~—————————————————————.
SKID STEER LOADER (BOBCAT~ VEGETATION CLEARING USING BULLHOG•sHREDDER ATTACHED TO SKID STEER ~.,.,._.. ……..~—.—.-~-.·—-.. -..–·—·-.—–.–..-.–….. .-..—-.••wo –…·—-.. .·—-·… -· ….. BULL HOGID WOOD SHREDDER SILT FENCE INSTALLATION FIGURE2 VEGETATION SHREDDER AND SILT FENCE INSTALLATION DETAILS WEST LAKE L.ANOFILL OU-1 REMEDIAL DESIGN EMS I Engineering Management Support, Inc.

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2012-07-25 – Quality Assurance Project Plan for Surface Gamma Scans and Down-hole Gamma Scans West Lake Landfill OUl – Reviewed

%52g£ / UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
%• c**
REGION 7 901 NORTH 5TH STREET KANSAS CITY, KANSAS 66101
JUL 2 5 2012
MEMORANDUM
SUBJECT: Quality Assurance Project Plan for Surface Gamma Scans and Down-hole Gamma Scans West Lake Landfill OUl – Reviewed
FROM: Diane Harris^ WU&Kv^
Regional Quality Assurance Manager
ENSV/IO
u
40407109 °’
EPA Project Manager SupSSS^^ SUPR/MOKS 0 UO |
The review of the subject document prepared by EPA Superfund MOKS branch, dated July 2012, has
been completed according to “EPA Requirements for Quality Assurance Project Plans for
Environmental Data Operations, ” EPA QA/R-5 March 2001.
Because the document was unsigned, it was reviewed as a draft and the comments are outlined below.
Critical comments identify issues which need to be addressed before the document can be approved.

Critical Comments
1.
Signature Page. When the document is ready for final approval, it will need to be submitted with the appropriate signatures.

2.
§B1 Sampling Process Design, pages 6-7.

a.. The last sentence of page 6 states “the detector will be lowered to the bottom of each accessible well or to a maximum depth of 150 feet, whichever is greater.” If the bottom of the accessible monitoring well is less than 150 ft, how will the detector be lowered to 150 ft? See also §A6.1.
b^/How will it be determined the reading on the detector is stable?
2>y §B8 Instrument Calibration and Frequency, page 8. How will it be determined when calibrations are needed on-site?
Ay Figure 1 is a general map of the site layout. It does not include the locations of any monitoring wells. The map should include the locations of monitoring wells that are anticipated to be sampled.
, v, RECYCLED ^… vb0DuD%FIBER
General Comments
1 ./§A3 Distribution List, page 3. Will the QAPP be distributed to the OSC performing the “work? 2/’§Bl 1 Data Management, page 8. How long will the data be stored? 3y Attachment A could not be located. If you have any questions, please contact the lead reviewer, Jenn Boggess at x7185, or me at x7258. R7QAO Document Number: 2012240 ‘

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2012-07-26 – Earth City Board of Trustees – Community will be mad if 100% excavation not performed

\

Summarized Phone Conversation I had with John Basilica, Chair, Earth City Board of Trustees-Re: West Lake Landfill Debbie Kring to: Dan Gravatt, DeAndre Singletary, Audrey Asher 07/26/2012 02:02PM Cc· Rich Hood, Hattie Thomas, Cecilia Tapia, Robertw Jackson, Kristina
· Gonzales
The attached document serves as a phone record for a conversation that I had with John Basilica today, July 27, 2012. Please let me know if you have questions. For the record, this site is currently in lit.-hold.
~~~u
WestlakelandfiiiOverviewBoardofTrustees.docx
Debbie
Debra L. Kring Public Affairs Specialist/Local Elected Officials Liaison EPA-Region 7, Office of Public Affairs 901 North 5th Street Kansas City, Kansas 66101
(913) 551-7725 or toll-free@ 1-800-223-0425
v711 ltmniiiiill1 3
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Superfund
OL,f D/

Write-Up Re: Discussion with John Basilica,
Chairman, Earth City, MO Board of Trustees

West Lake Landfill
I spoke by phone today with Mr. John Basilica of Earth City, MO. He calls.me every 4-6 months to get an update on West Lake Landfill. Their next board meeting is August 22nd, so the update for this call was of key importance to him.
As background, John and the Earth City Board were extremely supportive of EPA’s initial remedy selection, primarily due to the concern about bird strikes at the St. Louis airport.
We talked for about 15 minutes about the status
of the landfill, and EPA’s current stance with
respect to the SFS. I outlined some of the
current and proposed actions (very generically)
as we are proposing to do in an updated Fact
Sheet.
..

In summary, John stated that he is on the ground in this community and the area in general and really hears what the constituents say. He stated that whatever EPA plans to do at the landfill, it should take the following into consideration, understanding that the two solutions are: full excavation of the landfill OR EPA’s preferred remedy, which includes capping, groundwater monitoring, and institutional controls:
Unless it is deemed that the appropriate action for the landfill is 100% +excavation (which would include the removal of every molecule of contaminated material), the public will be mad.
Unless it is deemed that EPA’s preferred remedy is going to be performed in the near future (sooner vs. later), the public’s patience is running out.

Post

2012-07-30 – Updates to West Lake Landfill Update

..

Fw: West Lake Landfill Bullets w/changes Rich Hood to: Dan Gravatt 07/30/2012 10:15 AM
Rich Hood Associate Regional Administrator For Media, Intergovernmental Relations Region 7
(o)
913-551-7906

(c)
913-339-8327

—–Forwarded by Rich Hood/R7/USEPA!US on 07/30/2012 10:14 AM—-.
From: Rich Hood/R7/USEPA!US To: LaTonya Sanders/R7/USEPAIUS@EPA Date: 07/26/2012 12:53 PM Subject: Fw: West Lake Landfill Bullets w/changes
LaTonya,
Recommend you share these bullets with the senator and the two congressmen. We would hope to issue the fact sheet next month before going to Bridgeton for discussion and updates.
Pleaese call if you have questions.
Rich Hood Associate Regional Administrator For Media, Intergovernmental Relations Region 7
(o)
913-551-7906

(c)
913-339-8327

—–Forwarded by Rich Hood/R7/USEPA!US on 07/26/2012 12:50 PM —-.
From: Debbie Kring/R7/USEPA!US To: Rich Hood/R7/USEPA!US@EPA Date: 07/26/2012 12:47 PM Subject: West Lake Landfill Bullets w/changes
FYI. ……… .

WestLakeLandfiiiBulletsJuly2012.docx
Debra L. Kring Public Affairs Specialist/Local Elected Officials Liaison EPA-Region 7, Office of Public Affairs 901 North 5th Street Kansas City, Kansas 66101
(913) 551-7725 or toll-free @ 7 1-800-223-0425
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Superfund
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West Lake Landfill Update-July 2012

Past actions include: signing the Record of Decision (ROD) in 2008. This decision included placing an engineered cover system over the radiologically-contaminated areas, long-term groundwater monitoring, and the adoption of institutional controls to restrict access. Action was conducted after holding numerous public meetings and comment periods.


After receiving numerous comments after the ROD was signed, EPA tasked the potentially.responsible parties (PRPs) to conduct a Supplemental Feasibility Study (SFS) to further evaluate: the ROD-selected remedy; and full.scale excavation of the landfill material.


The SFS was approved by EPA, released to the public in December 2011, and posted to EPA’s website.


The estimated costs defined in the SFS Report triggered a formal review by EPA’s National Remedy Review Board (NRRB).


The NRRB recommended that EPA Region 7: -Evaluate additional groundwater sampling to refresh the data; and

– Conduct a more detailed analysis of
potential treatment technologies for the
radiologically-contaminated landfill
material.


EPA Region 7 also decided to update the gamma scans ofthe OU-1 surface, and conduct vertical gamma scans of the site’s monitoring wells.


Timeline: (for EPA actiops) 1) Groundwater sampling -starting July 2012;

2) Gamma scan evaluation-starting August 2012;and
..

3) Additional studies-would be conducted, if and when warranted.
• EPA will host a public availability session near the end of2012 to provide data results and take questions about the next steps in the remedy-selection process.

Post

2012-07-31 – West Lake Landfill groundwater sampling prep

Page 1 of 3
w\ RE: West Lake Landfill groundwater samplingprep
ffe ‘ ‘S Pau’ Rosasco

WT to: ‘Muenks, Shawn’ 07/31/2012 10:29 PM Cc: Dan Gravatt, “‘Ward Herst'” Hide Details From: “Paul Rosasco” To: “‘Muenks, Shawn'”
Cc: Dan Gravatt/R7/USEPA/US@EPA, “‘Ward Herst'”
Shawn,
Sorry I was out visiting my father. The initial vegetation clearing has been completed. See you next week.
From: Muenks, Shawn fmailto:shawn.muenks@dnr.mo.aovl Sent: Wednesday, July 25, 2012 3:22 PM To: ‘Paul Rosasco’ Cc: ‘Dan Gravatt’; Ward Herst Subject: RE: West Lake Landfill groundwater sampling prep
Paul,
I am planning to be on site August 6 and 7. We can try to locate the well(s) we were interested in during that time (namely D-14). I do not plan to take any splits on the days that EPA will be taking them. I will save our splits for another time (probably sometime during the week of August 13). I am also interested in the schedule for the vegetation clearing. Has this been done already? Please provide dates for clearing activities.
Thanks,
Shawn Muenks, P.E.
iniiiiii ^
Missouri Department of Natural Resources SuperfundP.O. Box 176, Jefferson City, MO 65102-0176
Ph: (573)751-3107
DW!
email: shawn.muenks@dnr.mo.gov From: Paul Rosasco fmailto:paulrosasco@emsidenver.coml Sent: Tuesday, July 17, 2012 1:10 PM
file:///C:/Users/DGRAVATT/AppData/Local/Temp/n’otes6D6848/~web5425.htm 5/9/2014
Page 2 of 3
To: Muenks, Shawn
Cc: ‘Dan Gravatt’; Ward Herst
Subject: RE: West Lake Landfill groundwater sampling prep

Shawn,

With respect to dust suppression, we will use our best efforts to minimize dust generation such as adjustment of
the height of the deck of the brush hog to reduce dust generation to the extent possible while still achieving our
objective of clearing paths to and the immediate areas around the wells to be sampled or the immediate areas
of missing/abandoned wells that need to be further inspected. We only expect to spend a couple of days cutting
brush so overall we don’t anticipate generating a lot of dust.

With respect to damaged wells, the field crew went out and inspected the wells and determined that some of
the damage was located at relatively shallow depths. Consequently, they are out there this week digging out
around the damaged wells that they can access and repairing/replacing the upper portions of the pipe. For wells
that are damaged at deeper intervals, we will attempt to install the Waterra tubing in these wells. If we cannot
snake the tubing down through the wells, we will not obtain samples from the wells. We are not planning on
using a downhole camera to inspect the wells. Although a downhole camera could tell us the exact depth and
possible nature or cause of damage, repair of any damage below the first few feet below the ground surface
would require mobilizing and using a drill rig which is beyond the scope of this activity. Therefore, we did not
see any value in performing downhole television logging at this time.

We will attempt to locate, and if we can find it, obtain a sample from well D-14. I intend to do this when you are

out at the site. Right now, we anticipate starting groundwater sampling sometime the week of July 30th. The
first activity will be to collect a set of synoptitc water levels. They will then start with sampling of the wells
included in the landfill permit. To the extent possible, we will hold off beginning to sample the OU-1 wells until
Dan and you are on site. Dan Gravatt and I spoke this morning and we are planning on being there beginning on

Monday August 6th. It would be great if you could be there then as well. I would like to set up and obtain most
of the split samples during that early part of that week if possible. Dan has indicated that he would like to
obtain splits from D-3 and D-6 and approximately another 10-12 unspecfied wells. Besides D-14, please let me
know if there are any other wells you are interested in obtaining split samples so I can schedule them
accordingly.

Thanks, Paul

From: Muenks, Shawn I”mailto:shawn.muenks@dnr.mo.qov1
Sent: Tuesday, July 17, 2012 11:43 AM
To: Rosasco, Paul fpaulrosasco@emsidenver.com’)
Subject: West Lake Landfill groundwater sampling prep

Paul,

I have some questions regarding preparation for the upcoming groundwater sampling. I previously inquired
about dust suppression associated with clearing activities. I would also like to know if you were able to obtain a
down-hole camera for inspection of possible plugged wells.

Let me know when would be a good time for me to call and discuss these details, thanks.

Shawn Muenks, P.E.
Missouri Department of Natural Resources

P.O. Box 176, Jefferson City, MO 65102-0176
file:///C:/Users/DGRAVATT/AppData/Local/Ternp/notes6D6848/~web5425.htm
5/9/2014

Post

2012-08 – QAPP Surface Gamma Scans and Down-Hole Gamma Logs

Re: meter cable for Westlake G;;J Dan Gravatt to: CharlesA Hooper 10/25/2012 09:44AM
Chuck, I figured a paper towel sprayed with alconox solution for decon. Let me know how the marks stand up to that Here’s the final QAPP.
~~n
West Lake Gamma Scan QAPP.doc
Thanks, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 11201 Renner Boulevard, Lenexa, KS66219 Phone (913) 551-7324
Principles and integrity are expensive, but they are among the very few things worth having.
CharlesA Hoop’-=e-‘-r__Dan, I got the meter cable marked yesterday. 0 … 10/25/2012 09:29:23 AM
From: CharlesA Hooper/R7/USEPA!US To: Dan GravatUR7/USEPA!US@EPA Date: 10/25/2012 09:29AM Subject: meter cable for Westlake
Dan,· I got the meter cable marked yesterday. One foot increment hash-marks with labels every five feet. Now I need to make sure this marker is going to do the trick for decon; how were we planning on doing that and was there a final QAPP? I figured wet wipes but I don’t remember what was in the plan. If the wet wipes take off the marker then I’ll have to try it again with a different type but I wanted to let it dry before trying it yesterday. -Chuck
Please note our new address in Lenexa, Kansas.
Chuck Hooper, CHP Radiation Safety Officer US EPA, Region 7 11201 Renner Boulevard Lenexa, Kansas66219
(913) 551-7271 office Hooper.CharlesA@epa.gov

At-Title and Approval
Quality Assurance Project Plan
Surface Gamma Scans and Down-hole Gamma Logs

West Lake Landfill OUt
Bridgeton, Missouri

August, 2012

Diane Harris Date: Regional Quality Assurance Manager
DeAndre Singletary, Chief Date: MOKS Branch SUPR Division, EPA Region 7
Dan Gravatt, RPM Date: MOKS Branch SUPR Division, EPA Region 7
A2 -Table of Contents
A 1. Title and Approval
A2. Table of Contents

A. Project Management …………………………………………………………………………………………………… 3
A3. Distribution List …………………………………………………………………………………………….. 3
A4. Project/Task Organization ……………………………………………………………………………….. 3
AS. Problem Definition/Background ………………………………………………………………………. 3
A6. Project/Task Description ………………………………………………………………………………… .4
A7. Quality Objectives and Criteria for Measurement Data ……………………………………….. 5
AS. Special Training Requirements/Certification ……………………………………………………… 6
A9. Documentation and Records ……………………………………………………………………………. 6

B. Measurement/Data Acquisition …………………………………………………………………………………….. 6
B1. Sampling Process Design ………………………………………………………………………………… 6
B2. Sampling Methods Requirements …………………………………………………………………….. ?
B3. Description of Decontamination Procedures for Sampling Equipment.. ………………… ?

84. Sample Handling and Custody Requirements …………………………………………………….. 8

85. Analytical Methods Requirements ……………………………………………………………………. 8

86. Quality Control Requirements ………………………………………………………………………….. 8

87. Instrument/Equipment Testing, Inspection, and Maintenance Requirements ………….. 8

88. Instrument Calibration and Frequency ………………………………………………………………. 8
B9. Inspection/ Acceptance Requirements for Supplies and Consumables …………………… 8
8 I 0. Data Acquisition Requirements ……………………………………………………………………… 8
B11. Data Management ………………………………………………………………………………………… 9

C. Assessment/Oversight …………………………………………………………………………………………………. 9
C1. Assessments and Response Actions ………………………………………………………………….. 9
C2. Reports to Management ………………………………………………………………………………….. 9

D. Data Validation and Usability ………………………………………………………………………………………. 9
Dl. Data Review, Validation, and Verification Requirements ……………………………………. 9
D2. Validation and Verification Methods ………………………………………………………………… 9
D3. Reconciliation with User Requirements ………………………………………………9

Abbreviations and Acronyms
Figure I: OU1 Extents and Monitoring Well Locations (Figure 2 from 2012 PRP SAP)
Table I: List of Monitoring Wells to be Logged (Table 3 from 2012 PRP SAP)
Appendix A Field SOPs
A. Project Management
A3. Distribution List
This quality assurance project plan (QAPP) is prepared for the West Lake Landfill site in Bridgeton, Missouri, and is submitted as documentation of the protocols and procedures to be followed during collection of surface and down-hole gamma scans at the site. Distribution of this plan will be as follows:
Dan Gravatt, RPM, MOKS/SUPR, U.S. EPA Region 7 On-Scene Coordinators (OSCs) assisting with field data collection, U.S. EPA Region 7 Diane Harris, RQAM/ENSV, U.S. EPA Region 7
A4. Project/Task Organization
This project is being managed and administered by EPA Region 7 according to the responsibilities described below:
Dan Gravatt, RPM
Project Manager
MOKS Branch/SUPR Division (913) 551-7324
Responsibilities: Project Management; Field Team Leader; Field Data Collection Project
Design and Implementation
OSCs (to be determined) and/or RPMs
MOKS Branch, ERNB and/or ERSB sections
Responsibilities: Field data collection

Tetra Tech (START Contractor)
Responsibilities: Field technical support for gamma scanning and figure preparation

A5. Problem Definition/Background
The purpose of this QAPP is to support the collection of surface and down-hole gamma scans. The objective ofthis work is to collect additional data on the distribution of radionuclides within Operable Unit 1 (OUl).
Surface gamma scans and down-hole gamma scans ofboreholes were conducted as part of the Remedial Investigation (RI) for the site in the late 1990s, and the data was summarized in the RI Report (EMSI, April 2000). Work under this QAPP will re-scan the surfaces ofboth areas of OU 1 for gamma emissions, as well as scanning all accessible monitoring wells at the site for gamma emissions. Some of the monitoring wells were previously scanned (as boreholes, prior to their completion as wells) during the RI, and some have never been scanned.
Gamma scanning field work will be performed by the RPM and OSCs using field.portable scanning instruments. No samples of any media will be collected.
A6. Project/Task Description
The objective ofthis study is to collect additional data on the distribution ofradionuclides within OU 1. This QAPP addresses field procedures to collect the surface and down-hole gamma scan data. The measurement and data acquisition methods specified below have been selected to meet this objective. Figure 1 illustrates the site layout and monitoring well locations for down.hole scans.
The data from this study will be assembled and provided to Dan Gravatt, RPM, MOKS/SUPR Division, U.S. EPA Region 7.
A6.1 Work to be perfonned
The scope offield activities to be performed for these gamma scans includes the following:

Scanning the surface ofOUl with a Ludlum Model2241-3 and Nal Tl detector; and


Scanning all accessible and intact monitoring wells associated with OU I and OU2 with a Ludlum Model 2241-3 and Ludlum 44-62 Nal probe to the maximum depth ofthe well or 150 feet, whichever is less.

(
1) Measurements

(a)
Areas and monitoring wells to be sampled

All accessible portions of the surface ofOUl will be scanned with the Ludlum Model 2241-3 and its Nal Tl detector. It is anticipated that vegetation or rubble piles may prevent scanning ofportions of Area 2 of OU 1. All accessible and intact monitoring wells on-site capable ofpassing the Ludlum 44-62 Nal down-hole probe will be scanned.
(b) Analyses
Both the Ludlum Model2241-3 with Nal Tl detector and the Ludlum 2241-3 with 44-62 Nal probe will collect real-time data on gamma intensity. No laboratory samples will be collected or analyzed.
(2) Standards/Criteria
As gamma scanning is a semi-quantitative data collection technique that does not yield specific concentrations ofany radioisotopes in environmental media, there are no applicable thresholds or criteria for determining whether a particular gamma count value is acceptable or unacceptable. This data will be used to qualitatively update EPA’s knowledge of the distribution ofradionuclides at the site.
(3) Personnel/Equipment Requirements
All personnel perfonning activities covered by this QAPP shall comply with the Occupational Safety and Health Act, as well as EPA regulations for worker health and safety. Personnel requirements are discussed in Section A8. Level D PPE consisting of steel-toed boots, appropriate gloves, long pants and long-sleeved shirt at a minimum will be required for field personnel. Additional PPE for operating EPA’s utility terrain vehicles will include full-face helmets and eye protection.
(4) Assessment Techniques
Field instrumentation will be calibrated and demonstrated to be working properly as described in 8.7 below.
(5) Project Schedule
The anticipated schedule for this sampling effort will consist ofone field scanning mobilization in August, 2012. The field work is anticipated to take one week.
(6) Documentation
Data collection activities will be documented with the following (more detailed descriptions of the documentation is provided in Sections A9, 810, and C2 of this QAPP):
Field records;
Data Summary tables; and
Data Summary figures.

A7. Quality Objectives and Criteria for Measurement Data
The purpose of this investigation is to obtain additional gamma scans ofthe surface and down-hole gamma logs of accessible monitoring wells. No samples of any media will be collected. As gamma scanning is a semi-quantitative data collection technique that does not yield specific concentrations of any radioisotopes in environmental media, the following quality objectives are generally in a narrative form.
Representativeness will be addressed by proper calibration and use of the gamma scan probes for the surface and down-hole measurements, so that the instrument readings correlate to the distribution of gamma-emitting radionuclides at the site.
Comparability expresses the confidence with which one· set of analytical data may be compared with another. Comparability will be qualitatively addressed by comparing the results of the surface gamma scan with the results of the previous RI surface gamma scan; however, due to differences in the methodologies used, differences in the two scan results will not necessarily indicate any change in conditions at the site
Completeness is a measure of the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under normal conditions. Field completeness is a measure of the amount of valid measurements obtained from the measurement taken in the project. The field completeness objective for this project will be 80%. I 00% completeness is not required for the data to be useable for its intended purpose.
Accuracy and precision will be addressed by proper calibration and use of the gamma scan probes for the surface and down-hole measurements, so that the instrument readings accurately measure gamma emission rates at the site.
AS. Special Training Requirements/Certification
All personnel who will be on-site performing field activities associated with this investigation must have successfully completed an initial 40-hour hazardous waste operations training course and, thereafter, an annual 8-hour refresher course. The training must comply with Occupational Safety and Health Administration (OSHA) regulations found in 29 Code of Federal Regulations ( CFR) 191 0.120( e). Personnel must also have had advanced radiation safety training, and will be required to wear a thermoluminescent dosimeter and electronic personal dosimeter while on-site. Personnel must be trained and certified to operate EPA’s utility terrain vehicles, which will be used for the surface gamma scan.
A9. Documentation and Records
The project manager will be responsible for ensuring the most current version of the QAPP is available and distributed to all involved parties, and that data collected during this field work is properly stored and reported to stakeholders.
B. Measurement/Data Acquisition
B I. Sampling Process Design
The surface gamma scan will be conducted with a Ludlum Model 2241-3, with a 3-by 3.inch Nal Tl scintillator probe. The scan will be conducted in a serpentine pattern across each area of OU 1, with spacing between scan lines of 30 feet (the RI QAPP specified a 30’ grid). A narrower spacing and/or scan lines at different angles may be used in areas exhibiting higher gamma counts to provide more detail, based on field observations. The detector will be held approximately twelve inches above the ground surface while the surveyor moves the detector at a constant speed approximating walking pace, and the system will collect a reading every two seconds. Global Positioning System (GPS) data will be simultaneously collected, and the resulting gamma results will be mapped. Prior to scanning the site, background gamma levels will be established at a nearby uncontaminated area (the RI QAPP specified “Local background will be established by taking a measurement off-site on the open field east of the site and east of the St. Charles Rock Road entrance to the site”).
The down-hole gamma scan will be conducted with a Ludlum Model2241-3, with a 44.62 detector. The detector will be lowered to the bottom of each accessible well or to a maximum depth of 150 feet, whichever is less. The detector will then be raised in one-foot increments, and measurements will be recorded at each interval using the scaler set for a 6-second count.
Groundwater samples will not be collected during this work, though previously available analytical results from other studies may be used in interpreting the data from these down-hole gamma scans. Groundwater elevations within the wells will not be measured during this work, though previously available water level measurements from other studies may be used in interpreting the data from these down-hole gamma scans.
Wells PZ-1 03SS, PZ-1 04SS, PZ-1 05SS, PZ-1 08SS, PZ-111 SO and PZ-116SS are designated as background wells to represent naturally-occurring gamma emissions in the subsurface geologic materials. These wells were selected for their depth ( 150 feet or more), their distance from the OU I cells, and their lack of any historical detections of radionuclides in groundwater above applicable standards.
B2. Sampling Methods Requirements
Standard operating procedures for the gamma scanning instrument and detectors will be followed. These SOPs are included in Appendix A.
The utility terrain vehicle will be driven at a speed appropriate to generate a thorough density of data points and to minimi?e the generation ofdust.
The EPA field team leader will detennine the need for any change in sampling method or locations, if field personnel note difficult site conditions. Any corrective actions required during the implementation of field sampling activities will be documented by the field team leader.
B3. Description of Decontamination Procedures for Sampling Equipment
The down-hole gamma probe shall be decontaminated prior to logging the first well and between each well by washing with a soap solution (such as Alconox) and rinsing with potable water. Previous analytical results for these wells indicate that several metals and volatile organic compounds are present in some wells above their maximum contaminant levels, including arsenic, lead, and benzene. Concentrations of these contaminants are not high enough to warrant additional PPE or more stringent decontamination methods. The rinse water will be poured onto the ground away from the well after use.
The surface gamma scan instrument does not contact the land surface and does not require decontamination.
The utility terrain vehicles, field personnel boots, and any other equipment potentially contaminated by soil will be decontaminated by dry brushing to remove the material. Equipment will then be scanned with a Ludlum Model 44-9 Geiger-Muller “pancake probe” to ensure that any radioactive contamination has been removed down to a level ofthree times the background count rate with the pancake probe.
Any solid investigation-derived waste such as gloves or paper towels will be bagged, surveyed with the ”pancake probe” to ensure that radiation levels do not exceed three times the background count rate, and disposed of at the solid waste transfer facility on-site.
B4. Sample Handling and Custody Requirements No samples of any media will be collected during this work. B5. Analytical Methods Requirements No analytical methods will be used for this work. B6. Quality Control Requirements
Quality control will be maintained during the field work by operating the instruments in accordance with the manufacturer’s instructions and EPA’s SOPs. B7. Instrument/Equipment Testing, Inspection, and Maintenance Requirements
The field equipment testing, inspection, and maintenance will be performed in accordance with the manufacturer’s recommendations. B8. Instrument Calibration and Frequency Field equipment calibrations will be performed in accordance with the manufacturer’s recommendations prior to mobilization. B9. Inspection/ Acceptance Requirements for Supplies and Consumables No supplies or ,consumables will be required for this work. B10. Data Acquisition Requirements
Data acquired from the surface gamma scan instrument and its GPS tracker will be downloaded to EPA computer systems and mapped as necessary to support program goals. Data from the down-hole gamma scanner will be recorded by hand in field logbooks and transcribed into an EPA computer system, or entered directly into an EPA laptop in the field in real time.
B 11. Data Management
Data will be stored and backed up on EPA computer systems, filed in the Records Center, and distributed to stakeholders as needed. Documents filed in the Records Center are stored according to standard records retention schedules.
C. Assessment/Oversight
C 1. Assessments and Response Actions
The EPA QA manager or their designee may conduct an audit of the field activities for this project if requested by the EPA project manager. The EPA QA manager will have the authority to issue a stop work order upon finding a significant condition that would adversely affect the quality and usability of the data. The EPA project manger will have the responsibility for initiating and implementing response actions associated with findings identified during the on-site audit. Once the response actions have been implemented, the EPA QA manger will perform a follow-up audit to verify and document that the response actions were implemented effectively.
C2. Reports to Management
A report of the field work and analytical results will be prepared by the project manager and copies shared with the state and other stakeholders. This report will also include information on any performance evaluations, audits, and significant QA problems, as applicable.
D. Data Validation and Usability
Dl. Data Review, Validation, and Verification Requirements
The EPA Project manager will be responsible for overall validation and final approval of the data in accordance with project purpose and use of the data.
D2. Validation and Verification Methods
As the data collected by the planned field work is semi-quantitative, no additional data validation or verification methods are planned.
D3. Reconciliation with User Requirements
Once the data results are compiled, the EPA project manager will review the data results to detennine if they fall within the acceptance limits as defined in this QAPP. Completeness will be evaluated to determine if the completeness goal for this project has been met. If the completeness objective has not been met, the EPA project manager will determine an appropriate course of action. Failure to meet the completeness objective will not necessarily require re.sampling.
..

Upon compilation of the data, the RPM will review the data in relation to the quality objectives and criteria for measurement, to identify any limitations on the use of the data. The RPM will evaluate data to ensure the information sufficiently characterizes the distribution of gamma-emitting radionuclides at the site, and assess the degree to which the Quality Objectives in A. 7 and the Quality Control measures in B.6 have been met. If the RPM detennines data quality indicators do not meet the project requirements, then the data may have to be discarded and re-sampling may be required.
CFR EPA GPS
osc
OSHA
ou
PPE PRP QA QAPP QC RI RPM RQAM SAP SOP
sow
Abbreviations and Acronyms
Code of Federal Regulations
U.S. Environmental Protection Agency Global Positioning System On-scene commander Occupational Safety and Health Administration operable unit personal protective equipment potentially responsible party quality assurance quality assurance project plan quality control remedial investigation Remedial project manager regional quality assurance manager sampling and analysis plan standard operating procedure statement of work

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