1990-03 – DOE – Radiological Characterization Report for FUSRAP properties in the St. Louis, Missouri, Area

DOE/OR/20722-203 o 19 RADIOLOGICAL CHARACTERIZATION REPORT FOR FUSRAP PROPERTIES IN THE ST. LOUIS.... View Document

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2005-01-07 – DOE – NORTH ST. LOUIS COUNTY HAUL ROAD ANALYSIS AND JUSTIFICATION FOR ADDITIONAL INVESTIGATION – EVALUATION OF INACCESSIBLE MATERIALS BENEATH PAVEMENTS

REPLY TO
ATTENTION OF:
DEPARTMENT OF THE ARMY
ST. LOUIS DISTRICT, CORPS OF ENGINEERS
8945 LATTY AVENUE RECEIVED
BERKELY, MISSOURI 63134
January 20,2005 JAN 2 1 2005
Formerly Utilized Sites Remedial Action Program
SUPERFUND DIVISION
Subject: Final Version of North St. Louis County Haul Road Analysis and Justification for
Additional Investigation – Evaluation of Inaccessible Materials Beneath Pavements dated
January 7,2005
Mr. Dan Wall
U. S. Environmental Protection Agency
Region VII, Superfund Branch
901 North Fifth Street
Kansas City, KS 66101-2907
Dear Mr. Wall:
Please find enclosed a copy ofthe North St. Louis County Haul Road Analysis and
Justification for Additional Investigation – Evaluation of Inaccessible Materials Beneath
Pavements Final, dated January 7,2005 for your records. The responses to comments on the
subject document were sent under separate cover on December 22,2004.
If you need any additional information or have any questions regarding this document, please
contact me at (314) 260-3915.
Sincerely,
Sharon R. Cotner
FUSRAP Program Manager
Enclosiu-es
CF: Mr. Robert Geller
40327800 lliil
Superfund
RECEIVED
JAN 2 1 2005
SUPERhUNU DIVISION
FINAL
NORTH ST. LOUIS COUNTY HAUL ROAD
ANALYSIS AND JUSTIFICATION FOR
ADDITIONAL INVESTIGATION – EVALUATION
OF INACCESSIBLE MATERIALS BENEATH
PAVEMENTS
ST. LOUIS, MISSOURI
JANUARY 7,2005
Prepared by
U. S. Army Corp of Engineers, St. Louis District Office,
Formerly Utilized Sites Remedial Action Program
With assistance from
Science Applications International Corporation (SAIC)
Under Contract No. DACW43-00-D-051S
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North St. Louis County Haul Road Analysis and Justification for Additional Investigation-Evaluation of
Inaccessible Materials Beneath Pavements
TABLE OF CONTENTS
SECTION PAGE
1.0 INTRODUCTION AND PURPOSE 1
2.0 SITE BACKGROUND AND HISTORY 2
2.1 TIMELINE OF EVENTS 3
2.2 METHODS OF POSSIBLE IMPACT 7
2.2.1 How Impacts May Have Been Caused By Truck Transportation 8
2.2.2 Protection ofthe Materials Under Pavements From Direct Impacts 8
2.2.3 Low Probability of Occurrence Mechanisms that Could Result in Impacts
Under Road Pavements 8
2.3 CONSIDERATIONS AND PROCEDURES 9
2.4 HISTORICAL FIELD-TESTING 10
2.4.1 Results Ofhiitial Testing Under Roads 11
2.5 HAUL ROUTES BETWEEN THE SLAPS AND THE HISS/FUTURA SITE 16
2.5.1 Evaluation of Haul Routes Between the SLAPS and the HISS. 23
2.5.2 Methods for Transporting Residues Between the SLAPS and the HISS 23
2.5.3 Conclusions 25
2.6 RESEARCH SUMMARY 26
3.0 SUMMARY OF POTENTIAL IMPACTS BY ROADS 33
3.1 SUMMARY OF RESULTS OF HISTORICAL TESTING 33
3.2 TYPICAL RIGHT-OF-WAY WIDTHS 40
3.3 AREAS OF FILL 41
3.4 BRIDGES 41
3.5 ADDITIONAL INFORMATION 45
4.0 REFERENCES 46
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LIST OF APPENDICES
A.l McDonnell Boulevard A-1
Figures Ml Through M8
A.2 1-270, Including Pershall & Dunn Roads… A-5
Figures PI Through P8
A.3 Eva Avenue A-8
Figures El Through E2
A.4 Frost Avenue I A-11
Figures Fl Through F2
A.5 Hazelwood Avenue A-16
Figures HI Through H4
A.6 Latty Avenue A-20
Figures Ll Through L3
A.7 1-170 A-25
Figures II Through 17
A.8 Lindbergh Boulevard A-28
Figures LBl Through LB3
A.9 North Hanley And Graham Road A-31
Figures HAI Through HA7
A.IO Airport Road A-35
Figures Al Through A3
A.ll Banshee Road…. A-37
Figures Bl Through B3
A.12 Poison Road A-40
Figures Al Through A3
A.13 Seeger Industrial Road A-42
Figures SI Through SI
A.14 Pavement Evaluation Of Nyflot Avenue A-44
Figures
A.15 Selected Historical Documents A-46
REFERENCE DOCUMENTS
RD 1 Copy Of “History Of Material Storage At The St. Louis Airport Storage Site” A-47
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LIST OF EXHIBITS
EXHIBIT A – Investigation Under Road Pavement
EXHIBIT B – Key Map of Figures Included in Appendices
LIST OF TABLES
SECTION PAGE
Table 2-1 Comparison of Haul Routes Between the SLAPS and the HISS 23
Table 2-2 Aerial Photographs Available 27
Table 3-1 Possible Impacts from Haulage SLAPS and the HISS 1966/67 …. 35
Table 3-2 Possible Impacts from Haulage HISS and West Lake Landfill 1973. 36
Table 3-3 Potential Wind, Stormwater or Floodwater Impacts 37
Table 3-4 Results of Testing 38
Table 3-5 Summary of Findings 39
Table 3-6 Cause of Impacts :.— 40
LIST OF FIGURES
SECTION PAGE
Figure 2-1 General Location of the Mallinckrodt Chemical Plant and the SLAPS, HISS,
and West Lake LandfiU Storage Sites in St. Louis, Missouri 12
Figure 2-2 Diagram of Route Scanned in the Vicinity of the Mallinckrodt Chemical
Plant Site, St. Louis, Missouri………………………………………………………………… 13
Figure 2-3 Diagram of Routes Scanned by Oak Ridge National Laboratory and Routes
Characterized by Bechtel National, Inc. in the Vicinity of the Lambert-St.
Louis International Airport, St. Louis, Missouri 14
Figure 2-4 Locations of Impacts Found By Testing 15
Figure 2-5 Routes Between the SLAPS and the HISS Route A Most Direct Route 17
Figure 2-6 Routes Between the SLAPS and the HISS Route B 18
Figure 2-7 Routes Between the SLAPS and the HISS Route C 19
Figure 2-8 Route Between the SLAPS and the HISS Route D 20
Figure 2-9 Route Between the SLAPS and the HISS Route E 21
Figure 2-10 Route Between the SLAPS and the HISS Route F 22
Figure 2-11 USGS Quad Map Locations 30
LIST OF ILLUSTRATIONS
Illustration 2.1 Typical 1960 20-Ton Over-the-Road Dump Truck 25
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North St. Louis County Haul Road Analysis and Justification for Additional Investigation-Evaluation of
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LIST OF ACRONYMS AND ABBREVIATIONS
AC
AEC
aka
B&K
BNI
CADD
CDC
DOE
EPA
HISS
MoDOT
NRC
ORNL
OU
PCC
ROW
SAIC
SLAPS
SLDS
SOR
USGS
asphaltic concrete
Atomic Energy Commission
also known as
B&K Construction Inc.
Bechtel National, Inc.
computer-aided design and drafting
Commercial Discoimt of Chicago
United States Department of Energy
United States Envirormiental Protection Agency
Hazelwood Interim Storage Site
Missouri Department of Transportation
Nuclear Regulatory Commission
Oak Ridge National Laboratories
Operable Units
Portland cement concrete
right-of-way
Science Applications Intemational Corporation
St. Louis Airport Site
St. Louis Downtown Site
sum of ratios
United States Geological Survey
DEFINITIONS:
Impact – Subject to the potential presence of residue.
Impervious – Will not allow the passage of fluid or dust.
Material – Any natural soil or manmade substance beneath a road pavement.
Obliterated – Completely demohshed and removed leaving no clear traces.
Residue – Waste byproducts fi-om processing activities carried out at Mallinckrodt Chemical
Works in downtown St. Louis.
Right-of-way – Land subject to an easement for the passage ofthe public and other public uses.
Road pavements – The hard, durable, impervious, manmade surface covering of a street
designed for the passage of vehicles.
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North St. Louis County Haul Road Analysis and Justification for Additional Investigation-Evaluation of
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1.0 INTRODUCTION AND PURPOSE
This report determines the potential location of possibly impacted materials beneath road
pavements around the St. Louis Airport Site (SLAPS) and the Hazelwood Interim Storage Site
(HISS). This report is limited to evaluating materials near or underlying the roadways located
within an area referred to as the SLAPS Road Study Area. The area to be studied is bounded by
the following roadways (See Exhibit A):
On the West by Lindbergh Boulevard,
On the North by Interstate 270,
On the East by Graham Road and North Hanley Road,
On the South by Airport Road to its intersection with McDonnell Boulevard and with
McDonnell Boiilevard to its intersection with Banshee Road and then with Banshee Road
This determination was accomplished by reviewing available records of pavement histories, road
construction dociunents, historical aerial photographs, available pavement borings, historical
maps and documents, site investigations, and other miscellaneous documents to determine when
and how these pavements were constructed and when and how the materials beneath these
pavements may have been potentially impacted by residue hauling or other possible means of
residue transportation.
Impervious pavements that existed during the period of possible impacts protected the
imderlying material fi-om direct exposure to residue; therefore, there is no need to subject those
materials to fiirther investigation. Conversely, fiirther investigation is needed in the areas where
pavements were constructed over materials possibly impacted by prior exposure to residues.
This report examines the history of road pavements relative to the effects fix)m residues in the
SLAPS Road Study Area.
This report
• Identifies the changes in road surface location, type of construction, right-of-way, and
pavement widths for the SLAPS Road Study Area roads from 1946 to the present (2004).
• Determines whether the road surfaces prevented residue from migrating from the surface to
directly affect the material beneath that pavement.
• Identifies where pavements have been constructed over areas possibly previously impacted
by residue. This residue originates from residue hauling activities or water and wind erosion
from the storage of wastes in the SLAPS Road Study Area.
• Evaluates the historical evidence, in conjunction with evidence from field-testing, to
determine where fiirther investigation is warranted.
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Those properties along each roadway which have been identified as vicinity properties are listed
in the following table.
Table 1-1 Vicinity Properties adjoining roadways
Road Segment
Eva Avenue
Hazelwood Avenue
Latty Avenue
Frost Avenue
1-170
1-270
Lindbergh Boulevard
North Hanley Road
Graham Road
Airport Road
Banshee Road
Pershall and Ehmn roads
Poison Road
Seeger Industrial Drive
Nyflot Road
McDonnell Boulevard
Vicinity Proprieties
16, 17,18,19
24, 31 A, 32, 33, 34, 35, 35A, 37, 38, 39, 39A, 40, 41, 42, 43, 44,
45,46,47,48,48A, 53
35, 37,38, 39, 39A
19, 20,20A, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31
31,31A,33,34,35,39,39A,50
48A, 53, 54, 55, 56, 57, 58, 63A
3,63
52
15
15
14A
48,48A, 49, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62,
55,56
21,22,23,24, 32
39,41
2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14,14A, 15, 16
2.0 SITE BACKGROUND AND HISTORY
Starting in the early 1940s, uranium metal and other radioactive substances were produced at the
MaUinckrodt Chemical Works in St. Louis, Missouri. These facilities, as well as other properties
in their vicinity, are now collectively known as the St. Louis Downtown Site (SLDS). Beginning
in 1946 the residue from this processing operation was transported to and stored on a 21.7-acre
property that is located north of St. Louis Mimicipal Airport (now Lambert-St. Louis
Intemational Airport). This parcel and surrounding areas are collectively now known as the
SLAPS. The site was used for the storage of residues from 1946 to 1967. The residues were
transported from the SLDS to the SLAPS by truck over public roadways. In 1966 the residues
were sold to a private company, the Continental Mining and Milling Company (Continental),
which transported the residues from the SLAPS over the public roadways to a second site for
eventual reprocessing and shipment by rail to Cotter Corporation facilities in Canon City,
Colorado. This second site, 9200 Latty Avenue, is located south of Latty Avenue and east of
Coldwater Creek. This property and the surrounding properties are collectively known as the
Latty Avenue Site. The area was used to store residues from 1966 to 1973. The SLAPS and the
Latty Avenue Site are collectively known as the North St. Louis County Sites.
After the removal of the residues from the SLAPS by Continental, the SLAPS site was
transferred to the control of the St. Louis Airport Authority. The structures at the site were
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demolished and buried on-site. In 1970, approximately 1 to 3 feet of fill from airport
construction projects was brought to the SLAPS and spread over the site. This fill and the
retuming trucks traveled over public roadways.
After the removal of much ofthe residue from the HISS by rail transport to Colorado, a portion
ofthe remaining residues were removed and transported over the public roads to the West Lake
Landfill facility for disposal. This activity occurred in 1973.
During all of these activities, the residues were stored on the open ground with few engineering
controls to prevent erosion by water or wind action. The HISS and the SLAPS are also partially
within the floodplain of Coldwater Creek.
2.1 TIMELINE OF EVENTS
The residue from the Mallinckrodt refining operation is the potential source of impacts along the
roads. The events listed chronologically below are relevant to determining the possible inipacts
to roads.
• On April 24, 1941, Mallinckrodt began processing uranium ore in downtown St. Louis.
Mallinckrodt continued uranium refining in downtown St. Louis until 1959. These activities
were performed imder contracts with the Manhattan Engineer District and the United States
Atomic Energy Commission (AEC).
• In 1945 the Manhattan Engineering District began the process of looking for a 5-acre site to
store residues from the SLDS. The need for the land was urgent because there was no room
to store these residues at the downtown plant. The preferred land was to be:
– Fairly isolated or easily capable of isolation by the erection of fences
– Not subject to floods or excessive ground drainage
– Readily available, and preferably located to the north or northwest ofthe city.
• On March 2, 1946, permission was obtained to use the SLAPS for the storage of residues.
Actual title was not acquired until January 3, 1947. This land was acquired by
condemnation. Due to the “unfavorable publicity” generated by the condemnation
proceedings, a decision was made to erect a fence around the site. Most of the wastes and
residues were stored on open ground.
• From 1946 through 1958, residues were transported to the SLAPS for storage, mostly from
Mallinckrodt in downtown St. Louis. Private contractors using government-supplied
equipment transported the residues over the public roadways.
• In 1948 and 1949, highly radioactive radium-bearing residues were transferred from the
SLAPS to Femald, Ohio.
• In 1952, “several hundred tons of contaminated metal and debris” were buried at the SLAPS
under 6 to 8 feet of fill obtained from McDonnell Aircraft.
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• In 1954, sixty tons of captured Japanese uranium residues and approximately 500 tons of
other “low grade uranium bearing residues” were brought to the SLAPS from Middlesex,
New Jersey.
• In an inventory ofthe site dated April 11, 1959, it is stated that the following residues had
been deUvered to the SLAPS:
Pitchblende Raffmate, AM-7 74,000 tons
Raffinate, AM-10 32,500 tons
Slag, C-liner 7,800 tons
Interim Residue Plant Tailings, C-701 5,400 tons
Barium Cake, AJ-4 10,200 tons
Vitro residues 290 tons
Captured Japanese Uranium precipitates 60 tons
55,000 30^ and 50-gal drums as scrap 3.500 tons
Total tons hauled to the SLAPS prior to 1960 133,750 tons
These values were based on weight of residues delivered to the site with no adjustment for
moisture pickup.
Source: March 22,1960 drawing titled MCW DWG #6-1403-19-C.
See Reference Document No. 1 for a copy of a document titled History of Material
Storage at the St. Louis Airport Storage Site, which contains a description of the
residue designations listed above and additional information conceming the origins
and disposition ofthe residues.
• In 1959, a raihoad siding and loading facilities were constructed at the SLAPS.
• In 1960, Federal Division of Raw Materials explored disposal ofthe residues. Per their June
1960 memo, the refined value ofthe cobalt, nickel, copper and selenium in the residues was
believed to be $15,000,000 to $20,000,000. In addition the residues contained 250,000
pounds of uranium, the value of which was not included in the $15,000,000 to $20,000,000.
• In 1962, bids were invited on the residues, and an award was made to Contemporary Metals
Corporation, Los Angeles (Contemporary); however. Contemporary failed to fiimish the
$50,000 performance bond and pay the $126,500 bid and defaulted on the contract.
Contemporary did no work on the site.
• Two additional invitations to bid were issued in 1964, neither of which produced a
responsive bid.
• In 1964, 4,000 tons of C-Oxide residues were shipped either to Femald, Ohio for processing
or to Weldon Spring for storage.
• A September 23,1965, Memo titled St. Louis Airport Resides listed the inventory for another
invitation to bid to be following five categories of residues. Separate bids were invited for
each category.
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Pitchblende Raffinate 74,000 tons
Colorado Raffinate 32,500 tons
Barium Cake, unbleached 1,500 tons
Barium Cake, leached 8,700 tons
Miscellaneous Material in Dmms 350 tons
The memo also discussed the proposed remediation ofthe site as follows:
“The major problem would appear to be in 5 acres in the west end of the area. This was
originally low swampy ground, drained by a couple of ditches. It was filled and graded and then
the Colorado Raffinate, some dmmmed material and contaminated waste of all kinds were buried
on this fill. However, there is buried somewhere in the fill about six carloads of metal scrap, an
unknoAvn quantity of drums, and a jeep.”
• In February 1966, Continental Mining and Milling (Continental) purchased the five residue
items listed above for $126,500. Continental then borrowed $2,500,000 from Commercial
Discount of Chicago (CDC) for the processing operation. The residues are believed to have
totaled 117,000 tons. Continental later purchased 7,800 tons of C-Liner Slag for an
additional $14,000.
• On December 21, 1965, the Village of Hazelwood approved the use of the 9200 Latty
Avenue property by Continental for refining operations.
• On February 14, 1966, AEC gave Continental a Source Material License for “Removal of
stockpile residues from 50 Brown Road, Robertson, Missouri, and storage only at the
licensee’s facilities located at 9200 Latty Avenue, Hazelwood, Missouri, in accordance with
the procedures described in the licensee’s application dated Febmary 4, 1966, and
supplements dated February 7 and Febmary 8,1966.”
• On February 28,1966, AEC gave Continental Notice to Proceed to remove the residues from
the SLAPS. Continental was given 400 days, until April 4,1967, to complete the task.
• In a five-month period, some time between March 1966 and April 1967, the residues were
moved from the SLAPS to the HISS by a hauling contractor hired by Contmental. This
move required ten dump tmcks for a period of five months and cost Continental $100,000.
• On Febraary 3, 1967, CDC foreclosed on Continental’s loan. CDC became the owner ofthe
residues and the HISS property at a public sale.
• February 14, 1967, the AEC provided a “punch list” of items in need of completion at the
SLAPS before April 4, 1967 in order for AEC to declare the work complete. One of the
punch list items was to remove an “apparently abandoned” haulage truck from the SLAPS.
• On April 14, 1967, the AEC wrote Hartford Accident & Indenmity Company stating that
Continental had not responded to earlier letters so “we (AEC) would assume from our
knowledge, that we can expect no fiirther action by them, so that we must, apparently, look to
you (Hartford) for finishing the work.” Hartford apparently paid to complete the clean-up
and AEC released their performance bond.
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• In 1967, CDC attempted to sell the residues; there were no bidders. The residues at the HISS
were estimated at 100,000 tons.
• From 1967 to 1968, CDC began drying the residues under an NRC license. The dried
residues were shipped to Cotter Corporation facilities in Canon City, Colorado. By the end
of 1968,47,000 tons of residues had been shipped.
• In 1969, no activity took place at the HISS. The remaining residues were sold to Cotter
Corporation.
• In 1969, the SLAPS was transferred to the St. Louis Airport Authority. The St. Louis
Airport Authority demolished the existing buildings and buried the demolition debris on-site.
The SLAPS was then covered with approximately 3 feet of clean fill. In 1970, this fill was
tmcked in from the construction of Lambert-St. Louis Intemational Airport.
• In 1970, Cotter Corporation resumed drying operations and shipped all but 18,700 tons of
residues to Canon City, Colorado.
• In 1973, the Cotter Corporation hired B&K Constmction Inc. (B&K), a St. Ann, Missouri
road constmction company, to load the remaining residues onto rail cars for shipment to
Cotter Corporation facilities in Canon City, Colorado. Approximately 10,000 tons of
residues were shipped to Cotter Corporation in Canon City, Colorado without drying.
• In 1973, B&K disposed ofthe remaining residues (8,700 tons of leached barium sulfate cake)
at the West Lake Landfill. It is uncertain what occurred. B&K billed Cotter for shipment of
50,000 tons, but B&K and others state that only 9,000 tons were actually sent to the landfill.
The AEC was told that the remaining 8,700 tons of residue were mixed with 40,000 tons of
soil prior to being sent to the landfill, but it does not appear that this actually occurred.
• In 1976 and 1977, the HISS (it was then know as the Latty Avenue site) was evaluated by the
Nuclear Regulatory Commission for release for unrestricted use. Additional efforts were
found to be needed.
• In 1984, the U.S. Department of Energy (DOE) issued a report titled Post-Remedial Action
Report for the Hazelwood Site describing the testing performed to allow the cities of
Berkeley and Hazelwood to design a new Latty Avenue road pavement and storm sewer
system.
• In 1985, the DOE conducted mobile gamma scanning to detect any anomalies associated
with the transportation routes between the Latty Avenue Properties and the West Lake
Landfill. Impacts were found on McDonnell Boulevard, Pershall Road, and Hazelwood
Avenue.
• In 1986, DOE directed Bechtel National, Inc. to provide radiological support to the cities of
Berkeley and Hazelwood during the Latty Avenue road and storm sewer improvement
project. During this time concentrations of radium-226 and thorium-230 contamination in
excess of DOE remedial action guidelines were found along and under Latty Avenue. The
asphalt pavement itself was also found to be impacted. The existing asphaltic concrete (AC)
pavement was removed, as well as some of the material formerly under the pavement. A
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new Portland Cement Concrete (PCC) pavement was constmcted. The impacted material
was removed and stockpiled on the HISS.
• In 1986, Oak Ridge National Laboratory (ORNL) issued a report entitled Results of the
Radiation Measurements Taken of Transportation Routes (LM004) in Hazelwood, Missouri.
This report indicated that anomahes were found along Pershall Road between Lindbergh
Boulevard and Poison Lane, along Hazelwood Avenue between Pershall Road and Latty
Avenue, and along McDonnell Boulevard between Byassee and Coldwater Creek. This
smdy was a follow-up to the 1985 DOE mobile gamma scanning listed previously.
• In 1990, in a report entitled Radiological Characterization Report for FUSRAP Properties in
the St. Louis, Missoxiri Area, Bechtel National, Inc. (BNI) stated that, based on subsurface
drilling and testing, “In general, radioactive contamination is present in some areas
underneath Latty Avenue, McDonnell Boulevard, and Pershall Road, and contamination
exists along both sides of Hazelwood Avenue and Pershall Road.”
• In 1991, the DOE conducted mobile ganuna scanning to detect anomahes. Anomalies were
detected on McDonnell Boulevard, Pershall Road, and Hazelwood Avenue.
2.2 METHODS OF POSSIBLE IMPACT
The possible sources of residues which may have impacted materials, which are now under
pavement, are hsted below.
• Residue from SLDS was placed at SLAPS from 1946 through 1959.
• Residue was hauled by tuck between the SLAPS and the HISS in 1966 and 1967.
• Fill material was brought by tmck from airport constmction projects to the SLAPS site and
the empty tmcks retumed to the airport m 1969 and 1970.
• Residue was hauled by tmck from the HISS to the West Lake Landfill in 1973.
• Storm water erosion from the SLAPS and the HISS site does not appear to have been
rigorously controlled. Aerial photographs from the early 1950s show tiie SLAPS drainage
ditches along interior roadways and around the stockpile areas, which discharge into
Coldwater Creek. Storm water would have carried residue into these ditches and then into
the Coldwater Creek floodplain.
• Wind erosion from the SLAPS and the HISS site does not appear to have been rigorously
controlled. The residues stored at the SLAPS were reported to be in piles 20 to 25 feet in
height, which would be higher than the surrounding terrain. The 20-foot height is given in a
June 13, 1991 document by U.S. Department of Health and Human Services. This document
states that “At the SLAPS site the uranium processing wastes were stored on open ground
and once covered two-thirds ofthe area to an estimated height of 20 feet.” A 25-foot height
is given in a 1959 memo as the height of a “Pitchblende Raffinate stockpile”.
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2.2.1 How Impacts May Have Been Caused By Truck Transportation
Some possible mechanisms for the loss of residue during transportation by tmck include, but are
not limited to, spillage from tmcks, dusting from driving at high speeds while hauling uncovered
residue, and falling of residue and residue contaminated earth from vehicle undercarriages, beds,
and wheels. Any areas adjoining traveled pavements not covered by other hard-surface
pavements might have been impacted.
A conceivable, but unlikely, mechanism for contamination, would involve mechanical
breakdowns or accidents involving the loaded tmcks. In the event of an accident or breakdown
of loaded vehicles, it is some times necessary for safety reasons that the load be dumped prior to
repairing or towing of the vehicle. Should one of these uncommon occurrences have occurred
involving a vehicle hauling residue if could have resulted in impact to areas on or near the
roadways used to transport residues.
2.2.2 Protection of the Materials Under Pavements From Direct Impacts
Hard-surface pavements should have shielded the materials directly beneath them from direct
impacts, while any areas adjoining hard-surface pavements (i.e., unpaved road shoulder and
nearby unpaved areas) could have been impacted. Hard-surface pavements are considered to be
Portland cement concrete (PCC) or batch-mixed and -placed asphaltic concrete (AC) pavement
of sufficient thickness to shield the material beneath. Oil-and-chip pavements, penetration AC
pavements, or seal-coat-over-aggregate pavements are not considered sufficiently durable or
nonporous to eliminate the potential for direct impacts to the material beneath them. Used in this
report , unless otherwise noted, AC refers to batch-mixed and -placed AC of sufficient thickness
and strength to prevent direct impacts to material beneath that pavement. Areas not covered with
hard surface pavements could have been impacted. Those areas could have subsequently been
paved as the result of new road constmction, rending the impacted material under the later
constmcted pavement inaccessible.
2.2.3 Low Probability of Occurrence Mechanisms that Could Result in Impacts Under
Road Pavements
There are several mechanisms that would result in impacts under otherwise impervious
pavements. Such mechanisms would include those described below.
Placement of new utilities. It is a common practice to place utility services within public rightof-
ways (ROWs) and sometimes under the road pavement. Such utility placement can resuh in
the removal of the existing pavement, trenching, backfilling, and replacement of the paved
surface. It is possible that the backfill material could be impacted material “borrowed” from
nearby road ROW or that the excavated material would be stored on impacted ground and
become impacted. Utilities could include, but would not be limited to, storm and sanitary
sewers, water, gas, electric, and communications lines. Boring, jacking, or other underground
tunneling methods could also be used to place such utilities. Therefore, any utility placement
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could have resulted in the movement of impacted material to locations that were previously
protected by pavement.
Repair of existing utilities. All utilities are subject to failure, and the repair and replacement of
failed utilities could have resulted in the placement of impacted materials to locations that were
previously protected by pavement. Water and sewer failures could also have resulted in the
movement of impacted material within the soil.
Structural failure of pavement, AC, or PCC. Such a failure could have allowed a route for
impacting agents to enter locations that are under the pavement. Also, the repair of stmctural
failures generally requires the removal and replacement of the existing surface and any failed
subgrade material. Pavement repairs could have resulted in the movement of possibly impacted
material to locations that were previously protected by pavement.
Pavement reconstruction. Impacts could have also resulted when an existing impervious
pavement was obliterated and a new pavement constmcted to replace it. The constmction
activities of demolishing and removing the old pavement, the regrading ofthe new subgrade, and
the constmction of the new pavement could have moved impacted material from Ihe former
shoulder area to beneath the new pavement.
While the mechanisms listed above could result in impacts to material located under otherwise
protective pavements, the conclusions of this report are based on the judgment that the chances
of such impacts are too low to justify additional testing of inaccessible material under substantial
pavemients. The material under such hard-surfaced and impermeable pavements is considered to
have been protected from direct impacts.
2.3 CONSIDERATIONS AND PROCEDURES
The purpose of this report is to identify those materials under currently existing pavements that
may have been impacted by residue lost during residue hauling activities, residues transported by
stormwater or wind erosion, and residues transported by stormwater flooding. This report
includes determmations for where the testing of materials under the pavement could find such
impacted material.
The conclusions ofthis report are based on the following considerations:
• Residues would not have directly impacted those areas protected by hard-surface pavements
prior to 1946.
• Pavements constmcted prior to 1966 would have protected the materials beneath them from
direct impacts from the 1966 and 1967 hauling activities between the SLAPS and the HISS.
• Pavements constincted after 1966, adjacent to tiie 1966 and 1967 tiie SLAPS-to-tiie-HISS
hauling routes could possibly have been placed over directly impacted materials.
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• Pavements constmcted after 1946 within the floodplain of Coldwater Creek downstream of
the SLAPS could possibly have been placed over materials impacted by residue transported
by water erosion and flooding.
Pavements constmcted after 1946 adjacent to the SLAPS could possibly have been placed
over materials impacted by residue transported by wind erosion.

2.4 HISTORICAL FIELD-TESTING
• In 1985, ORNL issued a report entitled Results of Mobile Gamma Scanning Activities in
Berkeley, Bridgeton, .andHazelwood, Missouri, which stated in part.”
“No anomalies were detected from the intersection of Pershall Road and Lindbergh
Boulevard, Lindbergh Boulevard to Natural Bridge Road (Highway 115), and Natural
Bridge Road to St. Charles Rock Road to the West Lake Landfill entrance. Also no
anomalies were detected on North Hanley from 1-270 to Airport Road, Airport Road,
Frost Avenue, and Eva Avenue. Anomalies were detected on McDonnell Boulevard,
south side, from Coldwater Creek to the intersection of Norfolk Southern Railroad
crossing and on the north side of McDonnell Boulevard from the Berkeley city limits to
Trumbell Asphalt sign near Byassee Road. Anomalies were detected along Pershall
Road, south side, from the Ford Motor Company, new car parking area, to just past
Poison Lane and on the north side of Pershall Road. Anomalies were also detected on
Hazelwood Avenue, mainly on the west side of the street, in front of Wetterau Perishable
Center approximately 115 feet south from the railroad crossing of Latty Avenue and one
spot on the west side of Hazelwood Avenue”.
• In 1986, ORNL issued another report, entitled Results ofthe Radiation Measurement Taken
of Transportation Routes (LM004) in Hazelwood, Missouri. This report identified
concentrations of higher-than-background radiation readmgs on McDonnell Boulevard
between Coldwater Creek and Byassee Road, on Hazelwood Avenue north of Latty Avenue,
and on Pershall Road between Poison Road and Lindbergh Boulevard. These were the only
routes surveyed for this report.
• In 1990, in a report entitled Radiological Characterization Report for FUSRAP Properties in
the St. Louis, Missouri Area, Bechtel National, Inc. stated that, based on subsurface drilling
and testing, “In general, radioactive contamination is present in some areas underneath Latty
Avenue, McDonnell Boulevard, and Pershall Road, and contamination exists along both
sides of Hazelwood Avenue and Pershall Road.”
• In 1991 DOE conducted mobile gamma scanning surveys to detect any anomalies associated
with the transportation routes around the SLAPS. The following roads near the SLAPS were
scanned:
St. Charles Rock Road from Fee Fee Road to Taussig Road
Fee Fee Road from St. Charles Rock Road to McDonnell Boulevard
Taussig Road from St. Charles Rock Road to Gist Road
Gist Road from Taussig Road to Garret Road
Garret Road from Gist Road to Missouri Bottom Road
Natural Bridge Road from St. Charles Rock Road to Lindbergh Boulevard
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Lindbergh Boulevard from Natural Bridge Road to McDonnell Boulevard
Banshee Road from Lindbergh Boulevard to McDonnell Boulevard
McDonnell Boulevard from Lindbergh Boulevard to Airport Road
McDonnell Boulevard from Fee Fee Road to Dunn Road
Dunn Road from McDonnell Boulevard to Lindbergh Boulevard
Pershall Road from Lindbergh Boulevard to North Hanley Road
North Hanley Road from Dunn Road to Airport Road
Airport Road from North Hanley Road to McDonnell Boulevard
Eva Avenue from McDormell Boulevard to Frost Avenue
Hazelwood Avenue from Frost Avenue to Pershall Road
Frost Avenue from Eva Avenue to North Hanley Road
Latty Avenue from the HISS to North Hanley Road
The results were issued in a report titled Results of Mobile Gamma Scanning Activities in
St. Louis, Missouri. ORNL. This report also collected results from and discussed all of the prior
mobile gamma scanning testing activities. Figures illustrating the roads, which were scanned,
are reproduced as Figures 2-1, 2-2, and 2-3. Figure 2-1 shows the general location of the
Mallinckrodt Chemical Plant and the SLAPS, the HISS, and West Lake Landfill storage sites,
St. Louis, Missouri. Figure 2-2 is a diagram of routes scanned in the vicinity ofthe MalUnckrodt
Chemical Plant site, St. Louis, Missouri. Figure 2-3 is a diagram of routes scanned by ORNL and
routes characterized by BNI. in the vicinity of the Lambert-St. Louis Intemational Airport, St.
Louis, Missouri.
• This survey found no anomahes on the suspected haul routes in the vicinity of the
Mallinckrodt plant that could not be explained by factors other than haulage activities. The
survey found impacts along Latty Avenue from the HISS to Graham Road and confirmed the
impacts found along other haul routes in past surveys.
2.4.1 Results Of Initial Testing Under Roads
At least 1,632 samples have been collected in areas that are in or near existing road pavements.
Of these, 127 have individual test results exceeding remediation goals proposed in the Record of
Decision for umestricted release. These points are shown on the drawings contained in the
appendices. These data were obtained from the FUSRAP primary sample database and represent
the test results from many sources compiled into a common elecfronic format.
Figure 2-4 shows the roadways in or around which residue has been detected that may exceed
remediation goals in the proposed Record of Decision.
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Figure 2-1 General Location of the Mallinckrodt Chemical Plant and the SLAPS, HISS,
and West Lake Landfill Storage Sites in St. Louis, Missouri
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Figure 2-2 Diagram of Route Scanned in the Vicinity of the Mallinckrodt Chemical
Plant Site, St. Louis, Missouri
^
0»(LFOiW09Ml2S7
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Figure 2-3 Diagram of Routes Scanned by Oak Ridge National Laboratory and Routes
Characterized by Bechtel National, Inc. in the Vicinity of the Lambert-St.
Louis International Airport, St. Louis, Missouri
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2.5 HAUL ROUTES BETWEEN THE SLAPS AND THE HISS/FUTURA SITE
In fransporting residue between the SLAPS and the HISS, the probable roads fraveled include
Eva Avenue, Hazelwood Avenue, Latty Avenue, Frost Avenue, 1-270, Lindbergh Boulevard
(also known as (aka) Highway 66/67), McDonnell Boulevard (aka Brown Road, State Route TT
or STT), Pershall Road (aka 1-270 Soutii Outer Road), Dunn Road (aka 1-270 Nortii Outer Road),
Graham Road (aka North Hanley Road), and Airport Road.
While there are many potential routes to get from one site to the other, the most direct route
involves a portion of McDonnell Boulevard from the SLAPS to Eva Avenue, Eva Avenue to
Frost Avenue, Frost Avenue to Hazelwood Avenue, Hazelwood Avenue to Latty Avenue, and
Latty Avenue to the HISS (Route A). Route A is illustrated in Figure 2-5.
The photographic information examined shows evidence of wear consistent with heavy tmck
hauling on Eva, Frost and Latty avenues during the period consistent with the 1966 and 1967
haulmg activities between the SLAPS and the HISS. It seems likely that the greatest potential
for impacts would have occurred along the route described above. Reports from eyewitnesses to
the hauling activities indicate that the tmcks did use this route, except during periods of wet
weather.
When the hauling activities did not use Route A, because of weather-related effects on the
hauling roads, train traffic blocking the Frost Avenue crossing, or some other reason, other
possible routes might have included those listed below. Since Eva Avenue and part of Frost
Avenue were unimproved dirt roads at that time, they may not have been passable in times of
prolonged wet weatiier.
• Route B – McDonnell Boulevard to Lindbergh Boulevard, Lindbergh Boulevard to Pershall
Road, Pershall Road to Hazelwood Avenue, Hazelwood Avenue to Latty Avenue. This route
is illustrated in Figure 2-6.
• Route C – McDonnell Boulevard to Lindbergh Boulevard, Lindbergh Boulevard to Pershall
Road, Pershall Road to Graham Road, Graham Road to Latty Avenue. This route is
illusfrated in Figure 2-7.
• Route D – McDonnell Boulevard to Lindbergh Boulevard, Lindbergh Boulevard to 1-270,
1-270 to Graham Road, Graham Road to Latty Avenue. This route is illustrated in
Figure 2-8.
• Route E – McDonnell Boulevard to Airport Road, Airport Road to Graham Road, Graham
Road to Frost Avenue, Hazelwood Avenue to Latty Avenue. This route is illustrated in
Figure 2-9.
• Route F – McDonnell Boulevard to Airport Road, Airport Road to Graham Road, Graham
Road to Latty Avenue. This route is illusfrated in Figure 2-10.
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1-270 r
[
/ • ^ PERSHALL RDAD-
|ui
HAZEL VDDD
AVE.
LATTY AVE.
LATTY
AVE.
LINDBERGH BLVD.
MCDONNELL BLVD.

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North St. Louis County Haul Road Analysis and Justification for Additional Investigation-Evaluation of
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2.5.1 Evaluation of Haul Routes Between the SLAPS and the HISS
It is the conclusion of this report that Route A would have been the most heavily used route. If
Route A were not available, then Route B would be the next most reasonable route. Routes E
and F were also reasonable routes; however, there are constmction plans, completed in July
1966, for a major reconstmction of Airport Road. It is our judgment that this work would have
been placed out for bid in 1966 or 1967, making it likely that Airport Road was vmder
constmction when the SLAPS to the HISS haulage activities occurred. Residue hauling could
have used Airport Road before constmction started, during the Airport Road reconstmction, or
after constmction was finished. However, this use would be considered less likely than the use
of Route B. Routes C and D cannot be mled out but appear to offer no advantage over shorter
routes. Impacts have been found on Latty Avenue east of Hazelwood Avenue. For such impacts
to have occurred some haulage would have had to use Routes C or F. Table 2-1 compares routes
A through F.
Table 2-1 Comparison of Haul Routes Between the SLAPS and the HISS
ROUTE
Route A
Route B
Route C
Route D
Route E
Route F
LENGTH
2.15 miles
3.60 miles
4.33 miles
4.38 miles
3.28 miles
3.44 miles
COMMENTS
Most direct route
A reasonable route
No known advantage over shorter routes.
No known advantage over shorter routes.
A reasonable route. However, Airport Road believed to be under construction 1966 to
1967.
A reasonable route. However, Airport Road believed to be under construction 1966 to
1967
2.5.2 Methods for Transporting Residues Between the SLAPS and the HISS
According to an August 15, 1967 memo titied Historical Review ofthe Mallinckrodt Airport
Cake, beUeved to be from the Congress of the United States, House of Representatives,
Committee for Public Works and Transportation, Science and Technology, the residues were
moved from the SLAPS to the HISS by Continental Mining and Milling of Chicago, Illinois.
This move required ten dump tmcks for five months and cost Continental $100,000.
In a bid dated December 27, 1965, from Braun Excavating Company (Braun) to Contemporary
and Continental, Braun made the following statement:
The unit price quoted includes loading of material into tmcks at the existing stockpile
area, transporting same to the new stockpile area, unloading and stockpiling. We
anticipate washing down the tmck wheels before entering the pubhc road, utilizing the
existing wash facilities at the BroAvn Road location. We fiirther anticipate the necessity
of keeping a bulldozer and operator at the General Electric plant site to stockpile the
material as it is dumped, and the second washing down of the tmck wheels before again
entering the road.
Items which we have not included in our Per Ton price quotation, and which are to be
bome by other, are as follows:
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a. Tmck washing facilities at both present and future stockpile areas.
b. Water used for washing tmcks.
c. Additional hazard insurance coverage over and above our present
standard workman’s compensation, and comprehensive liabihty
coverage.
d. Required periodic medical examinations, special wearing apparel, etc.,
for employees.
e. Weighting facilities for tmcks at either location, and wages for scale
man.
f. Any special material, such as wax paper, oil, sand, etc., required to
facilitate dumping of material from tmcks.
g. Facilities to be used by employees for washing, showering, and changing
of apparel.
It is likely that the acmal haulmg activities in 1966 and 1967 were conducted using methods
similar to the above. The residue would have been carried in over-the-road dump tracks.
Loading of the tracks would have been by portable conveyor system or front-end loader. Either
method would have produced dust.
Braun’s bid price for this work was $1.25 per ton. The confractor who actually performed this
work m 1967 for Continental was paid $100,000, which would be approximately $0.85 per ton.
It is believed that the tracks used would have been 20-ton dump tracks, similar to the one shown
in Illusfration 2.1; however, no documented evidence conceming the acmal type of equipment
used, other than that the equipment used for transport was “dump tracks”, has been located to
date.
An indication ofthe level of dust control expected in this work in the mid-1960s comes from a
United States Memorandum dated July 25, 1967, entitled Requirements for Surface Cleanup of
the Airport Site, which states
…the following should be considered the general plan for decontamination, which the
Airport Commission will be required to follow. It is noted that none of the clean-up
operations are of such nature to require film badging or protective precautions other than
ordinary personal hygiene practices. All tmcking operations shall be conducted in a
manner to assure minimum dusting. This can be easily accomphshed by wetting down
tmckloads prior to departure.
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North St. Louis County Haul Road Analysis and Justification for Additional Investigation-Evaluation of
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Illustration 2.1
^ ^ 1 Si
* ” .:
am*
m
: • • • ‘ ^ ^ ^ v r #]
p – ^ . . :•%, –
•”**~~’»s««^’gg;’-_-.~-yt^’
JlfiilraiTi^rieweg Photo >-
&.1
. . . . . . . -‘t
-‘i:-‘*., .-A. Y*
.„!» a., t – ‘ -^ ri
…… viTJ- ^’H
l\?s l ^ ‘ * M * i p J i i ^ ~
“¥’ ;-•: •
J
1 , i
” J ‘
^ V ^ ^ ^ ^ ^ H
. . ‘ . . • • ‘
– – * – ‘ . – * • » • ‘ , ‘ . ^.
Typical 1960 20-Ton Over-the-Road Dump Truck
The information available indicates that the hauling of materials from the SLAPS to the HISS
required 10 dump trucks for a period of five months. A typical 1960 era 20-ton dump tmck is
shown in Illustration 2.1 above. This type of truck has a bed capacity of 12 cubic yards. Dry
loose earth has a typical weight of 2,000 pounds per cubic yard. Heavy wet mud has a typical
weight of 3,000 pounds per cubic yard. Assuming a weight for the residue of 2,500 pounds and
that each truck was loaded with 12 yards of material would mean that each tmck load would
carry about 15 tons of material. The trucks would need to be heaped to carry the 20 tons
capacity. It is common practice for each truck to carry the maximum possible load. If the
material were heaped it would increase the chance of dusting and spillage from the truck bed. To
move the 120,000 tons of residue would have required between 6,000 and 8,000 trips.
2.5.3 Conclusions
The primary means of transport of residue between the SLAPS and the HISS was by means of
dump trucks. The most probable route for transport of residues between the SLAPS and the
HISS was Route A, from the SLAPs to McDonnell Boulevard to Eva Avenue, Eva Avenue to
Frost Avenue to Hazelwood Avenue, Hazelwood Avenue to Latty Avenue as shown in Figure 2-
5. However, Routes B, E, and F, as shown in Figures 2-6, 2-9 and 2-10, were also used. These
routes appear to have offered the quickest and most economical routes between the SLAPS and
the HISS in 1966 and 1967.
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McDonnell Boulevard must have been used as a haul route. McDonnell Boulevard is the only
road access to the SLAPS.
Lindbergh Boulevard must have been used as a haul route, since impacts have been fotmd on
McDonnell Boulevard west of Coldwater Creek. The impacted areas on McDonnell Boulevard
cannot be explained by wind or stormwater action. The impacts must be the result of haulage
activities. Lindbergh Boulevard has tmdergone extensive widening and reconstmctions since
that time and any impacts to the shoulders in 1967 or earlier would now be under pavement.
Graham Road must also have been used as a haul road, since impacts have been fotmd along
portions of Latty Avenue east of Hazelwood Avenue. The impacted areas on Latty Avenue east
of Hazelwood Avenue cannot be explained by wind or stormwater action and must be the result
of haulage activities. This haulage activity must have occmred as part ofthe 1966 and 1967
haulage of residues from the SLAPS to the HISS. There are two possible routes from the SLAPS
to the HISS involving Graham Road. One route would have entered Graham Road from 1-270 or
Pershall Road and proceeded south on Graham Road. This portion on Graham Road has been
obliterated and been totally reconstmcted as the much wider North Hanley Road. Any impacts
to the shoulders of Graham Road in 1967, where it has been replaced with North Hanley Road,
would now be imder the North Hanley Road pavement.
The second route would use Graham Road by way of Airport Road and proceed north on
Graham Road. Airport Road was tmdergoing reconstmction in 1966 and 1967 and would have
likely been an tmdesirable haul route because of the constmction-related delays likely to be
encoimtered in the use ofthis route. A portion ofthe pre-North Hanley/Graham Road pavement
is still m existence. The portion in existence also contains the location of a former raihoad
crossmg ofthe Norfolk Southem mainline.
2.6 RESEARCH SUMMARY
Documents were obtained and reviewed from a number of sources. Among the records reviewed
were aerial photographs, constmction plans, road maintenance records, county tax records,
highway maps. United States Geological Survey (USGS) quad maps, and historical documents.
One key document was a 1992 United States Envirormiental Protection Agency (EPA)
Region VII smdy entitled Aerial Photographic Analysis of the St. Louis Airport Study Area,
Hazelwood, Missouri. This document contains a collection of aerial photographs from the years
1941, 1953, 1965, 1971, 1974, 1980, 1984, 1985, and 1990 showing tiie HISS and tiie SLAPS
and some ofthe surrounding roads. Each photograph is accompanied by an analysis ofthe work
being done on or around the sites at each particular time. These photographs of the sites were
indispensable in determining what had occurred on the roads over time. While these
photographs provide excellent coverage ofthe roads immediately adjacent to the SLAPS and the
HISS, they do not always extend far enough to cover Route 67 (aka Lindbergh Boulevard),
Airport Road, North Hanley Road, or 1-270. In addition, the scale of the photographs is very
large, with 1 inch equal to 1,000 feet and 1 inch equal to 2,000 feet being the most common.
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This large scale made it difficuh to determine with certainty the condition and type of the road
surface.
Additional aerial photographs were obtained from St. Louis County. These aerial photographs
were 1 inch equal to 200 feet or 1 mch equal to 400 feet in scale. St. Louis Coimty has aerial
photographs available from 1966, 1981, 1985, 1990, 1993, 1995, and 1997. The 1966 (1 inch
equal to 200 feet) and 1997 (1 inch equal to 400 feet) photographs were copied and reviewed for
the purposes of this report. The other photographs were from periods in which other coverage
was available or covered times of lesser interest and, therefore, were not purchased for review.
Aerial photographs were also obtained in electronic form from Surdex Corporation, a St. Louisbased
aerial photogrammetry firm. These photographs were from 1965, 1971, 1973, 1975, and
1997. The figures included in the appendices use the 1997 aerial photographs as background and
also show the outiine ofthe pavement from the 1965 photographs.
All of these aerial photographs were used to determine what generally occurred on the roadways
over time. The interpretation of this type of information is, by necessity, subjective. The
photographic data available for review is hsted m Table 2-2.
Constmction plans and maintenance records provide more objective and detailed information to
supplement the interpretation of the aerial photographs. The dates available are from the fiscal
year m which the projects were fimded for constmction, and those are the dates used in this
report. The actual date of constmction might be as many as several years later. The infomiation
from the constmction and maintenance records was used in preference to the aerial photographs
wherever possible; however, for some ofthe roads, the aerial photographs were the only records
available. Those aerial photographs available are listed in Table 2-2.
Table 2-2 Aerial Photographs Available
YEAR
1941
1953
1958
1965
1965
1966
1971
1971
1973
1974
1975
1980
SCALE
1:11000
1:20,350
1:10,895
CADD
1:11,110
1:2400
1:10,825
CADD
CADD
1:12,115
CADD
1:7,777
USED
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
No
Yes
SOURCE
1992 EPA Study
1992 EPA Study
1992 EPA Study
Surdex Coiporation
1992 EPA Study
St. Louis County
1992 EPA Study
Surdex Corporation
Surdex Corporation
1992 EPA Study
Surdex Corporation
1992 EPA Study
COMMENTS
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Table 2-2 Aerial Photographs Available (Cont’d)
YEAR
1981
1984
1985
1985
1990
1993
1995
1997
1997
SCALE
1:4800
1:6,060
1:8,290
1:4800
1:4800
1:4800
1:4800
1:4800
CADD
USED
No
Yes
Yes
No
No
No
No
Yes
Yes
SOURCE
St. Louis County
1992 EPA Study
1992 EPA Study
St. Louis County
St. Louis County
St. Louis County
St. Louis County
St. Louis County
Surdex Corporation
COMMENTS
Color Photograph
Believed same as Surdex CADD below
For those roadways that are part ofthe state of Missouri highway system (e.g., 1-170, 1-270,
(1-270 includes Dimn Road as the north outer road and Pershall Road as the south outer road),
Lindbergh Boulevard (State Route 67), and McDonnell Boulevard (State Route TT), a key
resource was the Missouri Department of Transportation (MoDOT) pavement history drawings.
These drawings show the project year and type of road surface constmcted. Equally important,
they provide the constmction project number, which is the key to MoDOT’s microfilm system of
the old constmction plans for those highways. Only selected constmction plans were obtained
for this report, but should a greater level of detail be desired in the fiiture, additional plans are
available.
The pavement history drawings obtained from MoDOT were as follows:
096 St. Louis Sheet 8 of 31 covermg 1-170
096 St. Louis Sheet 11 of 31 covering Lindbergh Boulevard (State Route 67)
096 St. Louis Sheet 20 of 31 covermg 1-270
096 St. Louis Sheet 25 of 31 covering McDonnell Boulevard (State Route TT)
Selected highway constmction plans were obtained for portions of 1-170, Lindbergh Boulevard,
1-270, Pershall Road, and McDonnell Boulevard. Additional details of the plans reviewed are
provided in the appendices with the associated roads. These plans were also used to help
determine the ROW widths and whether fill was placed on impacted material.
Selected St. Louis County Land Information Services maps were also obtained. These
computer-aided design and drafting (CADD) drawings are at a 1-inch equal to 400 feet scale and
show street and road ROWs and property boundaries of all parcels. They also list the St. Louis
County Locator Number for each parcel. With the locator number, the owner of record, last
recorded deed, zoning, and other information can be obtained from the St. Louis County Web
site. The reliability ofthe information from the county tax assessor’s office, however, must be
considered low. The assessor’s office makes no warranty as to its accuracy, and the quality
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assurance of the input of this mformation is poor. For certainty in property boundary-line
location, a registered land surveyor, using the latest property boundary description of record,
surveyed property monument locations, and the historical chain of title for that parcel, should
locate boundary and ROW lines in the field. The maps obtained were Map Panels 9-K, 9-L,
10-K, 10-L,11-K, and 11-L.
In addition, selected tax assessor’s maps were obtained. These hand-drawn and hand-updated
drawings are at various scales, with 1 mch equal to 150 feet being the most common. These
drawings have the dimensions ofthe property boundary lines, acreages, coimty location number,
record owner, existmg buildings and pavements, and recording information of deeds or plats.
The quality assurance of these records is also poor, but they do provide some additional
information. These linens are quite old, and some times provide a historical record of what
might have occurred on a parcel over time. These drawings certainly predate any work at the
SLAPS or the HISS. The panels obtained were Map Numbers Ferguson-Florissant R-2 6, 7 and
Hazelwood 237,238, 245,247b, 249,250.
Historical highway maps were obtained from the COE. The maps obtained were dated 1952,
1965, and 1976.
Historical mapping from the USGS reviewed included the maps hsted below. Figure 2-11 shows
the six USGS quadrants of primary interest.
29
w:Vremedial designVroad researchVnc road study – fmalVfinal pavement report l-7-05.doc Final

1/7/2005
North St. Louis County Haul Road Analysis and Justification for Additional Investigation-Evaluation of
Inaccessible Materials Beneath Pavements
Clayton Quad Map
1941 (photographed 1933)
1941
1954
1954 (photograph revised 1968)
1954 (photograph revised 1968 and 1974)
Columbia Bottoms Quad Map
1935 (photographed 1924)
1941 (pubhshed 1952) ‘
1941 (pubhshed 1959)
Granite City Quad Map
1940 (photographed 1933)
1950 (photographed 1949)
1956
1954 (photographed 1952; published 1958)
1954 (photographed 1952; pubhshed 1966)
St. Charles Quad Map
1933 (photographed 1927)
1947 (photographed 1927; revised 1946)
1955 (revised 1946).
1960 (photographed 1952)
1969 (photographed 1952; revised 1968)
1975 (photographed 1968)
1986 (photographed 1974)
roll 079, frame 321
roll 079, frame 322
roll 229, frame 075
roll 079, frame 319
roll 079, frame 318
roll 079, fi^me 364
roll 079, frame 363
roll 079, frame 361
roll 059, fi-ame 216
roll 059, frame 214
roll 059, fiame 213
roll 059, frame 212
roll 059, frame 211
roll 082,
roll 082,
roll 082,
roll 082,
roll 082,
roll 229,
roll 229,
frame 178
firame 177
frame 176
fiame 175
frame 169
frame 378
fiame 377
Creve Coeur Quad Map
1940 (photographed 1933)
1956 (photographed 1933; revised 1954)
1959 (photographed 1952)
1966 (photographed 1952; revised 1965)
1969 (photographed 1968)
1976 (photographed 1974)
roll 079, frame 385
roll 079, frame 386
roll 079, frame 383
roll 082, frame 175
roll082, fi:amel69
roll 229, frame 378
31
w:Vremedial designVroad researchVnc road study – finalVfinal pavement report l-7-05.doc Final
1/7/2005
North St. Louis County Haul Road Analysis and Justification for Additional Investigation-Evaluation of
Inaccessible Materials Beneath Pavements
Florissant Quad Map
1954 (photographed 1952) roll 080, frame 053
1966 ^photographed 1952; revised 1954) roll 080, frame 052
1968 (photographed 1968) roll 080, frame 051
1975 (photographed 1974) roll 229, fiame 134
1982 (photographed 1979) roll 385, frame 041
Many documents were reviewed during the preparation ofthis report. Those documents found to
be most pertinent are hsted in Appendix A.15.
32
w:Vremedial designVroad researchVnc road study – fmalVfmal pavement report 1 -7-05.doc Final
1/7/2005
North St. Louis County Haul Road Analysis and Justification for Additional Investigation-Evaluation of
Inaccessible Materials Beneath Pavements
3.0 SUMMARY OF POTENTIAL IMPACTS BY ROADS
3.1 SUMMARY OF RESULTS OF HISTORICAL TESTING
Testing has identified impacted material adjoining several suspected haul roads. This testing has
also found evidence of impacts believed to be associated with erosion of the SLAPS and
flooding of Coldwater Creek and also with wind and storm water erosion. Based on the results
of all scanning information report

Post

1988-12 – DOE – Hazard Assessment for Exposure to Radioactive Fill Dirt Use for the Parking Ramp of the St. Louis Airport Parking Garage

. ·.

O.S. nepartment of Enerqy
oat Ridge Operations
Post Office Box 2001
Oak Ridg~, TN l78)1-8723
‘ · . .
OSS609
Dsil831
Bechtel National. Inc.
S…..~s-~~ ~~
~fill= Taa: .
ICIO Ota “-TwrfiOiiU .
O*IW;Llec•erM ~7130
.,….._,. . .D..lf.l nI 0 … act 0-~ l’lr J)UI OJ50
~~· l –
Attention: Andrew P. A vel, Site ~tanager
Technical ServicGs Division
Subject: Bechtel Job No. 14501, PUSRAP Project
DO! eontract No. DE-ACOS-810R20722
Hazard Assessment for Exposure to Pill Dirt used for the
Parkinq Ramp of th& St. Louis Airport Parkinq Garaqe.
Code: 7340/WBS: 134
Ref~rence: National Council on Radiation Protection an~ .
Measurements, Exposure of the Population ln the United
States and Canada fro~ Natural Back9round Radiation,
Bethesaa, MD, Decemher ~~~ 1987. .
Dear Mr. Avel:
In response to your request, a hazard assessment usjnq conservative
assumptions was developed for workers performing activities {n the
vicinity of the St. Lou!s Airport Site (SLAPS) (see Enclosure A).
The hazards to a laborer and truck rlriver involved tn lnad1n9 and
hauling the conta~inated soil to the ramp site and to a potential
road vorker performinq rP.pairs on th• ramp slopes was assessed for
radiation ~xposure to the contaminated soil taken fr~M Coldvater
Creek bed. The methodoloqy and parameters for the dose
calculations and tahles of the dos~s are shown in Enclosure A.
!~ su~~ary, the maximum dose to a laborer loadinq the soil was
estiaated to be 0.16 nrem, and the maximua rlose to the truck driver
haul i ng the soil to the ramp slte w.as estiruted to l’\~ O, 12 mre”.
The doses were fro• external gamma only since the soil was wet and
no airborne activity was likely. The total dose to the road ~orker
engaged in making repairs on the ra~p ~as estimated to be
0.42 mrem, a total of the cofthined ext~rnal qaftma and inhalation
doses. ~he hi9hest dose of 0.42 mre~ to any of tho ~orkers is ~nly
0.42\ of th~ DOE basic limit of 100 mrem for the ~nnual radiation
dose receiv~d by an indivioual ~e~her of the qeneral puhlie and
only about 0.14\ of the normal back9roun~ ra~ ia tion of JOO mrem/yr
for the area freferencP.d above).
058509 ouen
Andrew P. Avel 2
Since the conservative estimate ot the doses ~o the workers are
vell belov the DO! radiation protection standard, th~re is no
hazarc! to personnel who may coJle tn contact w~i th the ·tamp or to the
general public in leavinq the fill material in place. I
CRH:djw:89l4A
Enclosure: ~ stated
Very truly yours,
I
~~ .I
S. o. Liedle
Project Manager – PUSRAP
I
. . ”
nssoo9
BEHIND lHIS SHEET
IS TSD BACKUP ·
MATERIAL FOR FlllNG
PURPOSES ONLY – NOT
TO BE DiSTRIBUTED
878CIA
050609 oseen
. ENCLOSURE A
t. EXPOSURE SCENARIOS
I
A. Lab_Q,Jer f.temovi ng soil From Coldwater ‘1 creek
lt is assumed that the laborer s?ent1one week (40 hours)
during the year removing the soil tojbe used as fill dirt
from the ereek be~. lt is conservatively assumed he was
1 standinq on the c:ontamina ted soi 1 dur tnCJ. the soil removal,
thus if he was usinq a mechanical loader no shieldin9
factors for reducing the exposure rate ~as taken into
consideration. Since tho soil was wet, an inhalation dose
due to airborne dust particles was not considered li~ely.
B. Trucker Hauling the Soll from Coldwater creek to the Ai re.ort
Pa!kinq Garage Ramp {A Distance of three miles)
1
PI
It. is assumed that the trucker spent! 30 hours exposed to the
contaminated soil while the truck wak being loaded ond
I
enroute to the ramp •. No shiP.ldinq factors wer~ considered.
I
Thus, his dose ~oul~ be three-fourths that of the laborer.
I
SincP. the soil is wet or damp# no in~alation dose is
considered likely.
c. Road Worker tlorkinq_on the Ramp
8914A
12/23/88
It is assumed that the worker spends 40 hours during the
year workin9 on the ramp slo~e repai1ring drainage, etc. 1t
iR also assumeo that the ~or~er is e~posed to dry soil that
I
would beco~e airborne durin9 excavation. A maximu~ mass
loading factor of 4 x 10 -4 g/m 3 ~as pI sed to estt•m ate th e
air concentr~tion of resuspenderi con~aminate~ dust particles.
t t • SOURCE TERMS .
The source terms used for dose calculations are the avera9e
concentration of the radionuclides in th• top foot of soil
~aken neat the bridge over coldwater creek at Menonnel
Boulevar
Dose Conversion Paelors
Radionu.clide
Uranium-234
Oraniuii-23S
Urantum-238
Rad·i um-226
Thorium-230
‘:’horiura-232
External Dose
(mrem/ yr eer pCi/?J
l, 4 0 X 10-3
~ ,4 4 X 10-l
1.30 X 10-l
1.58 X 101
1.90 X 10-l
1.26 X 10-l
in area
2. Methodolo9y for caleulatin9 external ~am~a dose
(Ref. l)
Dose fmrem/yr) ~ {concentration of radionuclide in soil
( pCi /g) (depth factor J ·{a rea factor 1 (occupancy factor)
[dose conve~sion factor (~r~m/yr per pCi/g))
4 —————————- –· -· .. – – ·-
1111!1111——— -·-“”• ·.· ·.. ….. – =–7″” · ·- •.• •.- . ·.. “. .. .. .. l .:. ; . –·–.- ~ .. ; .. –. ;-,”, ,”.;:·-~ ,,. ..- · ..;: . ·.. ·.~ … · ::-~ ..


osa;).-og
! asees,
IV. Ma:Jt isua Dos& to -Workers
89l4A
12/23/88
‘l’ABLt 1
TOTAL DOSE tO LABORE~ REMOVING SOIL
FROM COLDWATER CREEK !.
Radionuclide
Uranium-214
uranium-235
Uranium-238-
Radium-226
· ‘I’horium-230
‘I’horium-232
Total
I External Gamma Dose
(mreuVyr)
TAElLE 2
TOTAL DOSE ‘1’0 TRUCKER HMJ!.l Nq SOIL
TO R””‘P Sl ‘t’E
Radionuclide
uranium-234
uranium-23S
uranium-238
Radium-226
Thorium-230
Thor i um-2 l 2
Total
External damma Dos~
(mrerit/yr)
s
2.8 X lo-S
1. 2 x lo-4
2. G x , 1o-l
1.2 x lo-1
2.1 x lo-4
5.1 X 10-6
1.2 x 1o-1


1
•• ,., • , I , • • •• • ,; ~ ,,l) •. •. • : • • , •, i , • • . • \~’I t’ , • … \
IV.. Mil”inm Dose to Workers
89l4A
12/23/88
‘l’ABLf! l
TO’rAL DOSE TO LABORER REMOVING SOIL
PROM COLDwATeR C~£2K
External Ga1!una Dose
Ridionuclide Cmr~m/yr)
Urartium-234 1.8 X 1o·S
uraniura-235 4.3 X 1o·t
Uranium-238 3.5 X 1o-J
Radium-22’6 1.6 X 1o·l
Thorium-230 3.7 X lQ-4
Tho ri Utn• 2 3 2 7.0 X 1o·6
Tota! l.6 X 1o-1
TABLE 2
“TOTAL DOSE TO TRUCKER HAUi..lNC SO[L
‘t’O RAMP SI’l’E
External Gamma
Rad ionucll de (mrem/yr)
Uranium-234 2 •. 8 X lo-s
Uranium-23S l. 2 X Io-4
Uranium-23B 2.6 X 1o-l
Radiuaa·226 1.2 X 1o-1
Thor ium-230 2.7 X l0-4
Thorium-232 S.l X 1o-6
Total l.2 X 1o-1
5
nose



Radion\lelide
Ot’anium-234
tJraniutrt•23S
or ani um-238
Radium-226
Thodum-230
Thocium-232
‘rotal•
05S609
TABLE 3
TO!AL DOSE TO ROAD WORKER ~!PAIRING
SLOPE OF GAJtAG£ RAMP
£x~ernal Gal!lla nose Inhalation oose
(mr~r.t/yr) (mrem/yrl
3.8 I lo-s 1.2 X to-2
4.l X lo-4 1.9 X l0-4
l.S X 1o-J 1.1 X l0-2
1.6 X 1o-1 2.9 X to·4
l. 7 X lo-4 2.1 X to·l
7,0 X 10-6 l.O X l0-2
1.6 X 1o-1 2.6 X to·l
•rhe combined dose from external gamma and i nhalation
a 4.2 z lo-1 ~rem/yr.
891~”
12/21/88


OS86D9
1’ABLE 3
TOTAL DOSE TO ROAD WORKER REPAIRING
SLOPE OF CARAGE RAMP

Ext~tfi&l Gllnl!ta Dose Inhalation oose
Radionuelide Cmrei”‘\/yr) {lfttem/yr)
uranium-23ot
uraniu~n-2l5
oranhull·238
Radium·226
Thorium-230
Thorium-232
l.S .x
4.3 X
3.5 X
1.6 X
3.7 X
7.0 X
lo-s 1.2 X
lo-4 1.9 X
10•.3 l.l X
1o-1 2.9 X
lo-4 2.1 X
lo-‘ l.O X
Total* 1.6 X 1o-1 2.6 X
*Tne eo~ined dose from external 9am~ and inhal~tlon
· • 4.2 :r lo-l mrera/yr.
8914A
12/23/88
l0-2
10_,
l0-2
lo-4
l0-1
lQ-2
l0-1
..


I .
05I 81.\ ng ~
Qt~~wnas a •
1. GiltH!rt, ‘r. L., et at. A Manual for Impller~ent.inCJ Residual
Radioactive Material CUid~lines, Washington, D.c.,
I
Jan&l~tY 1988 (In press). A Sllpplement to o.s. Department of
Ener9y Guidelines for Residu~l Radioact iJitr at Formerly ·
2tili:ed Sitea Remedial Action Program arid Renote surplus
Paeilities Manageme~t Pro9ran Sites •
89l4A
l:l/23/&S
..,

Post

1989-01-20 – DOE – Radiologically contaminated soil beneath a parking garage ramp at the Lambert International Airport

Mr. To• Richter
St. Louts Airport AuthGrity
P.O. Bo• 10212
~rt suttc;n
St. Louts. MD 63145
DMr “”. Richter: ·
D 1~ IIDWit of Etwgy
OMRJdteO,.a..,.
– ,,O.IMDI
_OR Riclte. T……….., m31-8723
January 20. 1989
CONTAMittAT£8 SOIL BENEATH PARllll& WAG£ RAIIP
Tbe purpose of uats letter ts to dtscuss racUo)ottcallr contam1~ted son
…_atb a OU’k1ftt tarave ramp at the L.uMrt lnternat1ona1 Atf’IM)rt. The son
was ,.., .. ., fr. 1 State c011struct1Gft project •tar the St. l.Gu1s Airport
Stonee Site (SLAPS) wMcb vas suspeeted to be contlfl1nated vittl lw levels
of thort … 230. Tbts son vas trlDSported to the 11T’I)Ort tenatn~l lr”tl vtaere
tt w.s asM as ftll dur1ft9 recent construct1on of a parting garage “”‘· The
analys1s of ~les takeo at the Dlrk,ng gerate ranp durtnt construct1oa
conftnlld that levels of thor1~230 were s11tht1y above DOE’s cleinup ·
crlter1a of. 5 ptcocurtes per trail.
Stace the conttatnated soil is beneath the foundat1on of the parting ramp,
DO[ ca.pletld 1ft assessment of the potentitl health rtsks Which would result
froa leaving the soil in place. ln develop1nv the asse~sment DOE utilized
conservat1ve assumpttons for potential exposure to a worker Who would be
wort1nt on tilt founclat1on of tbe part1ng l”liiiP 1n tht contam1na~ed son. The
nsl.lltarit •xtiiUII dose to aft 1Delhidua1 worttng tn thts manner “‘S est1aate4
‘tO be 0.42 ara/yr. Th1s esttmate vas based em external guma radiation and
inhalatton doses from uran1um-234. ·235. -238, radi~226. thortum-230, and
-232. For COIIIIWir1son. this value ts less than 1/2 of one percent of the OOI
allaw&ble dose l’\111t ta the puhHc of 100 we&Jyr. Tht potential fo~
exposurt 1s ‘V’I!ry law ghen the present lotat10ft of the cont&mtnat.ed so11 aftd
dut to the fact that thoMua-230 1s the pr1mar”y contasiMnt and is an alphl
nc11it1on es1tter~ Alpha radiat,on 1s not tipable of penetraUI\g the outer
la~er of stta on tbe husao body and exposure nay only be obtained if the soil
1s ingested (i .e •• eaten) or inhaled. Inhalation or ingestion of the
c~,taa1nated so11 11 quantities suffit1ert to cause any exposure ts eltrene1y
unl1kt1J given tbe locat.’on of tbe so~l .
• • • •
2
. I
ltftll Ut rtsaalts of tilt r1st assess.at &nd tht c0ftsirvat1vt ISSYIPt1ons
lAtch an IIUe u pert Df the &SSHs.nt, \bt ‘rtnntlltCAtion of tilt •tertal
lft4 the nature of &lllha rad1at1oa, DOt dMS not reca.tl\11 re110va1 of the
Soft. Tbt d&ta whiCh 4tf1fttS tbe COI~tftlftt ltvt\S Of tb1S SD11 lftd tfte r1sk
asstsSDent v111 bt contidered in tbt overall Rt~~dia1 ‘ tnvest1gation/
Feu1b1Ht1 Studw fol'” ftnal deters1nat1ol of the ftetd I fen- ret~edtat1on . If
thtrt &rt anr Qutst1ons, please conttct ae at (61S) ”6· 084•.
cc : s. ltedle. lttl
A. W.llo, N£•23
~. W1ng, C£•53
6. Kepko • EPA Reg. ion Vtt
D. ledln, MDDMR
&. Turf. Jt£-!3
8. Ma~m1ng, CE·SO
• 1
Sincerely,
‘fz::-\ewM ~(Lc.L. P. A¥e1
Site Mauver ! .
Tecbntc•l Strv1cts D1v1ston
I
I
I •

Post

1988-10-25 – MDNR – West Lake Landfill – Letter to EPA requesting determination of Hazard Ranking Score

_. vfv . < • • » . . . • . ,,;;, • . i. i .• /: tfd JOHNASHCROFT \y(li*Ir>
DuiMcin ol I mironnu-m.il Otulii
UIVIMOM ,,| („…,!,w jnj |J1Klsi,n
FREDERICK A. BRL’NNKR “”X” “”VM-m ,» M.in^-tm-m x-rvuvi)
irix.t,,r STATI: (>i MI>S(>riu nm>i,,n ,,f |.arkv R^…^,,,,.
DEPARTMENT OF NATURAL RESOURCES “” “1N”W”””Jllim
Di\’isioN OF I:NVIRONMI;NTAL gi’Ai.nv
I’.O. Box 176
Jefferson City. MOdSI()2
October 25, 1988
Mr. David Wagoner, Director
Waste Management Division
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
Dear Mr. Wagoner:
The U.S. Nuclear Regulatory Conmission (NRC) staff recently released
a report (NUREG-1308, June, 1988) on the radioactive wastes at the
Westlake Landfill in St. Louis County, Missouri.
In the report the NRC staff concludes that “(1) measures must be
taken to establish adequate permanent control of the radioactive
waste and to mitigate the potential long term impacts from its
existing storage conditions and (2) the information developed is
inadequate for a determination of several important issues, i.e.,
whether mixed wastes are involved, and whether on-site disposal is
practical technologically, and, if so, under what alternative
methods.” However, the report does not indicate whether the NRC will
take any further action at the site and informal communication with
the NRC staff indicates that NRC does not intend to take further
action.
The suggestion has been made by a number of state and local officials
and citizen’s groups that the U.S. Department of Energy should
undertake action at the site under the Formerly Utilized Sites
Remedial Action Program (FUSRAP). However, a letter from DOE was
received by the Missouri Department of Natural Resources on
October 30, 1987 which states that [‘the DOE has reviewed the
possibility of the Westlake Landfill being designated as a FUSRAP
site and has concluded, based on the criteria used to designate
FUSRAP sites, that the Westlake Landfill is not eligible for
consideration as a FUSRAP site. The radioactive waste was under
Nuclear Regulatory Commission license when it was brought to the
landfill and, consistent with current DOE policy, would not be
disposed of at a DOE site.”
Mr. David Wagoner
October 25, 1988
Page 2
Since no further activity is planned at the site by either the NRC or
the DOE, I request that the U.S. Environmental Protection Agency
(EPA) determine the Hazard Ranking Score (HRS) for this site and, if
appropriate, place the site on the National Priorities List (NPL).
This ranking should be conducted using all currently available
information on the site. Further, I request that EPA initiate the
Superfund process to determine potentially responsible parties and,
if necessary, initiate enforcement action to begin an appropriate
remedial action.
The Missouri Department of Natural Resources believes that the
current uncontrolled condition of the radioactive waste at the
Westlake Landfill is unacceptable and we are interested in expediting
action at this site. Please contact me if you have any questions
regarding MDNR’s position on this matter.
Sincerely,
DIVISION OF ENVIRONMENTAL QUALITY
William C. Ford/Director
WCF/dbc
cc: Mr. Jim Fiore, DOE
Mr. Germain LaRoche, NRC

Post

1979-12-28 – MDNR – West Lake Landfill – Letter to City of Bridgeton – Response to Resolution R-79-12

•.
‘ i :_ J Q.t · ,.
1—-+——jl
~ © ‘—–:- ~,.,.,-,,_…,-.
December 28, 1979
llonorable E. 1-1. (Bill) Abram
MJyor
City of nrid9eton
11955 Natural Bridge Road
Oriugeton, Missouri 6304~
Dear Mayor Al~ram:
S1~nator Edw;r, L. 01rck ha:.. fort.·arded tl1e City of nridg~ton’s Resolution
R-79-12 reliltive to dispo~.Jl of radioacti\’e milterial tc the Depa!”trnent
of ~latural Resources for re~ponse relativE· to Mi~souri’s role in control rr;
tlte disposal of radioactive wilste rnrlterials.
You are probc.bly aware thilt the Federa~ riuclear Regulatory Corm1ission fia’..
tile primary responsibility for controllinu the disposal of radioactive
w~ste materiols. The Sta:c of Missouri is not an agree1.1ent state and
h1s no arrdn~_·ement” with the :luclear Regulatory Comrnis~ion to enforce ‘:.hr!
r~ ~·ithin d.e St.1tc of t1i>souri. At the pres·:?nt tir.ie the Solid
·,J1~te Regulations of the f>cpurtnient of ildtural Resources prohit:it the
accrptance of radioactive ~d~te materials at per~it:ed sanitary lan~fil~ ..
The,.cforl’, the l·lestlake L.111dill in St. Louis County does nut lia·,ie autho
izJt.ion to accept radioac:i·.-c 1·1ast.e rnat.er~als. Tt1e DEpartment of ~at~.ir..i,
;t~~ourccs is interested in 1:hat radioac:t ive 1~aste mat!Jials r.ia1 hdve be1:;
di~.pc:;ec1 of ;.t the Wc~tla’:f’. Landfill iri tt1e past un1 hds been in corn11niC.
l’:.’on .,Jith the Oepartmen~ of Lnergy in 1).lkridge, T·~nn~c;see reciue:;tin~1
t 1tlt the; pr11vide us ~1ith 11i1Jt inf0rr:1a:.ion t~ey i1,1vr: ctitainc:d rel.1t~vc : 1
tw disp0·.3J of the v1aste i1l tl1e .Jec;tL•~’? L.:indfill. ~·r. Earl Harl 1 iscn
1·1ith the (Je~ .. ~·tment of En-~rt:Jy llas assured us he vii 11 ~rovide u~. w1 th d r ·
•)f ~lie inves·.iuation rc;:>0″~ .~s soon clS it is availa111c.
lt l1us Geen ;ndicated triat .’l’ry lo.” lr.-t l rudioacli 11c t1u::.te n.dter·iai w.1·
in·1olved in ·:he disposal H the ~.Jcstlal:f Landfiil, anc there sho•1ld her:·
·jJrl’Jer to th .. citizens of i;r·id·.1et•Jr .. 111· .. 1,!vcr, t~w :>c~.irtrnent of rla 0.:.Jr2l
~e··,uurces via:rts to 1·evicH :1l Ll.!cr1nii:ai J.Jli: fro:? t:1t r1l:parl1;1e11t of ::1r.
in·1·~stigaticr1 ar:d stuJy Li:·’.:· t: 1.akir.·J .11 -1 rf’c01m1~!rl(~.1t .inc; as to 1·1lia·. 1 .. ·
>11·1uld be tai.en.
Joseph P. Teasdale Gov;;-rnor
furd A. Lafser Director
Divi’.ii0n ot Enviror~m . , , !al (luclPy.
James P. Odendonl u1rictor

Post

1978-06-16 – NRC Memorandum – Removal of Contaminated Soil from Latty Avenue to Weldon Spring

MEMORANDUM FOR:
THRU:
FROM:
SUBJECT:
JUN 1 6 1978
Chairman Hendrie
Cofonlssloner
Commissioner Kennedy
Coranissioner Bradford
JSlpwd) Lee V. Gossi*
iv
Distribution:
FCPF
NMSS
ixOocket 40-8035
LVGossick
CVSmith,Jr.
SMeyers
RECunningham
JBMartin
LCRouse
EDO r/f
SECY
PE
GC
Volgenau
Shapar
Lee V. Gossick, Executive Director
Clifford V. Smith. Jr., Director
Office of Nuclear Material Safety and Safeguards
REMOVAL OF CONTAMINATED SOIL FROM HAZELWOOD TO WELDON
SPRING, MISSOURI (REF: SECY -78-1 69)
The staff has been 1n contact with the DOE staff at Geraantown,
Maryland,-who has the responsibility for answering your letter to
Mr. O’Leary dated April 24, 1978. In this letter, we reconcended
that the contaminated soil be moved to the Wei don Spring raffinate
pit area in orcier that the property on Latty Avenue can be
decontaminated and released for unrestricted use. The staff’s conversations
with the DOE staff indicate that DOE is contemplating a
neoative response to our suggested use of Heldon Spring and 1s
preparing a memorandum suggesting that the material be consoldated
on site until a permanent low»level waste burial ground is picked,
which could be years from now.
In the discussion of remedial action alternatives, which was enclosed
in your April 24 letter to Mr. O’Leary, the staff rejected on-s1te
storage because the contaminated material would not be removed to an
isolated area, the material would have to be moved at a later date
(this would mean moving the material twice 1n a densely populated area),
and finally the site could not be released for unrestricted use.
Nothing has happened since that letter to change the staff’s position
that movement of the material to the Wei don Spring pit area 1s the
best solution because the site is remote, it is controlled to provide
restricted access, it is owned by the Federal Government, and last but
far from least, it is already contaminated, and the residues from Latty
Avenue would be only a rainiscule increase in the volume of contaminated
soil and rubble presently existing at Weldon Spring.
OFFICE>-
SURNAME>-
DATE>-
•-— ‘ ”
ISTRC FORM 318 (9-76) NRCM 0240 T^ 111 a. GOVERNMENT PRINTING OFFICEl 1976 — 628-824
If DOE insists on their Indicated course of action, 1t could significantly
delay the cleanup of the site because of the complex negotiations
required with the former licensee, Cotter Corporation. The Cotter
Corporation has Indicated that they might be willing to pay for the
movement of the material to a nearby site, but they would resist having
to move it twice or move it a long distance. We view our proposed
solution as the raost reasonable of the available alternatives which
is both technically sound and would also release Mr. Jarboe of a
predicament that was not of his making and 1s currently costing Ma
an estimated $60,OOC/year in cash and an Indeterminate amount 1n lost
business because of the delay in building his chemical plant.
I therefore recorwend that Mr. O’Leary be contacted by phone to
reitterate the need to solve this problem as rapidly as possible
and that disposal to a site other than Wei don Spring would only
cause additional delays.
Clifford V. Smith, Jr., Director
Office of Muclear Material
Safety and Safeguards
6/15/78
. FCPF
WTCrow SEE
6/ /78 ATTACHED FOR
PftWr
OFFICERSURNAME
>-
DATE^-
FCPF
LCRouse
67 778
FCSL
JBMartin
67 778
CVSmith,Jr. LVGossick
6/7F/78
NEC FORM 318 (9-76) NRCM 0240 “£? Ul 3. GOVERNMENT PRINTINO OFFICE! 1S78 –
\
,6/15/78
If DOE 1nst«ts on their indicated course of action. 1t could significantly
delay the cleanup of the site because of the complex negotiations
required with\he former licensee, Cotter Corporation, The Cotter
Corporation has\1nd1cated that they might be willing to pay for the
movement of the Arterial to a nearby site, but they would resist having
to move 1t twice 6r move 1t a long distance. Since our legal hold on
Cotter Corporation Ms tenuous, the litigation posslblltles could keep
a staff of lawyers ttasy for years and still not get Mr. Jartoe out of
a predicament that wa\not of his making and Is currently costing Mm
an estimated $60,000/year 1n cash and an Indeterminate amount 1n lost
business because of the\elay 1n building his chemical plant.
I therefore recossnend thavtlr. O’Leary be contacted by phone to
reitterate the need to solve\th1s problem as rapidly as possible
and that disposal to a site other than k’eldon Spring would only
cause additional delays. \
\
S\
Cl\fford V. Smith, Jr., Director
Office of Wuclear Material
SaV>ety and Safeguards
FCPF
WTCrow^-
6//’>/78
OFFICERSURNAME
^~
DATE^-
FCPJ?/^
LCRousk < 6//4/7S K3L ItyjKjtfa -u....:.. FC RECunningham 6/ /78 . FC SMeyers 67 778 NMSS CVSmith,Jr. 67 778 EDO LVGossick 67 778 NRC FORM 318 (9-76) NRCM 0240 Ul 8. GOVERNMENT PSilNTINO OF.FICEi 1976-

Post

1997-05-20 – EPA – West Lake Landfill – Settlement Negotiation Consultant Consent Request

Redacted
FOIA Exemption 4
TECHNICAL SERVICES AGREEMENT — CONSULTANT
JAMS/Endispute
Consultant
222 S. Riverside Plaza, Suite 1850
Address
Chicago,
City
(800)445-4650
Telephone
IL
State
FAX:
Tax Identification Number
60606
Zip
312-655-9197
DYNA MAC
Cc:JRPCJRATICIN
The Dynamac Building
2275 Research Boulevard
Rockville, MD 20850-3268
Telephone: 301-417-9800
FAX: 301-417-9801
AGREEMENT
NUMBER
1. Parties to this Agreement. This agreement is made this_ day of , 19_, between
Dynamac Corporation, a Delaware corporation hereinafter called DYNAMAC, with its
headquarters located at 2275 Research Blvd., Rockville, Maryland, 20850-3268, and __
JAMS/Endispute hereinafter called Consultant, with offices at222 s. Riverside Plaza, Suite lf:!50,
Chicago, nDYNAMAC desires to procure and Consultant desires to provide certain technical services.
This Agreement between the parties shall constitute a basic Agreement, the terms and
conditions of which shall apply to each Purchase Order issued by DYNAMAC and accepted
by Consultant.
2. Term. The term of this Agreement shall commence on the date of execution of this
Agreement and shall continue until terminated by the provisions of Article 16.
3. Scope of Services. Under the terms of this Agreement, Consultant shall provide the technical
services listed in Addendum A which shall specify:
a. Contract number and nature of work to be performed;
b. Category of staffing of each individual required;
c. Estimated start date and estimated completion date;
d. Total not-to-exceed cost;
e. Individual who will coordinate for DYNAMAC;
f. Other information which is necessary to clarify the work.
Consultant shall provide the technical services according to the fees listed in Addendum A.
DYNAMAC shall request such services in writing in a Purchase Order. Consultant shall
provide the services requested and shall reply in writing to DYNAMAC’s request within a
reasonable time following receipt by Consultant of DYNAMAC’s request. The Consultant
is not authorized to start work until he receives a Purchase Order signed by DYNAMAC. ,· ·
I
4. Modification of Scope of Services. DYNAMAC may at any time modify the scope of services
upon written notice to Consultant specifying the desired modifications on the Purchase
Order and, if required, Addendum A Consultant shall at its discretion, agree to perform
such services according to mutually-agreed-to-changes. A copy of the revised Purchase
Order and modified Addendum A Form accepted and executed by Consultant shall be
returned to DYNAMAC.
5. Cancellation of Technical Services. DYNAMAC may at any time cancel the performance of
any technical services upon ten (10) days prior written notice to Consultant stating its
intention to cancel and specifying the Purchase Order number and Addendum A Form to
be canceled and the date upon which such cancellation shall be effective. In the event of
such cancellation, DYNAMAC shall pay for reasonable and authorized services rendered
and expenses incurred prior to the effective date of cancellation.
6. Billing of Services. Consultant shall invoice DYNAMAC “monthly” for the services rendered
during the preceding “monthly” period using the form Addendum B. Payment shall be made
by DYNAMAC approximately thirtY (30) days following DYNAMAC receipt and approval
of the invoice.
7. Payment. In consideration of the services rendered to DYNAMAC by Consultant under this
agreement, DYNAMAC shall pay Consultant in accordance with the signed Purchase Order.
The fees listed in Attachment A are considered fixed and shall not be amended unless
mutually agreed to in writing by both parties. Any estimates made by Consultant for the
cost of services to DYNAMAC shall be made in good faith but shall in no event be higher
than those charged to Consultant’s most favored client or customer.
8. Travel. Consultant may be required to furnish services on DYNAMAC or other premises.
DYNAMAC shall reimburse the Consultant for travel expenses (as authorized in Joint
Travel Regulations) that have been authorized in writing including living expenses incident
to such travel; however, travel time shall not be considered as time spent in furnishing
services. All payments for such authorized expenses shall be made upon submission of
Addendum C by the Consultant, including all receipts .
9. Independent Consultant. In furnishing services pursuant to this Agreement, the Consultant
shall at all times be acting as an independent Consultant and shall be responsible for all
income and other payroll-associated taxes. As such, the Consultant shall not be an
employee of DYNAMAC and shall not by reason of this Agreement or services hereunder
be entitled to participate in or to receive any benefit or right under any of the DYNAMAC
employee benefit or insurance plans.
10. Reassignment of Personnel. Consultant shall not reassign any personnel without prior
notification to DYNAMAC. All proposed substitutes shall have qualifications equal to or
higher than the qualifications of the person to be replaced. DYNAMAC shall be notified
of any proposed substitution at least thirty (30) days in advance of the substitution. Such
notification shall include: (a) an explanation of the circumstances necessitating the
substitution, (b) a complete resume of the proposed substitute, and (c) any other
information requested by DYNAMAC in order to determine that the Consultant is
maintaining the same high quality of personnel. H approved, such person shall be billed at
a rate no higher than that of the person for whom the substitution was made.

11. Non-Competing. This Agreement is intended to secure Consultant’s help and cooperation
and Consultant agrees that during the term of this Agreement, Consultant shall not accept
any employment or engage in work or business adverse to the interest of DYNAMAC
insofar as such employment, work or business may involve or be closely related to matters
referred to Consultant under this Agreement, or where any third party which competes with
DYNAMAC in the field of this Agreement might be benefitted by the services rendered or
information gained by the Consultant under this Agreement.
12. Proprietary Rights. In view of the confidential relations which are contemplated under this
·Agreement, the Consultant shall promptly disclose and assign to DYNAMAC any inventions
or discoveries . made or conceived resulting from the work done by Consultant for
DYNAMAC during the term of this Agreement. Any such inventions or discoveries shall
become and remain the property of DYNAMAC whether or not patent or other applications
are filed thereon. From time to time, at DYNAMAC’s request and at its expense, the
Consultant shall make applications upon any such inventions or discoveries through
attorneys or representatives designated by DYNA.MAC for Letters Patent in the United
States and in all other countries, and shall assign such applications to DYNA.MAC or its
order forthwith. The Consultant shall give DYNA.MAC, its attm:neys and representatives,
all reasonable assistance in preparing such applications, and from time to time, upon
request, shall executed all papers and do all things that may reasonably be required to
protect the rights of DYNA.MAC and vest in it or its nominees the inventions and Letters
Patent herein provided for.
13. Confidentiality. The Consultant shall keep such written records and make such reports upon
Consultants work under this Agreement as may be requested by DYNA.MAC, and shall not
disclose any DYNA.MAC proprietary or confidential information obtained or developed
during the term of this Agreement to any third person without the written consent of an
authorized representative of DYNA.MAC, either during the term of this Agreement or
thereafter. Consultant fully understands that the proprietary and/or confidential
information, while not being limited to, does include the identity of any DYNA.MAC clients,
data developed on any scientific studies, computer programs and associated data, and any
proprietary DYNA.MAC products. The Consultant shall deliver to DYNA.MAC, at its
request, all such records, together with any written material which may have been furnished
to Consultant by DYNA.MAC in connection with this Agreement, and thereafter Consultant
shall make no further use or utilization of any such material and information without the
prior written consent of DYNA.MAC.
14. Liability. Consultant shall be liable for any and all loss, destruction or damage to any
DYNAMAC-furnished materials when such loss, destruction or damage was due to the
negligence of Consultant, and to the extent of restoring the lost, destroyed, or damaged
materials, provided that such restoration can reasonably be performed by Consultant, and
DYNAMAC furnishes Consultant with all source data necessary for such restoration.
15. Indemnification. Consultant hereby releases and agrees to defend, indemnify and hold
harmless DYNA.MAC, DYNA.MA.C’s parent company, DYN.AMAC’s employees, directors,
officers, agents and subcontractors from and against any and all liabilities, claims, damages,
losses costs and expenses for all injuries to or death of any and all persons and for loss of
or damage to property, including but not limited to loss or use thereof, arising directly in
connections with the services described herein, where caused by the Consultant or his
employees or agents.

16. Tennination of Agreement. DYNAMAC may at any time terminate this Agreement upon
five (5) days prior written notice to Consultant stating its intention to terminate and
specifying the date upon which such termination shall be effective. All obligations of the
Consultant under Articles 12 and 13 above shall survive and not be affected by any
termination of this Agreement or its expiration.
Upon termination of this Agreement, the parties shall promptly return to each other all
written matter of any type provided by the other party, which contains confidential
information; the Consultant shall be paid for services rendered and reimbursable expenses
incurred up to the date of such termination and not thereafter. Payment upon termination
shall be accepted by the Consultant in full satisfaction of all claims and demands against
DYNAMAC based upon or arising out of or in connection with this Agreement.
17. Severability. In the event that any of the provisions contained in this Agreement shall, for
any reason, be held to be unenforceable in any respect under the laws of the State of
Maryland, such unenforceability shall not affect any other provisions of this Agreement, but
this Agreement sh~l be construed as if such unenforceable provisions had never been
contained herein.
18. Oral Representations. No employee, agent or representative of DYNAMAC has the
authority to bind DYNAMAC to any oral representation concerning these services.
19. Service of Notice. Any notice required or permitted to be sent under this Agr~ement shall
be delivered by hand or mailed by registered mail, return receipt requested, to the addresses
of the parties first set forth in this Agreement. Notice so sent shall be deemed effective on
the first day following the date of mail deposit.
20. Entire Agreement. This Agreement, including those provisions and conditions contained in
DYNAMAC’s purchase order, constitutes the entire Agreement of the parties. No waiver,
notice, alteration, or modification of any of the provisions shall be binding unless in writing
and signed by a duly authorized representative of DYNAMAC and of the Consultant. Tiris
Agreement shall be governed by the laws of the State of Maryland and there are no
understandings or representations expressed or implied, not specified herein.
DYNAMAC Acceptance: Consultant Acceptance:
Signature Signature Date
David A. Biver
Name Name (print)
Vice President
Title Title
Redacted
FOIA Exemption 4
The Conflict of Interest provisions set forth in the prime contract are hereby made apart of this
consultant agreement.
H-2 ORGANIZATIONAL CONFLICTS OF INTEREST (EPAAR 1552.209-71) (MAY 1994)
(a) The Subcontractor warrants that, to the best of the S.lbcontractor’ s knowledge and belief, there
are no relevant facts or circumstances which could give rise to an organization conflict of interest,
as defined in FAR Subpart 9.5, or thatthe Subcontractor has disclosed all such relevant information
(b) Prior to commencement of any work, the Subcontractor agrees to notify the Dynamac
Contracting Officer immediately that, to the bes: of its knowledge and belief, no actual or potential
conflict of interest exists or to identify to the Dynamac Contracting Officer any actual or potential
conflict of interest the firm may have. In emergency situations, however, work may begin but
notification shall be made within three (3) working days.
( c) Th~ Subcontractor agrees that if an actual or potential organizational conflict of interest is
identified during performance, the Subcontractorwill immediaely make a full disclosure in writing
to the Dynamac Contracting Officer. This disclosure shall include a description of actions which
the Subcontractor has taken or proposes to take, after consultation with Dynamac’ s Contracting
Officer, to avoid, mitigate, or neutralize the actual or potential conflict of interest. The
Subcontractor shall continue performance until notified by Dynamac’s Contracting Officer of any
contrary action to be taken.
(d) Remedies. Dynamac may terminate this Subcontract cr any work assignment issued hereunder
for convenience, in whole or in part, if it deems such termination necessary to avoid an
organizational conflict of interest. If the Subcontractor was aware of a potential organizational
conflict of interest prior to award or discovered an actual or potential conflict after award and did
not disclose it or misrepresented relevant infonrution to Dynamac ‘s Contracting Officer, Dynamac
may terminate the Subcontract fer default, debar the Subcontractor from Dynamac subcontracting,
or pursue other remedies as may be permitted by law or this Subcontract. .
(e) The Subcontractor agrees to insert in each subcontract or consultant agreement placed
hereunder, except for subcontracts or consultant agreements for well drilling, fence erecting,
plumbing, utility hookups, security guard services, or electrical services, provisions which shall
conform substantially to the language of this clause, including this paragraph (e).
H-3 NOTIFICATION OF CONFLICTS OF INTEREST REGARDING PERSONNEL (EPAAR
1552.209-73) (MAY 1994)
(a) In addition to the requirements of the subcontract clause entitled “Organizational Conflicts of
Interest,” the following provisions with regard to employee personnel performing under this
Subcontract shall apply until the earlier of the following two dates: the termination date of the
affected employee(s) or the expiration date of !he Sub~ontra~t. _ _
(b) The Subcontractor agrees to notify immediately the Dynamac Project Manager and the Dynama:
Contracting Officer of (1) any actual or potential personal conflict of interest with regard to any of
its employees working on or having access to information regarding this Subcontract, or (2) any such
conflicts concerning lower-tier subcontractor employees or consultants wcrking on or having access
to information regarding this subcontract, when such conflicts have been reported to the
Subcontractor. A personal conflict of interest is defined as a relationship of an employee,
subcontractor employee, or consultant with an entity that may impair the objectivity of the employee,
subcontractor employee, or consultant in performing the subcontract work.
(c) The Subcontractor agrees to notify the Dynamac Project Manager and Dynamac Contracting
Officer prior to incurring costs for that employee’s work when an employee may have a personal
conflict of interest. In the event that the personal conflict of interest does not become known until
after performance on the Subcontract begins, the Subcontractor shall immediately notify Dynamac’ s
Contracting Officer of the personal conflict of interest. The Subcontractor shall continue
performance of this subcontract until notified by Dynamac’ s Contracting Officer of the appropriate
action to be taken.
(d) The Subcontractor agrees to insert in each subcontract or consultant agreement placed
hereunder, except for subcontracts or consultant agreements for well drilling, fence erecting,
plumbing, utility hookups, security guard services, or electrical services, provisions which shall
conform substantially to the language of this clause, including this paragraph (d).
STATEMENT OF WORK
Site Background
West Lake Landfill (the “Site), Operable Unit No. 1, involves a remedial
investigation/feasibility study (RI/FS) being performed by Cotter Corporation (N.S.L.),
Laidlaw Waste Systems (Bridgeton), Inc., Rock Road Industries, Inc., and the U.S.
Departme~t of Energy.
In 1966, the Atomic Energy Commission (AEC) sold 8,700 tons of leached barium
sulfate, together with other radioactive residues, to Continental Mining and Milling
Company (Continental Mining). The radioactive residues were generated as byproducts
of uranium processing performed by the AEC’ s contractor. These processing
residues were stored at the ABC’s St. Louis Airport Storage Site. Continental Mining
moved the radioactive residues to its facility at 9200 Latty A venue in Hazelwood,
Missouri. Eventually, Cotter purchased the radioactive residues and shipped all but the
8,700 tons of leached barium sulfate to its processing facility in Colorado.
In 1973, approximately 8,700 tons of radioactively contaminated leached barium sulfate
residues were mixed with approximately 39,000 tons of soil, and the entire amount was
disposed of in two areas of the Site. This material resulted from decontamination
efforts undertaken by Cotter at 9200 Latty A venue where the residues had been stored.
Studies have indicated that these two areas of the landfill are contaminated with
uranium-238, uranium-235, thorium-230, and radium-226. In addition to the
radioactive materials in the landfill, groundwater at the Site is also contaminated with
radioactive materials as well as other hazardous substances.
In 1993, EPA entered into an Administrative Order on Consent (AOC) for the
performance of a Rl/FS at the Site. As indicated above, Cotter Corporation, Laidlaw
Waste Systems, Inc., Rock Road Industries, Inc., and the U.S. Department of Energy
were signatories to this AOC.
Mediation Support
To date, the four respondents to the AOC have shared the cost of work equally. While
this allocation bas worked for the Rl/FS phase of the work, the upcoming remedial
design/remedial action (RD/RA) will be substantially more costly, and some of the
parties may have difficulty paying a 25 % share. The Rl/FS is still underway, so no
Record of Decision (ROD) has been issued and it is not expected that a ROD will be
issued before this mediation process is complete. ·
Despite the absence of projected remedial costs, both the PRPs and DOE are willing to
proceed with a mediation effort. In particular, DOE seeks a greater degree of certainty
in its budget planning process, and along with the PRPs may see mediation as an
opportunity to adopt a more equitable basis for liability than the current per capita
scheme.
On December 5, 1996, a meeting of the St. Louis Site Task Force was conducted in St.
Louis, Missouri. Those attending included DOE Assistant Secretary Thomas
Grumbley, EPA Regional Administrator Dennis Gramms, as well as various other
representatives of DOE, EPA, the State of Missouri, the City and County of St. Louis
and staffer.s from interested Congressional offices in the state and affected district. At
this meeting, DOE Assistant Secretary Grumbley announced that with regard to West
Lake Landfill OU-1, EPA would “allocate the responsibility at the site as best as it can
over the next six months or so, so that they can tell us what percentage of the
responsibility that [DOE] needs to take …. ”
Any allocation of responsibility that EPA may prepare, such as a non-binding allocation
of responsibility, may expose EPA to charges of favoritism, since DOE is a sister
federal entity. Discussions were held among the four identified potentially responsible
parties (PRPs) regarding how best to conduct an allocation. It was agreed that using a
third-party neutral mediator would best serve the interests of the parties and satisfy
EPA’ s desire to maintain neutrality.
Additionally, the private party PRPs have requested that in any mediation performed,
that the mediator give consideration and possibly allocate some responsibility to an
“orphan”. The orphan is B&K Construction Company, which acted as the transporter
of the radioactive materials for Cotter Corporation. It has been alleged that B&K
actually chose the Site for disposal of the wastes, although there appears to be some
conflicting information on this.
Therefore, in order to accomplish the allocation, EPA would envision starting as soon
as pr~c~i~a~l~ in order to meet the six-month deadline mentioned above. While this
schedule is ambitious, EPA still envisions that the parties would be substantially
involved in the process or nearly complete in their efforts by that date.
The process would involve voluntary allocation of liability with the four PRPs, with
EPA as a party to represent the “orphan” share previously discussed. An initial
meeting is expected, with several additional one-day meetings with all parties in
attendance to follow until resolution.
Appropriate shares for costs may include consideration of PRP ability to pay issues, as
driven by a range of estimated costs for various likely, but as yet not selected, remedial
alternatives. Additional costs or liabilities considerations may include credit for past
contributions under the per capita allocation scheme, EPA’s orphan share contribution
in the form of forgiveness of oversight costs, or other mechanisms or sources that may
come forward as the allocation proceeds. EPA would expect that the convening phase
of the mediation would resolve many of these issues to further clarify what the parties
expect from the process.
Contract Reqyirements
Dynamac Corporation was tasked on March 10, 1997, to provide a professional
arbitrator/ allocator/mediator that can provide the services indicated in the previous
information and meet the specific requirements contained in the Scope of Work section
of this document. Toward that end, Dynamac is soliciting bids to conduct the following
work from professional mediators, persons and organizations.
Scope of Work
A. Convening Activities (PHASE I)
1. The mediator shall contact key parties for the PRPs as identified by Dynamac Project
Manager. The mediator shall discuss the goals and purpose of the proposed mediation
process, as well as the technical or substantive issues involved in the allocation process.
If initial contacts with the key parties reveal that a mediation process is not feasible, the
mediator shall notify Dynamac, explain the difficulties (lack of interest, unequivocal
opposition of a key party, disagreement about the definition of the problem, wrong
forum or process, etc.) and await the Dynamac Project Manager’s decision on whether
to proceed with the mediation process.
2. The mediator shall provide oral reports to the Dynamac Project Manager as needed
pertaining to the general progress of the convening effort.
3. The mediator shall provide one copy of a draft convening report to the Dynamac
Project Manager within five working days of the conclusion of the convening effort.
The report shall:
a. Summarize the results of the convening contacts, including such items as:
(1) Who was contacted, representing what organization, during this period;
and
(2) Identification and discussion of the issues which the parties agree will be
considered as part of the allocation process, and the issues which the
parties choose not to have addressed in the allocation process.
b. A discussion of the chances of a successful allocation process and the goals and
purpose of the process from the viewpoints of the affected parties.
c. Recommendation of potential additional parties that should also participate in the
mediation process.
d. If the mediation process appears to be feasible, the report shall include a design
for the process including such things as:
(1) The structure and type of meetings between/among the mediator and the
affected parties;
Q.) The expected number, length, location and frequency of meetings;
(3) The research, data or information necessary prior to or during the
process;
(4) The estimated budget for the process as designed and proposed by the
mediator; and
(5) Whether an orientation session is recommended prior to the first
meeting.
(6) Commitments from the effected parties to fully participate in the
mediation process.
e. If a consultative process in not recommended, the mediator may suggest other
processes that could accomplish the goals of achieving a voluntary allocation
agreement.
The Dynamac Project Manager will review the draft convening report and provide
comments and revisions as necessary. The mediator will prepare the final report
incorporating the Dynamac Project Manager’s comments and revisions as appropriate.
The mediator shall distribute three copies of the final report to the Dynamac Project
Manager, and one copy to each of the parties interviewed for the report.
4. If Dynamac decides to proceed, the mediator shall submit an initial draft of operational
ground rules, for approval by Dynamac.
5. As a part of the convening effort, the mediator may arrange for and facilitate an initial
organizational meeting of the parties to discuss the form of the process and the parties
to be involved, to get commitments to go forward from each of the parties, discuss the
issues involved, and/or the ground rules for the process. ·
B. Mediation Activities
This phase will implement the design of the mediation process as accepted by the Dynamac
Project Manager based upon the final convening report reconunendations.
1. At the initial meetings, the mediator shall assist the group in further developing and
refining the ground rules or operating procedures of the process.
2. The mediator shall provide a draft agenda to the Dynamac Project Manager for each
meeting. The mediator shall distribute the final agenda to the Dynamac Project
Manager and to participants in the mediation process.
3. The mediator shall facilitate all plenary, subcommittee and work group sessions. As
facilitator, the mediator shall assist participants in articulating their interests,
identifying areas of agreement, and developing consensus solutions to the problems that
divide them. As facilitator, s/he shall keep the parties talking, listening, and moving
(as much as possible) towards the goal of the process.
4. The mediator shall communicate in person, by phone or in writing with process
participants to ensure that issues and concerns have been conununicated accurately and
that all participants are adequately prepared for the next meeting.
5. The mediator will be required to provide draft meeting sununaries to the Dynamac
Project Officer and the participants. The necessity for and the extent of the sununary
will be decided between the mediator and the Dynamac Project Manager during an oral
briefing following each meetings. The facilitator shall distribute final meeting
summaries to the Dynamac Project Officer and participants.
6. The mediator shall provide meeting facilities and support for all meetings. If
arrangements must be made for meetings to be held outside of the mediator’s facility,
Dynamac staff will provide logistical support in obtaining appropriate meeting
facilities.
7. The mediator shall furnish a draft report of the mediation process to the Dynamac
Project Officer within 15 working days of process completion. The report shall
include:
a. An executive sununary of the process including a brief background, an overview
of the issues discussed, and the resolutions of the issues;
b. Final meeting sununaries with relevant and necessary attachments;
c. Relevant substantive correspondence between the mediator and the participants
and between the participants (if available to the mediator); -and
d. A process evaluation by the mediator summarizing the ·results of the process,
analysis of the issues, procedural lessons learned, and reconunendations for
improvement.
The Dynamac Project Officer will review the draft final report and provide comments
and revisions as necessary and appropriate. The mediator shall prepare the final report
incorporating the comments and revisions as appropriate to maintaining the third-party
neutral status of the mediator. The mediator shall provide three copies of the final
report to the Dynamac Project Manager and one copy to each party involved in the
process.
The Conflict of Interest provisions set forth in the prime contract are hereby made apart of this
consultant agreement.
H-2 ORGANIZATIONAL CONFLICTS OF INTEREST (EPAAR 1552.209-71) (MAY 1994)
(a) The Subcontractor warrants that, to the best of the SJbcontractor’s knowledge and belief, there
are no relevant facts or circumstances which could give rise to an organization conflict of interest,
as defined in FAR Subpart 9. 5, or that the Subcontractor has disclosed all such relevant information
(b) Prior to commencement of any work, the Subcontractor agrees to notify the Dynamac
Contracting Officer immediately that, to the belt of its knowledge and belief, no actual or potential
conflict of interest exists or to identify to the Dynamac Contracting Officer any actual or potential
conflict of interest the firm may have. In emergency situations, however, work may begin but
notification shall be made within three (3) working days.
(c) The Subcontractor agrees that if an actual or potential organizational conflict of interest is
identified during performance, the Subcontractor will immedia~ly make a full disclosure in writing
to the Dynamac Contracting Officer. This disclosure shall include a description of actions which
the Subcontractor has taken or proposes to take, after consultation with Dynamac’s Contracting
Officer, to avoid, mitigate, or neutralize the actual or potential conflict of interest. The
Subcontractor shall continue performance until notified by Dynamac’ s Contracting Officer of any
contrary action to be taken.
(d) Remedies. Dynamac may terminate this Subcontract a any work assignment issued hereunder
for convenience, in whole or in part, if it deems such termination necessary to avoid an
organizational conflict of interest. If the Subcontractor was aware of a potential organizational
conflict of interest prior to award or discovered an actual or potential conflict after award and did
not disclose it or misrepresented relevant informa:ion to Dynamac’ s Contracting Officer, Dynamac
may terminate the Subcontract fer default, debar the Subcontractor from Dynamac subcontracting,
or pursue other remedies as may be permitted by law or this Subcontract.
( e) The Subcontractor agrees to insert in each subcontract or consultant agreement placed
hereunder, except for subcontracts or consultant agreements for well drilling, fence erecting,
plumbing, utility hookups, security guard services, or electrical services, provisions which shall
conform substantially to the language of this clause, including this paragraph (e).
H-3 NOTIFICATION OF CONFLICTS OF INTEREST REGARDING PERSONNEL (EPAAR
1552.209-73) (MAY 1994)
(a) In addition to the requirements of the subcontract clause entitled “Organizational Conflicts of
Interest,” the following provisions with regard to employee personnel performing under this
Subcontract shall apply until the earlier of the following two dates: the termination date of the
affected employee(s) or the expiration date of the Subcontract.
(b) The Subcontractor agrees to notify immediately the Dynamac Project Manager and the Dynama:
Contracting Officer of (1) any actual or potential personal conflict of interest with regard to any of
its employees working on or having access to information regarding this Subcontract, or (2) any such
conflicts concerning lower-tier subcontractor employees or consultants wcrking on or having access
to information regarding this subcontract, when such conflicts have been reported to the
Subcontractor. A personal conflict of interest is defined as a relationship of an employee,
subcontractor employee, or consultant with an entity that may impair the objectivity of the employee,
subcontractor employee, or consultant in performing the subcontract work.
(c) The Subcontractor agrees to notify the Dynamac Project Manager and Dynamac Contracting
Officer prior to incurring costs for that employee’s work when an employee may have a personal
conflict of interest. In the event that the personal conflict of interest does not become known until
after performance on the Subcontract begins, the Subcontractor shall immediately notify Dynamac ‘s
Contracting Officer of the personal conflict of interest. The Subcontractor shall continue
performance of this subcontract until notified by Dynamac’ s Contracting Officer of the appropriate
action to be taken.
(d) The Subcontractor agrees to insert in each subcontract or consultant agreement placed
hereunder, except for subcontracts or consultant agreements for well drilling, fence erecting,
plumbing, utility hookups, security guard services, or electrical services, provisions which shall
conform substantially to the language of this clause, including this paragraph (d).
STATEMENT OF WORK
Site Back~round
West Lake Landfill (the “Site), Operable Unit No. 1, involves a remedial
investigation/feasibility study (RI/FS) being performed by Cotter Corporation (N.S.L.),
Laidlaw Waste Systems (Bridgeton), Inc., Rock Road Industries, Inc., and the U.S.
Department of Energy.
In 1966, the Atomic Energy Commission (AEC) sold 8,700 tons of leached barium
sulfate, together with other radioactive residues, to Continental Mining and Milling
Company (Continental Mining). The radioactive residues were generated as byproducts
of uranium processing performed by the AEC’ s contractor. These processing
residues were stored at the AEC’s St. Louis Airport Storage Site. Continental Mining
moved the radioactive residues to its facility at 9200 Latty A venue in Hazelwood,
Missouri. Eventually, Cotter purchased the radioactive residues and shipped all but the
8,700 tons of leached barium sulfate to its processing facility in Colorado.
In 1973, approximately 8,700 tons of radioactively contaminated leached barium sulfate
residues were mixed with approximately 39,000 tons of soil, and the entire amount was
disposed of in two areas of the Site. This material resulted from decontamination
efforts undertaken by Cotter at 9200 Latty A venue where the residues had been stored.
Studies have indicated that these two areas of the landfill are contaminated with
ur.anium-238, uranium-235, thorium-230, and radium-226. In addition to the
radioactive materials in the landfill, groundwater at the Site is also contaminated with
radioactive materials as well as other hazardous substances.
In 1993, EPA entered into an Administrative Order on Consent (AOC) for the
performance of a Rl/FS at the Site. As indicated above, Cotter Corporation, Laidlaw
Waste Systems, Inc., Rock Road Industries, Inc., and the U.S. Department of Energy
were signatories to this AOC.
Mediation Support
To date, the four respondents to the AOC have shared the cost of work equally. While
this allocation has worked for the Rl/FS phase of the work, the upcoming remedial
design/remedial action (RD/RA) will be substantially more costly, and some of the
parties may have difficulty paying a 25 % share. The RI/FS is still underway, so no
Record of Decision (ROD) has been issued and it is not expected that a ROD will be
issued before this mediation process is complete.
Despite the absence of projected remedial costs, both the PRPs and DOE are willing to
proceed with a mediation effort. In particular, DOE seeks a greater degree of certainty
in its budget planning process, and along with the PRPs may see mediation as an
opportunity to adopt a more equitable basis for liability than the current per capita
scheme.
On December 5, 1996, a meeting of the St. Louis Site Task Force was conducted in St.
Louis, Missouri. Those attending included DOE Assistant Secretary Thomas
Grumbley, EPA Regional Administrator Dennis Gramms, as well as various other
representatives of DOE, EPA, the State of Missouri, the City and County of St. Louis
and staffers from interested Congressional offices in the state and affected district. At
this meeting, DOE Assistant Secretary Grumbley announced that with regard to West
Lake Landfill OU-1, EPA would “allocate the responsibility at the site as best as it can
over the next six months or so, so that they can tell us what percentage of the
responsibility that [DOE] needs to take …. ”
Any allocation of responsibility that EPA may prepare, such as a non-binding allocation
of responsibility, may expose EPA to charges of favoritism, since DOE is a sister
federal entity. Discussions were held among the four identified potentially responsible
parties (PRPs) regarding how best to conduct an allocation. It was agreed that using a
third-party neutral mediator would best serve the interests of the parties and satisfy
EPA’ s desire to maintain neutrality.
Additionally, the private party PRPs have requested that in any mediation performed,
that the mediator give consideration and possibly allocate some responsibility to an
“orphan”. The orphan is B&K Construction Company, which acted as the transporter
of the radioactive materials for Cotter Corporation. It has been alleged that B&K
actually chose the Site for disposal of the wastes, although there appears to be some
conflicting information on this.
Therefore, in order to accomplish the allocation, EPA would envision starting as soon
as practicable in order to meet the six-month deadline mentioned above. While this
schedule is ambitious, EPA still envisions that the parties would be substantially
involved in the process or nearly complete in their efforts by that date.
The process would involve voluntary allocation of liability with the four PRPs, with
EPA as a party to represent the “orphan” share previously discussed. An initial
meeting is expected, with several additional one-day meetings with all parties in
attendance to follow until resolution.
Appropriate shares for costs may include consideration of PRP ability to pay issues, as
driven by a range of estimated costs for various likely, but as yet not selected, remedial
alternatives. Additional costs or liabilities considerations may include credit for past
contributions under the per capita allocation scheme, EPA’s orphan share contribution
in the form of forgiveness of oversight costs, or other mechanisms or sources that may
come forward as the allocation proceeds. EPA would expect that the convening phase
of the mediation would resolve many of these issues to further clarify what the parties
expect from the process.
Contract Req.uirements
Dynamac Corporation was tasked on March 10, 1997, to provide a professional
arbitrator/ allocator/mediator that can provide the services indicated in the previous
information and meet the specific requirements contained in the Scope of Work section
of this document. Toward that end, Dynamac is soliciting bids to conduct the following
work from professional mediators, persons and organizations.
Scope of Work
A. Convening Activities (PHASE I)
1. The mediator shall contact key parties for the PRPs as identified by Dynamac Project
Manager. The mediator shall discuss the goals and purpose of the proposed mediation
process, as well as the technical or substantive issues involved in the allocation process.
If initial contacts with the key parties reveal that a mediation process is not feasible, the
mediator shall notify Dynamac, explain the difficulties (lack of interest, unequivocal
opposition of a key party, disagreement about the definition of the problem, wrong
forum or process, etc.) and await the Dynamac Project Manager’s decision on whether
to proceed with the mediation process.
2. The mediator shall provide oral reports to the Dynamac Project Manager as needed
pertaining to the general progress of the convening effort.
3. The mediator shall provide one copy of a draft convening report to the Dynamac
Project Manager within five working days of the conclusion of the convening effort.
The report shall:
a. Summarize the results of the convening contacts, including such items as:
(1) Who was contacted, representing what organization, during this period;
and
(2) Identification and discussion of the issues which the parties agree will be
considered as part of the allocation process, and the issues which the
parties choose not to have addressed in the allocation process.
b. A discussion of the chances of a successful allocation process and the goals and
purpose of the process from the viewpoints of the affected parties.
c. Recommendation of potential additional parties that should also participate in the
mediation process.
d. If the mediation process appears to be feasible, the report shall include a design
for the process including such things as:
(1) The structure and type of meetings between/among the mediator and the
affected parties;
(2) The expected number, length, location and frequency of meetings;
(3) The research, data or information necessary prior to or during the
process;
( 4) The estimated budget for the process as designed and proposed by the
mediator; and
(5) Whether an orientation session is recommended prior to the first
meeting.
(6) Commitments from the effected parties to fully participate in the
mediation process.
e. If a consultative process in not recommended, the mediator may suggest other
processes that could accomplish the goals of achieving a voluntary allocation
agreement.
The Dynamac Project Manager will review the draft convening report and provide
comments and revisions as necessary. The mediator will prepare the final report
incorporating the Dynamac Project Manager’s comments and revisions as appropriate.
The mediator shall distribute three copies of the final report to the Dynamac Project
Manager, and one copy to each of the parties interviewed for the report.
4. If Dynamac decides to proceed, the mediator shall submit an initial draft of operational
ground rules, for approval by Dynamac.
5. As a part of the convening effort, the mediator may arrange for and facilitate an initial
organizational meeting of the parties to discuss the form of the process and the parties
to be involved, to get commitments to go forward from each of the parties, discuss the
issues involved, and/or the ground rules for the process.
B. Mediation Activities
This phase will implement the design of the mediation process as accepted by the Dynamac
Project Manager based upon the final convening report recommendations.
1. At the initial meetings, the mediator shall assist the group in further developing and
refining the ground rules or operating procedures of the process.
2. The mediator shall provide a draft agenda to the Dynamac Project Manager for each
meeting. The mediator shall distribute the final agenda to the Dynamac Project
Manager and to participants in the mediation process.
3. The mediator shall facilitate all plenary, subcommittee and work group sessions. As
facilitator, the mediator shall assist participants in articulating their interests,
identifying areas of agreement, and developing consensus solutions to the problems that
divide them. As facilitator, s/he shall keep the parties talking, listening, and moving
(as much as possible) towards the goal of the process.
4. The mediator shall communicate in person, by phone or in writing with process
participants to ensure that issues and concerns have been communicated accurately and
that all participants are adequately prepared for the next meeting.
5. The mediator will be required to provide draft meeting summaries to the Dy~amac
Project Officer and the participants. The necessity for and the extent of the summary
will be decided between the mediator and the Dynamac Project Manager during an oral
briefing following each meetings. The facilitator shall distribute final meeting
summaries to the Dynamac Project Officer and participants.
6. The mediator shall provide meeting facilities and support for all meetings. If
arrangements must be made for meetings to be held outside of the mediator’s facility,
Dynamac staff will provide logistical support in obtaining appropriate meeting
facilities.
7. The mediator shall furnish a draft report of the mediation process to the Dynamac
Project Officer within 15 working days of process completion. The report shall
include:
a. An executive summary of the process including a brief background, an overview
of the issues discussed, and the resolutions of the issues;
b. Final meeting summaries with relevant and necessary attachments;
c. Relevant substantive correspondence between the mediator and the participants
and between the participants (if available to the mediator); and
d. A process evaluation by the mediator summarizing the results of the process,
analysis of the issues, procedural lessons learned, and recommendations for
improvement.
The Dynamac Project Officer will review the draft final report and provide comments
and revisions as necessary and appropriate. The mediator shall prepare the final report
incorporating the comments and revisions as appropriate to maintaining the third-party
neutral status of the mediator. The mediator shall provide three copies of the final
report to the Dynamac Project Manager and one copy to each party involved in the
process.
DVNAMAC
CORPORATION
Environmental Services Page 1of3
PRICE NEGOTIATION MEMORANDUM
PRIME CONTRACT NUMBER: 68-W4-0039
PROJECT NAME: Alternative Dispute Resolution for the West Lake Landfill
EPA WORK ASSIGNMENT MANAGER: Mr. Steve Kinser
DESCRIPTION OF REQUIREMENT:
A. Convening Activities (PHASE I)
1. The allocator shall contact key parties for the PRPs as identified by Dynamac Project
Manager. The allocator shall discuss the goals and purpose of the proposed allocation
process, as well as the technical or substantive issues involved in the allocatipn process.
If initial contacts with the key parties reveal that an allocation process is not feasible, the
allocator shall notify Dynamac, explain the difficulties (lack of interest, unequivocal
opposition of a key party, disagreement about the definition of the problem, wrong forum
or process, etc.) and await the Oynamac Project Manager’s decision on whether to
proceed with the allocation process.
2. The allocator shall provide oral reports as needed to the Dynamac Project Manager as
needed pertaining to the general progress of the convening effort.
3. The allocator shall provide one copy of a draft convening report to the Dynamac Project
Manager within five working days of the conclusion of the convening effort. The report
shall:
a. Summarize the results of the convening contacts, including such items as:
(1) Who was contacted, representing what organization, during this
period; and
(2) Identification and discussion of the issues which the parties agree
will be considered as part of the allocation process, and the issues which
the parties choose not to have addressed in the allocation process.
b. A discussion of the chances of a successful allocation process and the goals and
purpose of the process from the viewpoints of the affected parties.
c. Recommendation of potential additional parties that should also participate in the
consultative process.
The Dynamac Building, 2275 Research Boulevard, Rockville, f\:ID 20850-3268 Telephone: (301) 417-9800, Fax: (301) 417-9801
DVNAMAC
CORPORATION
Environmental Services Page 2of3
PRICE NEGOTIATION MEMORANDUM
PRIME CONTRACT NUMBER: 68-W4-0039
PROJECT NAME: Alternative Dispute Resolution for the West Lake Landfill
EPA WORK ASSIGNMENT MANAGER: Mr. Steve Kinser
d. If the allocation process appears to be feasible, the report shall include a design
for the process including such things as:
(1) The structure and type of meetings between/among the allocator
and the affected parties;
(2) The expected number, length, location and frequency of meetings;
(3) The research, data or information necessary prior to or .during the
process;
(4) The estimated budget for the process as designed and proposed
by the allocator; and
(5) Whether an orientation session is recommended prior to the first
meeting.
(6) Commitments from the effected parties to fully participate in the
allocation process.
e. If a consultative process in not recommended, the allocator may suggest other
processes that could accomplish the goals of achieving a voluntary allocation
agreement.
The Dynamac Project Manager will review the draft convening report and provide
comments and revisions as necessary. The allocator will prepare the final report
incorporating the Dynamac Project Manager’s comments and revisions as appropriate.
The allocator shall distribute three copies of the final report to the Dynamac Project
Manager, and one copy to each of the parties interviewed for the report.
4. If Dynamac decides to proceed, the allocator shall submit an initial draft of operational
ground rules, for approval by Dynamac.
The Dynamac Building, 2275 Research Boulevard, Rockville, MD 20850-3268 Telephone: (301) 417-9800, Fax: (301) 417-9801
Redacted
Redacted
Redacted
Redacted
FOIA Exemption 4
DYNAMAC CORPORATION INTERNAL MEMORANDUM
DATE:
TO:
FROM:
SUBJECT:
May 16, 1997
Dave Biver, Vice-President, Contracts
Alan Cummings
Mediator Selection Recommendations
Work Assignment, C07023
On May 9, 1997, at 1335 Hours CDT, the mediator selection committee convened via conference
telephone call to select a mediator to conduct the voluntary allocation process defined in the
Statement of Work for Work Assignment C07023. The selection committee consisted of:
Alan Cummings, Dynamac, work assignment project manager;
Ron Harris, Dynamac, attorney with ADR experience; and
Dave Dekkar, Arent Fox Kintner Plotkin & Kahn ,consulting attorney with extensive ADR
experience.
The selection committee reviewed two proposals that were received by Dynamac on April 24, 1997,
in response to a solicitation issued by Dynamac and forwarded to members of the selection
committee on April 25, 1997. Proposals were submitted by:
J.A.M.S/Endispute, naming William Hartgering as the mediator candidate; and
Clean Sites, naming Kathleen Whitby as the mediator candidate.
The selection committee evaluated each proposal in three areas:
Technical qualifications;
Convening plan content and specificity; and
Proposed budgets for the convening process.
Technical Qualifications
In the areas of education, training, and certifications, both proposed mediators met the evaluation
criteria in that both are attorneys with litigation experience, both are bar members, both are
recognized as mediators and arbitrators by professional organizations.
Although information contained in the proposals indicated that the Clean Sites candidate had more
experience in dealing with Superfund issues, the Endispute candidate clearly had more ADR
experience in successfully dealing with complex mediation/arbitration issues, many of which involved
May 16, 1997 Page 1
Superfund allocations. This experience includes a past and current landfill mediation effort. In the
Committee’s view, a basic knowledge of Superfund issues is critical, but the success of the mediation
will ultimately depend more upon the selected individual’s skill and experience as a mediator, than
upon the depth of the individual’s knowledge of Superfund Issues.
Clean Sites proposed a team approach to mediation, while Endispute proposed a single mediator
with logistic support provided by Endispute. The selection committee agreed that a team approach
would likely be less effective than a single mediator. Slight delays that may be caused by scheduling
problems with a single mediator will likely be more favorable than having the parties in the
mediation process deal with more than one mediator at different stages in the process. For reasons
of consistencyr and maintenance of the trust developed by the mediator in the early mediation stages,
the selection committee favored the single mediator approach.
In the areas of Conflict of Interest and availability, the selection committee agreed that both
proposals were acceptable.
Summary: In the area of Technical Qualifications, the selection committee slightly favored the
Endispute proposal based primarily on the overall ADR experience of the proposed
mediator and the single mediator approach.
Convening Plan
The selection committee compared the proposed convening plans with the requirements for the
convening process contained in the Statement of Work (SOW) in the mediation solicitation.
The convening plan proposed by Endispute precisely followed the solicitation SOW. The plan
clearly proposed three parts to completing the convening phase:
1. Introductory telephone conferences;
2. Joint preliminary meeting; and
3. Follow-up individual PRP meetings.
The plan contained specific objectives for each part and an estimated effort to complete each part.
The proposal specified that at the end of this process the PRPs would have a process in place for
mediation efforts or would have decided that the matter is not yet ready to mediate. The proposed
procedure clearly recognizes that this mediation process may not proceed past the convening stage
at this time.
The convening plan proposed by Clean Sites contained an overview of the convening process, but
did not tie the objectives into an action plan. Although there are usually several consecutive and
concurrent activities associated with this activity, Clean Sites proposed project approach was not
clear to the selection committee. It contemplated many possible scenarios that are beyond the
Convening Stage and did not contain any milestones to evaluate progress and likelihood of success
that were clear to the selection committee. The plan did indicate that parties involved in the process
might decide that this process may not be desirable at all or not desirable at this time.
Summary:
May 16, 1997
The selection committee favored the convening plan submitted by Endispute. The
plan was divided into easily understandable phases, contained clear and specific
objectives for each phase, and an estimated effort for each phase.
Page 2
Proposed Budget
The selection committee reviewed the proposed budgets from two perspectives; 1) As compared to
the effort estimated in the proposed convening plan, and 2) as compared to the other proposal.
The En dispute proposal contained hourly rate information for the number of PRPs identified in the
Background Section of the solicitation. Utilizing the effort estimates contained in the convening
plan, an estimated cost range was easily determined. Support for the mediation efforts was provided
as a fixed percentage of the fee for services. The proposal did not contain an estimate of direct
charges for travel associated with the St. Louis meeting. The top range of effort specified in the cost
estimate was 28 hours professional LOE.
The Clean Site proposal contained a matrix indicating tasks and professional category, and the
estimated effort for each. The selection committee could not clearly identify the tasks in the matrix
based on the proposed convening plan. Although one task was identified as Convening, the overall
cost estimate for the convening process was based on the total effort identified in the matrix. The
selection committee could not break out level of effort to phases of the convening process. The total
professional LOE estimatec.l in the Clean Sites budget was 164 hours, with 32 hours of clerical
support.
Comparatively, the En dispute budget was substantially less for a “worst-case scenario” than the Clean
Sites budget.
Summary: The selection committee favored the budget submitted by Endispute. The budget
was clearly linked to specific action plan phases. The Endispute budget was
substantially less than that submitted by Clean Sites. The selection committee
conclude.d, based on plan specificity, that the costs proposed by Endispute for the
convening process were reasonable for the proposed plan (not artificially low when
compared to the plan).
Conclusions and Recommendations
Based on the conclusions contained in the summaries for each evaluation section, the selection
committee recommends the selection of the mediator proposed in the Endispute proposal. The
committee favored the Endispute proposal in each of the three evaluation areas for the reasons
specified.
May 16, 1997 Page 3
ADR Associates
1630 S. 8th St.
Rogers, AR
72756
Telephone: (501) 621-5455
American Arbitration Association
13455 Noel Road, S.te. 1750
Dallas, TX
75240
Telephone: ( 405) 235-4443
Clean Sites, Inc.
53 W. Jackson Boulevard
Chicago, IL
60604
Telephone: (312) 554-0900
Endispute, Inc.
70 W. Madison Street
Chicago, IL
60602
Telephone: (312) 739-0900
Indiana Environmental Institute, Inc.
150 W. Market
Indianapolis, IN
46204
Telephone: (317) 635-6018
Institute for Environmental Assessment
7877 L Street
Omaha, NE
68127
Telephone: ( 402) 339-6240
Keystone Center
199 S. Herlong Avenue
Rock Hill, SC
29732
Telephone: (803) 324-1800
The Mediation Institute
7216 Walnut Cr. Dr.
Oklahoma City, OK
73142
Telephone: (405) 528-1121
Resolve
401 Ohio
Terre Haute, IN
47801
Telephone: (812) 231-1789
Resource Associates
P. 0. Box 1505
Arlington Heights, IL
Telephone: (847) 255-1400
Western Network
616 Don Gaspar A venue
SantaFe,NM
87501
Telephone: (505) 982-9805
‘i
J · A · M · S Innovative Solutions To Conflict
END IS PLJTE 222 S. Riverside Plaza • Suite 1850 • Chicago, IL 60606 • 312-655-0555 • Fax 312-655-0644
PROPOSAL FOR
COST ALLOCATION AND MEDIATION SERVICES
WILLIAM E. llARTGERING, MEDIATOR
WEST LAKE LANDFILL SITE
ST. LOUIS, MISSOURI
JAMS/ENDISPUTE
222 SOUTH RIVERSIDE PLAZA SUITE 1850
CHICAGO, ILLINOIS 60606
CONTACT: WILLIAM HARTGERING 312-655-9197
Introduction
On behalf of JAMS/ENDISPUTE, we appreciate the opportunity to respond to your request for
information. We propose William Hartgering, now an independent contractor from our
Chicago office, for your consideration. Included below are responses to the 6 areas outlined
in Dynamic Corporation’s April 14 letter (Dynamic RFI):
1-2. Qualifications, Experience & Training
3. Process Description (including estimated time for Phase I)
4. Proposed Hourly Rate
5. Three References, and
6. Conflict ofinterest/ Availability.
I & II. “Academic” Qualifications, Relevant Experience and Specialized Training
A. Relevant Experience. As reflected in the attached
• “Selected Environmental and Related Experience” (Ex. 1 ),
•”Representative Complex, Multiparty, Highstakes Matters” (Ex. 2),
• general vitae (Ex. 3), and his
• “Representative Commercial Mediation and Arbitration References” (Ex. 4),
Bill has been a full time mediator since 1981. Having established the Chicago
JAMS/ENDISPUTE office in 1982, his mediation experience includes hundreds of complex,
multi party matters in over 40 states and foreign countries involving hundreds of major
corporations and 8 different federal agencies.
Prior to 1981, he practiced with multicity law firms, concentrating on commercial,
employment, real estate and insurance related litigation, including clients with environmental
issues. He received his JD from Northwestern University School of Law, Chicago, Illinois,
where he was appointed to the Law Review.
The “Environmental and Related Experience” (Ex. 1) includes brief descriptions of
numerous representative matters. We would enjoy the opportunity to provide additional
information on any of them. A recent environmental mediation which might be of particular
interest to you in making your selection of a mediator here. It involv~d a:
• Cliemical/Pesticide Plant Superjund Site, 5 separate areas, $40-70M Allocation.
50+ year old Chemical and Pesticide Plant site, 5 separate areas involving different
combinations of 9 corporate parties (and the EPA as a participant) and an estimated $40-
70M clean up. After 6 years of bitter litigation, there were widely divergent views on key
William Hartgering: West Lake Landfill Site Mediation Proposal
issues including “Aceto,” alter ego and successor liability, relevancy of volumetric data,
substantial “orphan share” and toxicity issues.
Chosen as allocation consultant to work with a former judge, Bill ended up working as a
co-mediator. Each party submitted responsive memoranda and extensive exhibits and presented 4
days of argument. The mediators met with the parties separately on a site by site basis. The
matter was resolved within about 4 weeks of the start of the joint meetings with the parties.
PRPs with literally hundreds of complex Superfund site disputes described this as one of
the most complex matters they had seen.
Also potentially relevant to your selection process is a matter not described in the material:
• Pending Landfill Superfund Site Allocation. Bill was recently chosen as the
mediator/allocator for a site involving Superfund dollars in southern Wisconsin after a lengthy,
apparently nationwide search initiated by the federal court which suggested mediation. It will
be mediated later this spring. It involves the EPA and 5 PRPs.
The mediation schedule has not been confirmed, but I do not believe it will pose a
problem in your matter if Bill were to be chosen.
• Related Allocation Experience. Exhibits 2 and 3 also describe numerous complex,
multiparty, high stakes matters which similarly involved difficult allocations of liability and
damages among numerous parties. Due to focused preliminary meetings and managed, issue
related joint sessions, most of these matters were completed with a week of the opening of the
joint mediation sessions.
• Mediations involving Federal Agencies. Matters involving Federal agencies involve
unique issues, interests and procedural considerations. Bill has successfully mediated matters
involving 8 separate agencies, and has recently been chosen for a matter involving the DOE in
Louisiana after being proposed by the other side (see below). Many matters involved agencies
who were unfamiliar wjth mediation, particularly in large, multi issue matters. Each involved
2 to 12+ additional private parties, several of which were represented by counsel who had
mediated with Bill in previous complex matters.
B. Specialized Training.
•Co-Trainer for Basic and Advanced EnvironmentalADR Training. Bill recently
completed service as a co-trainer for both a basic and an advanced ADR (Alternative Dispute
Resolution) workshop for Region V of the EPA, having been invited by RESOLVE as part of
their contract to provide ADR training to the EPA regions.
2
William Hartgering: West Lake Landfill Site Mediation Proposal
• Co-Trainer for ADR and Advanced Negotiation for tlze Oregon Department of
Natural Resources and tlze Attorney General
•Advanced ADR Works/tops and Presentations. Bill has both lead and participated in
dozens of “Advanced Mediation” and Group Leadership Training, Advanced ADR workshops
and presentations. He has served as
– Adjunct Faculty of the Northwestern University Kellogg School of Business and the
School of Law (teaching negotiation and ADR)
– Faculty for the National Institute for Trial Advocacy (NITA-Negotiation Training), and
– Sole leader for Administrative Conference of the United States (ACUS) ADR
workshop for ADR liaisons for most of the major federal agencies.
III. Brief Description of Process
You have asked for a “brief’ description of how Bill might proceed as the mediator,
including an estimate of the hours for Phase I. Bill describes the Mediation in 3 Phases:
Convening, Completing the “Information Exchange,” and the Separate & Joint Meetings.
A. Phase I, the “Convening Phase.”
We have a limited amount of information at this point, particularly with reference to
the level of the parties’ interest in and experience with mediation. Based on an assumption
that the parties here may not be as far along on their decision to mediate as they generally are
in his cases, Bill would propose a simple 3 part

Post

1997-04-18 – EPA – West Lake Landfill – Alternative Dispute Resolution

WEST LAKE LANDFILL
ALTERNATIVE DISPUTE RESOLUTION
WORK PLAN
Volume I: Narrative Work Plan
Contract No. 68-W4-0039
Work Assignment No. C07023
April 18, 1997
Prepared for:
U. S. Environmental Protection Agency
Region VII
Kansas City, KS 66101
Prepared by:
Dynamac Corporation
5700 Broadmoor
Suite 701
Mission, KS 66202




WEST LAKE LANDFILL
ALTERNATIVE DISPUTE RESOLUTION
WORK PLAN
Volume I: Narrative Work Plan
Prepared for:
U. S. Environmental Protection Agency
Region VII
Kansas City, KS 66101
Contract No.
Work Assignment No.
Dynamac No.
Site No.
Date Prepared
Date Amended
EPA Work Assignment Mgr.
Telephone No.
Dynamac Project Manager
Telephone No.
: 68-W4-0039
: C07023
: 7023
: 14
: April 18, 1997
: Steve Kinser
: (913) 551-7728
: Alan Cummings
: (913) 831-0400
—-


CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
TABLE OF CONTENTS
Alternative Dispute Resolution
Work Assignment No. C07023
1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.1 WORK ASSIGNMENT HISTORY/BACKGROUND . . . . . . . . . . . . . . 1
1.2 SCOPE OF WORK ASSIGNMENT . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2.0 TECHNICAL APPROACH . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
2.1 TASK 1: PROJECT MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . 4
2.1.1 Provide Required Reports of Work . . . . . . . . . . . . . . . . . . . . . . 4
2.1.2 Conflict of Interest Screening . . . . . . . . . . . . . . . . . . . . . . . . . 4
2.1.3 Oversight by the Program Manager . . . . . . . . . . . . . . . . . . . . . 5
2.2 TASK 2: WORK PLAN DEVELOPMENT . . . . . . . . . . . . . . . . . . . . . 6
2.2.1 Work Plan Initiation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.2.2 Technical Scoping Meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.2.3 Work Plan Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.3 TASK 3: CONTRACT REQUIRED REPORTS . . . . . . . . . . . . . . . . . . 8
2.4 TASK 4: CLOSEOUT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
2.5 TASK 5: ARBITRATOR SELECTION . . . . . . . . . . . . . . . . . . . . . . . 10
2.6 TASK 6: CONVENING ACTMTIES . . . . . . . . . . . . . . . . . . . . . . . . 12
2.7 TASK 7: MEDIATION SUPPORT . . . . . . . . . . . . . . . . . . . . . . . . . . 13
3.0 DELIVERABLES AND SCHEDULE………………………….. 14
4.0 PERSONNEL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
5.0 SUBCONTRACTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
6.0 EXCEPTIONS TO THE WORK ASSIGNMENT OR ANTICIPATED
DIFFICULTIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
7.0 QUALITY ASSURANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
ATTACHMENT A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Work Plan
West Lake Landfill
April 18, 1997
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CERCLA Enforcement Support Setvices, Region VII
Contract No. 68-W4-0039
1.0 INTRODUCTION
1.1 WORK ASSIGNMENT HISTORY/BACKGROUND
Alternative Dispute Resolution
Work Assignment No. C07023
West Lake Landfill (the “Site”), Operable Unit No. 1, involves a remedial
investigation/feasibility study (Rl/FS) being performed by Cotter Corporation (N.S.L.),
Laidlaw Waste Systems (Bridgeton), Rock Road Industries, Inc., and the U.S. Department
of Energy.
In 1966, the Atomic Energy Commission (AEC) sold 8, 700 tons of leached barium sulfate,
together with other radioactive residues to Continental Mining and Milling Company. The
radioactive residues were generated as by-products of uranium processing performed by the
AEC’s contractor. These processing residues were stored at the AEC St. Louis Airport
Storage Site (SLAPSS). Continental Mining moved the radioactive residues to its facility
at 9200 Latty Avenue in Hazelwood, Missouri. Eventually, Cotter purchased the radioactive
residues and shipped all but the 8,700 tons of leached barium sulfate to its processing
facility in Colorado.
In 1973, approximately 8,700 tons of radioactively contaminated leached barium sulfate
residues were mixed with approximately 39,000 tons of soil, and the entire amount was
disposed of in two areas of the Site. This material resulted from decontamination efforts
undertaken by Cotter at 9200 Latty Avenue, where the residues had been stored. Studies
have indicated that these two areas of the landfill are contaminated with uranium-238,
uranium-235, thorium-230, and radium-226. In addition to the radioactive materials in the
landfill, groundwater at the Site is also contaminated with radioactive materials as well as
other hazardous substances.
In 1993, EPA entered into an Administrative Order on Consent (AOC) for the performance
of a RI/FS at the Site. As indicated, Cotter Corporation, Laidlaw Waste Systems, Inc.,
Rock Road Industries, Inc., and the U. S. Department of Energy were signatories to this
AOC.
To date, the four respondents to the AOC have shared the cost of the work equally. While
this allocation has worked for the Rl/FS phase of the work, the upcoming remedial
design/remedial action (RD/RA) wil1 be substantially more costly, and some of the parties
may have difficulty paying a 25% share. The Rl/FS is currently in progress, so no Record
of Decision (ROD) has been issued and it is not expected that a ROD will be issued before
this al1ocation process is complete.
Despite the absence of projected remedial costs, the four respondents to the AOC have
Work Plan
West Lake Landfill
Apnl 18, 1997
Page 1


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…..
CERCLA Enforcement Support SeIVices, Region VII
Contract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. C07023
indicated a willingness to proceed with an allocation effort. Since DOE is a respondent to
the AOC and a sister federal entity to the U. S. EPA, AOC respondents have agreed to use
a third-party neutra] allocator, and that this process would best serve the interests of the
parties and satisfy EPA’s desire to maintain neutrality.
Additionally, the private party PRPs have requested that in any allocation performed, that
the allocator give consideration and possibly allocate some responsibility to an “orphan”.
The orphan is B&K Construction Company, which acted as the transporter of the
radioactive materials for Cotter Corporation. It has been alleged that B&K actually chose
the Site for disposal of the wastes, although there appears to be some conflicting
information on this point.
As described by the U. S. Environmental Protection Agency (EPA) in the Work Assignment
Statement of Work (SOW), EPA requires that a third party-neutral allocator be obtained
to assist the AOC respondents develop a voluntary allocation of costs associated with this
site. Dynamac will locate and retain an allocator agreeable to all respondents and the U.
S. EPA, who will represent the orphan share in this process.
Dynamac will provide the allocator and perform the oversight functions described in the
SOW in such a manner as to maintain a neutral approach to all parties involved in the
allocation process.
1.2 SCOPE OF WORK ASSIGNMENT
In the Statement of Work within the work assignment, EPA has identified three primary
functions to be performed by Dynamac:
1. Dynamac will locate and obtain a professional allocator/arbitrator with experience
in dispute resolution pertaining to environmental Jaws and regulations to facilitate
the voluntary a11ocation process;
2. Dynamac will identify and contact the affected parties in this process pursuant to
SOW requirements and conduct activities described in Section B of the SOW,
“Convening Activities”; and
3. Dynamac wil1 provide subcontract oversight and assist the allocator as required in
Section C of the SOW, 11Allocation11

The Statement of Work also provides for project management, work plan development, and
the preparation and submission of contract required reports.
Work Plan
West Lake Landfill
April 18, 1997
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CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
These functions are organized into seven tasks:
Task 1 – Project Management
Task 2 – Work Plan/Cost Estimate
Task 3 – Contract Required Key Reports
Task 4 – Closeout
Task 5 – Allocator Selection/Subcontracting Activities
Task 6 – Convening Activities
Task 7 – Allocation Activity Support
Alternative Dispute Resolution
Work Assignment No. 0)7023
All support provided under this Work Assignment is described in Section 2.0, Technical
Approach, which was developed based upon the following:
1) The SOW dated March 10, 1997; and
2) The technical guidance and clarification provided during the technical scoping
meeting conducted on March 5, 1997.
Work Plan
West Lake Landfill
April 18, 1997
Page 3



CERCLA Enforcement Support Seivices, Region VII
Contract No. 68-W4-0039
2.0 TECHNICAL APPROACH
Alternative Dispute Resolution
Work Assignment No. C07023
This section describes the technical, management, and administrative activities proposed by
Dynamac to meet the Work Assignment objectives as described in Section 1.2 and as
provided in the ESS contract. Section 2.1 describes project management activities. The
remaining sections outline the Dynamac Team’s approach to completing the technical
requirements defined in the Work Assignment Scope of Work and further clarified at the
March 5, 1997 technical scoping meeting.
2.1 TASK 1: PROJECT MANAGEMENT
Performance of this task requires the successful completion of the following sub-tasks that
are identified and discussed in this section:
* Provide required monthly work assignment technical status reports to EPA;
* Provide personnel conflict of interest control;
* Oversight by the Program Manager; and
* Subcontractor oversight and reporting.
Quality Assurance/Quality Control (QNQC) is an integral part of performance of each task
of the Work Assignment. The level of effort and costs associated with providing QNQC
are included in the costing of each task.
2.1.l Provide Required Reports of Work
This work assignment specified a period-of-performance (POP) of four and one-half months,
from March 10, 1997 to July 31, 1997. Under this task, Dynamac will prepare the Work
Assignment Monthly Status Reports (monthly status reports or MSRs) throughout the
period that this Work Assignment is active. The MS Rs will describe the legal, technical and
financial progress of the Work Assignment during the previous month and substantiate any
expenditures, including direct labor, other direct costs (ODC), and travel associated with
the Work Assignment.
2.1.2 Conflict of Interest Screening
Dynamac initiated both organizational and personal conflict-of-interest (COi) screening
activities upon receipt of the Work Assignment. Following this initial step, Dynamac’s
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West Lake Landfill
April 18, 1997
Page 4


..
CERCLA Enforcement Support Seivices, Region VII
Contract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. C07023
Contracts Manager and Officer-in-Charge will complete the COI screening and submit the
results to EPA within 20 days of receipt of the PRP list.
Concurrent with the processing of the organizational COI screening and certification,
Dynamac staff assigned to this Work Assignment also completed personal COi screening
and disclosure forms. This information will be maintained on file by Dynamac.
2.1.3 Oversight by the Program Manager
The Dynamac Acting Program Manager, Mr. Alan Cummings, will provide oversight for the
Work Assignment as the Dynamac Project Manager. This oversight includes:
• Monitoring the work assignment to ensure that it remains on schedule and within
budget;
• Ensuring that appropriate Dynamac resources, including qualified personnel, are
available for the Work Assignment;
• Ensuring that all subcontract activities are properly monitored and reported; and
• Ensuring compliance with provisions of the ESS contract.
LOE and costs estimated for this task include completing the Dynamac corporate and
personnel COI searches and certifications, subcontractor monthly technical reports,
monitoring deliverable schedules and financial progress, and the preparation of
correspondence required by the ESS 7 Contract. Dynamac estimates include the following:
P-4 4 hours:
P-3 18 hours:
Work Plan
West Lake Landfill
This time includes COI certification, work plan and cost estimate
review and approval, approval of the allocator solicitation (contract
elements and requirements), and approval of the allocator subcontract.
This time includes the preparation of local technical reports required
by the contract, oversight for the subcontractor for technical and
budget issues (including scheduled deliverables), and preparation of
correspondence required by the contract.
Apnl 18, 1997
Page5




….
CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
2.2 TASK 2: WORK PLAN DEVELOPMENT
2.2.1 Work Plan Initiation
Alternative Dispute Resolution
Work Assignment No. C07023
Upon receipt of the Work Assignment, Dynamac initiated activities necessary to
development of a work plan. Activities completed include:
* Acknowledgement of receipt of the Work Assignment;
* Establishment of master and project files specific to this Work Assignment;
* Copying and distribution of the Work Assignment document to appropriate
staff;
* Assignment of Work Assignment-specific tracking numbers to accurately track
all Work Assignment expenditures; and
* Conducting initial meetings to determine the staffing approach for the Work
Assignment to best meet EPA’s requirements.
2.2.2 Technical Scoping Meeting
Dynamac prepared for and attended a technical scoping meeting with EPA staff on March
5, 1997. The purpose of this technical scoping meeting was to obtain clarification of the
SOW and a better understanding of technical requirements and upcoming deadlines
associated with the Work Assignment to enable Dynamac to develop a focused work plan
and cost estimate.
Dynamac representatives at the technical scoping meeting were:
Mr. Alan Cummings, Acting Program Manager
EPA representatives included:
Mr. Steve Kinser, EPA WAM
Mr. Ron Stewart, EPA CO
Mr. Larry Stafford, EPA
Mr. Dave Hoefer, EPNCNSL
Several issues that impact the technical approach, deliverables, and expenditures associated
Work Plan
West Lake Landfill
April 18, 1997
Page 6





CERCLA Enforcement Support Services, Region VII
C’.ontract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. C07023
with this Work Assignment were discussed during the technical scoping meeting. Important
direction and clarification provided by EPA during the meeting are discussed in Sections
2 and 6 of this work plan.
2.2.3 Work Plan Development
Following the technical scoping meeting, Dynamac completed development of this Work
Plan and associated Cost Estimate. The Work Plan and Cost Estimate were reviewed by
the Dynamac Contracts Manager, Mr. David Biver, to ensure compliance with the Region
VII ESS Contract. Dynamac submitted the work plan on March 17, 1997.
The estimated cost of accomplishing the tasks set forth in this work plan was presented in
Volume II of the original work plan. The initial cost estimate submitted with the work plan
does not include allocator costs. Since Task 5 requires that an allocator be selected who is
agreeable to all parties concerned, subcontract costs cannot be included at this point. The
first cost estimate only contains estimated costs for Dynamac personnel.
Dynamac will submit an updated cost estimate that includes subcontractor (allocator)
estimates after the allocator selection process is completed, and pursuant to the SOW for
this work assignment, after completion of the convening phase of this work assignment.
LOE and costs listed for Task 2 include the effort necessary to attend scoping meetings,
develop the work plan and related assumptions, and complete a cost estimate for this work
assignment that details labor, ODCs, and travel at the task level and by professional labor
level. Dynamac estimates the following:
P-3 30 Hours:
P-2 6 Hours:
Work Plan
West Lake Landfill
This includes attending technical scoping meetings, preparation of the
initial work plan, preparation of the original cost estimate, preparation
of the second cost estimate to include allocator costs from the initial
allocator acquisition, and the third cost estimate required by the SOW
upon completion of convening activities.
This includes the review and approval of three cost estimates (as
required by the SOW) by contract specialists to ensure that they are
accurate and are compliant with contract requirements.
April 18, 1997
Page 7



CERCIA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. Ol7023
2.3 TASK 3: CONTRACT REQUIRED REPORTS
Dynamac will prepare and submit all reports required by the contract with the exception of
the Monthly Status Reports, which will be prepared pursuant to Task 1. LOE listed for this
task is for the preparation of the work assignment monthly financial reports and
subcontractor financial tracking reports. Dynamac estimates include the following:
P-2 24 Hours:
Work Plan
West Lake Landfill
This includes generation of work assignment monthly financial
reporting and invoice backups in Kansas City, and financial tracking
and reporting on subcontractor invoices in Rockville for the specified
period of performance.
April 18, 1997
Page 8



CERCLA Enforcement Support Seivices, Region VII
Omtract No. 68-W4-0039
2.4 TASK 4: CLOSEOUT
Alternative Dispute Resolution
Work Assiglllllent No. C07023
This task includes efforts related to the support of project completion and closeout activities
in both the technical and financial areas as well as file maintenance and record indexing.
Typical activities include: review and consolidation of all project and master files to ensure
files are complete and in order according to EPA Region VII file guidance; preparation of
Work Assignment file indexes identifying all relevant file material; QA review of the final
structure and index, copying and providing relevant files to EPA; preparation of Work
Assignment files for archived storage; and review an documentation of the final financial
status of the Work Assignment. Dynamac estimates 6 P-2 hours and 4 P-3 hours to
complete the work described.
Work Plan
West Lake Landfill
April 18, 1997
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CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
2.5 TASK 5: ARBITRATOR SELECTION
Alternative Dispute Resolution
Work Assignment No. C07023
The statement of work for this work assignment requires that Dynamac select an arbitrator
professional to act as the convener and allocator for this process. Since pre-approved
subcontractors for this contract either do not have professional arbitrators/allocators or are
prime contractors on other EPA contracts, Dynamac will solicit proposals from professional
arbitration/allocation persons or organizations to ensure, to the greatest extent possible, that
third-party neutrality is obtained.
Dynamac has determined that most of the arbitrators with strong qualifications in dispute
resolution pertaining to environmental laws and judicial proceedings are independent
practitioners affiliated with professional arbitration associations. These persons do not
respond to U.S. Government RFPs on a routine basis. Information obtained by Dynamac
from ADR professionals indicates that many highly qualified arbitrators would not likely
respond to a detailed subcontract RFP, but would respond to a simpler request for
proposals for consulting work. Information provided to Dynamac indicates that an
arbitrator with a strong litigation background or who has adjudicated similar litigation in the
appropriate areas of environmental law is necessary to the successful completion of this
process. Costs associated with the acquisition of a qualified and experienced arbitrator
should be offset by the efficiency with which the mediation effort is conducted.
Furthermore, information provided to Dynamac indicates that the arbitrator will require
confidential meetings with PRPs, a process difficult to execute under a subcontract with
subcontract reporting requirements.
Pursuant to FAR requirements, Dynamac developed a statement of work for the arbitrator
that includes a series of assumptions contained in the EPA SOW for this work assignment
and obtained from the technical scoping meeting conducted on March 5, 1997. Dynamac
developed a comprehensive evaluation criteria from which proposals will be evaluated,
pursuant to FAR requirements. Dynamac developed a list of professional
allocation/arbitration persons and organizations who have experience in negotiations
processes pertaining environmental law and regulation issues. Dynamac is soliciting
proposals from the identified arbitrators as a consultant to conduct the mediation activities
described in the EPA SOW.
Based on the proposals and the technical qualifications provided by the candidate
arbitrators, Dynamac will select an arbitrator to perform the tasks identified in the SOW.
Proposal review, arbitrator selection, and execution of the consulting agreement will be
conducted by the Dynamac Project Manager in Kansas City, a Dynamac employee in the
Chicago Office who is an attorney with ADR experience, and ADR counsel in Rockville.
Dynamac will attempt to ensure that the arbitrator selected will be able to competently
execute the tasks identified in the EPA SOW and minimize costs associated with this
Work Plan
West Lake Landfill
April 18, 1997
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..
..
CERCTA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. CXl7023
process. Dynamac estimates that 12 hours per person will complete the selection task and
provide the final arbitrator recommendation.
LOE estimates for this task includes the effort necessary to identify arbitrators; develop the
solicitation for bids; review submitted bids for costs and qualifications; select an arbitrator;
and facilitate consultant agreement execution. Dynamac estimates include the following:
P-4 2 Hours:
P-3 24 Hours:
P-2 27 Hours:
Assist in the development and review of the statement of work and
review the consultant agreement by contracts personnel.
This includes drafting a detailed statement of work and deliverable
schedule for inclusion in the arbitrator solicitation, review of proposals
received from arbitrators, and selection of the arbitrator to perform
the work.
This includes drafting the solicitation for the arbitrator, mailing,
tracking and reviewing arbitrator responses, participation in the
selection process, and drafting and executing a consultant agreement
with a cost ceiling.
Dynamac Counsel: Consulting, 12 hours total for review of the solicitation and
participation in the selection and recommendation process.
Work Plan
West Lake Landfil1
April 18, 1997
Page 11

CERCLA Enforcement Support Setvices, Region VII
Contract No. 68-W4-0039
2.6 TASK 6: CONVENING ACTMTIES
Alternative Dispute Resolution
Work Assignment No. C07023
Pursuant to the requirements contained in the EPA statement of work for this work
assignment, Dynamac will, in conjunction with EPA, identify and contact the key parties
who have agreed to participate in this voluntary allocation process. Dynamac will determine
the following from each key party to this process:
1. What the perceived goals and objectives are for this process;
2. What format that each key party requests be used for the allocation process and any
format to which the key party would object; and
3. Whether or not each party will agree to continue with the voluntary allocation
process utilizing the third-party neutral allocator selected by the process described
in Section 2.5 of this work plan.
This process will be conducted in conjunction with allocator selection activities described
in Section 2.5 of this work plan to ensure that all parties agree to this process before the
final selection of an allocator. Dynamac is utilizing this approach to minimize costs should
one or more parties not agree to continue with the voluntary allocation.
EPA has provided Dynamac with a list of four key parties to this allocation process.
Dynamac anticipates that approximately two hours LOE will be necessary to contact and
discuss the items listed with each key party, and approximately two hours to complete a
Jetter report to EPA summarizing the results of the interviews and discussions. This task
will be performed by the Program Manager. Dynamac estimates include 10 Hours of P-3
time for this effort.
The deliverable for this task will be a briefing that identifies the responses of each key party
to the proposed allocation process and the desire of each party to participate in the process.
Arbitrator LOE for convening activities will be charged to this task. Dynamac estimates that a
maximum of 20 hours should be sufficient for this task.
Work Plan
West Lake Landfill
April 18, 1997
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CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
2.7 TASK 7: MEDIATION SUPPORT
Alternative Dispute Resolution
Work Assignment No. C07023
Dynamac will provide oversight and support for the arbitrator selected for this voluntary
allocation process. This support will include the following efforts and tasks:
1. Provide a liaison between the selected arbitrator and EPA for issues other than
scheduled deliverables. This liaison is necessary to limit direct contact between the
arbitrator and EPA for issues other than EPA’s participation in the allocation
process representing the orphan share. LOE for managing scheduled deliverables,
other than meeting summaries, is included in the Project Management section of this
work plan.
2. Provide support to the arbitrator in arranging for meeting facilities and ensuring that
meeting notices and agendas are distributed to key parties in a timely manner.
3. Provide support to the arbitrator in dealing with contract issues not identified in the
Project Management section of this work plan.
4. Review and comment on the arbitrator’s meeting summaries and forward the
information to the EPA W AM.
Dynamac anticipates that issues wiII arise that will require liaison between the arbitrator and
EPA that are not addressed in this work plan. LOE listed for liaison activities allows
Dynamac to be responsive to arbitrator requests for guidance for issues not addressed in
the SOW. Dynamac estimates that 10 hours LOE should be sufficient to provide liaison
activities and contract issue support to the arbitrator for the period of performance specified
in the work assignment form received on March 6, 1997.
Arbitrator hours for mediation activities will be charged to this task.
Work Plan
West Lake LandfilJ
April 18, 1997
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CERCLA Enforcement Support Seivices, Region VII
Contract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. C07023
3.0 DELIVERABLES AND SCHEDULE
Deliverables identified in the SOW, the technical scoping meeting, and described m
individual technical approach tasks in Section 2.0 are summarized below.
Table 3-1. Deliverables Schedule
I DELIVERABLE II SUBMITIAL DATE I
TASK 2: Work Plan/Cost Estimate
Work Plan/Cost Estimate April 7, 1997
COi Certification March 31, 1997
Cost Estimate, 1st Revision Within 5 working days of arbitrator
selection
Cost Estimate, 2nd Revision Within 5 working days of receipt of
arbitrator convening report and cost
estimate
TASK 7: Allocation Activity Support
Convening Activity Report
Final Allocation Report
Interim Reports/Briefings
Work Plan
West Lake Landfill
Within 10 working days of the conclusion
of convening activities
Within 15 working days of the
completion of allocation activities
As needed
April 18, 1997
Page 14



CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. C07023
4.0 PERSONNEL
Dynamac has selected a work assignment staff based upon categories defined in the Region
VII ESS contract and appropriate to the nature of work in this Work Assignment. Key
Technical and Key Reports staff are those identified in the ESS Region VII contract. The
technical staff identified are available to provide support for this Work Assignment.
Additional or supplemental staff may be assigned to the Work Assignment to facilitate
meeting EPA deadlines. Supplemental staff will be assigned and managed to meet the
overall Work Assignment cost structure and will not increase expenditures, unless justified
by changes in the scope of work.
Table 4-1 provides a summary listing of the Dynamac staff who will provide support for this
Work Assignment. Resumes of these staff members are included in Attachment A.
Table 4-1. WORK ASSIGNMENT STAFF
NAME I LABOR I CATEGOR~
DYNAMAC CORPORATION
Biver, David P-4
Cummings, Alan P-3
Harris, Ron P-3
Luce, Judy P-2
Bishop, Annette P-2
Dekkar, Dave Consultant
Work Plan
West Lake Landfill
TITLE
NATURE OF SUPPORT
Contracts Manager.
Review of contractual procedures and
documents, COI database searches.
Program Manager.
Dynamac counsel, ADR experienced.
Key Reports Coordinator.
Contracts Specialist.
J.D., Professional Arbitrator
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CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
5.0 SUBCONTRACTING
Alternative Dispute Resolution
Work Assignment No. C07023
The statement of work for this work assignment specifies that a third-party neutral
arbitrator be selected to conduct the voluntary allocation process therein described. Since
Dynamac is a prime contractor for the EPA Region VII Enforcement Support Services
Contract and the pre-approved subcontractors for this contract either do not have a
professional arbitrator or have other EPA contracts, Dynamac will retain a professional
arbitrator as a consultant, as specified in Section 2.5 of this work plan, to ensure that the
arbitrator can function as a neutral third party to this process. The arbitrator will be
selected pursuant to the procedures contained in Section 2.5 of this work plan.
The statement of work for the subcontractor will contain the elements contained in Section
B of the EPA SOW, Convening Activities, and Section C, Allocation.
Additional professional services anticipated for this work assignment include professional
counsel with significant ADR experience for drafting the arbitrator solicitation and selecting
the final arbitrator candidate.
Consultant costs for the arbitrator are not included in the initial cost estimate for this work
assignment, since selection of other than a pre-approved subcontractor is a part of the initial
work assignment. Dynamac will submit a second cost estimate to EPA after proposal have
been received from the subcontractor solicitation process, and a third cost estimate upon
completion of convening activities.
Work Plan
West Lake Landfill
April 18, 1997
Page 16


CERCLA Enforcement Support Seivices, Region VII
Contract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. OJ7023
6.0 EXCEPTIONS TO THE WORK ASSIGNMENT OR ANTICIPATED DIFFICULTIES
The technical approach for this Work Assignment is based upon the SOW provided by EPA
and additional clarification and technical guidance provided during the March 5, 1997
technical scoping meeting. This Work Plan is based on assumptions and limitations which
were defined at the technical scoping meeting.
This Work Plan and subsequent Cost Estimate is based upon the following assumptions:
1. That the period of performance is not extended beyond July 31, 1997. If the POP
is extended, Project Management and Key Report functions will increase. These are
calculated on a monthly basis times the POP.
Work Plan
West Lake Landfill
April IS, 1997
Page 17







CERCLA Enforcement Support Seivices, Region VII
Contract No. 68-W4-0039
7.0 QUALITY ASSURANCE
Alternative Dispute Resolution
Work Assignment No. C07023
The Dynamac Quality Assurance/Quality Control (QNQC) Program Plan is incorporated
by reference into the contract governing this Work Assignment. The Work Assignment and
all subsequent activities and deliverables may be the subject of a random audit by the EPA
Contract QA Officer pursuant to the EPA QA Program Plan. If an audit is conducted, any
corrective action will be addressed in meetings with the key management staff of the ESS
contract.
All deliverables submitted under this Work Assignment are subject to the deliverable QA
review process described in Dynamac’s QA Program Plan.
Work Plan
West Lake Landfill
Apnl 18, 1997
Page 18



CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
ATIACHMENT A
DIRECT LABOR MATRIX
Alternative Dispute Resolution
Work Assignment No. C07023




…._ /_ ,.,
DIRECT LABOR MATRIX
PERCENTAGES BY TASK AND P LEVEL
Work Assignment No. C07023
TASK
Task 1
Task2
Task3
Task 4
Tasks
Task 6
Task 7
WA Totals II
P-4
2
2
4
(2%)
Task 1: Project Management
Task 2: Work Plan Development
Task 3: Contract Required Key Reports
Task 4: Closeout
P-3
16
30
4
24
10
10
94
(55%)
TECHNICAL LABOR
LOE Hours
(Percent of Total Technical LOE)
P-2
6
24
4
27
63
(36%)
Consultant
12
12
(7%)
Task 5: Arbitrator Selection
Task 6: Convening Activities
Task 7: Mediation Support
0
TOTAL
18
(11%)
36
(21%)
24
(14%)
8
(5%)
53
(38%)
10
(6%)
10
(6%)
171
(100%)









…..

CERCLA Enforcement Support Services, Region VII
C’..ontract No. 68-W4-0039
ATIACHMENT B
RESUMES
Alternative Dispute Resolution
Work Assignment No. C07023




,Alan S. Cummings
Academic Qualifications: B.A., Liberal Arts, University of Missouri at Kansas City, 1992
Specialized Training: OSHA 40-Hour Hazardous Waste Site Health and Safety Training
OSHA 8-Hour Hazardous Waste Site Supervisor Training
Experience:
EPA 40-Hour Air Surveillance for Hazardous Materials (165.4)
NOAA 40-Hour Oil Spills in Riverine Environments
EPA 32-Hour Chemical Safety Audit (165.19)
EPA/NOAA 16-Hour CAMEO-II DOS
University of Missouri 16-Hour Hazardous Materials Incident Analysis
PVCC 48-Hour Chemistry of Hazardous Materials
PVCC 48-Hour Hazardous Materials Tactics
UPRR 16-Hour Introduction to Hazardous Materials Incident Response
MO DNR 4-Hour Recognition and Identification of Hazardous Materials
DOT 8-Hour HMT-181 Training and Certification
8-Hour Radiation Safety Course
8-Hour Environmental Law
American Red Cross First Aid and CPR
Program Manager, ESS 7, DYNAMAC Corp., 1995-Present.
Mr. Cummings is the program manager for the EPA Region 7 Enforcement Support Services
contract. He is responsible for providing technical leadership as well as ensuring compliance with
contract requirements. During his tenure, Mr. Cummings has conducted industrial surveys and
technical reviews for PRP searches and is a member of the EPA Region 7 chemical accident
investigation team that investigated the cause of a chemical explosion that occurred in Iowa in
1994.
Training Group Leader, Ecology and Environment, Inc., Region 7 TAT Contract, 1992-1995.
As the Training Group Leader, Mr. Cummings was responsible for managing 4 persons in that
TAT 7 Training Group. He has managed Superfund and CEPP projects, coordinated
multidisciplinary teams on concurrent projects, and tracked and reported on administrative and
financial issues. He also served as the project manager on CERCLA responses and removals.
In his capacity as Training Group Leader, Mr. Cummings was charged with managing TAT
planning support, task-based hazards analysis programs, training development and delivery
programs, the chemical safety audit program, review and recommendations for developing
environmental health and safety regulatory requirements, the regional TAT health and safety
program, and aII of the necessary coordination with Federal, state and local agencies as well as
the private sector. He managed all resources associated with this portion of the TAT contract.
As a project manager, Mr. Cummings was responsible for developing and reviewing all project
work plans and reports as well as conducting field supervision and management of these activities.
He conducted field work reviewed resultant data and reports, tracked project budgets and
schedules, and performed other miscellaneous contract administrative activities associated with his
position. As a manager of TAT programs, Mr. Cummings was responsible for the development
of more than 66 work plans and their associated cost estimates and supervised teams comprised
of diverse disciplines (engineers, industrial hygienists, fire fighters, scientists, hazardous waste
specialists). He was responsible for hiring, development, supervision and evaluation of his staff.

During the 1993 midwestem floods, Mr. Cummings performed and supervised ha:zardous
substance and oil recovery from land and rivers. He directed aerial and river reconnaissance
surveys, orphan container recovery operations, chemical field screening, and waste stream
sampling and bulking. He also provided contractor oversight, conducted hazardous waste storage
facility inspections and inspections for compliance with SARA Title III. He provided key safety
plan support for Des Moines River activities and Perryville, MO, activities through development,
evaluation, updating and training. During his time as Training Group Leader, Mr. Cummings also
managed the chemical emergency response to the Terra International chemical plant explosion in
Sergeant Bluff, IA. He managed and conducted around-the-clock air surveillance operations
documenting off site releases of anhydrous ammonia for public exposure evaluation. He worked
closely with EPA and the local incident commander providing potential exposure information and
recommendations for public safety. He entered the facility during the emergency phase of this
operation with EPA to assess other chemical storage tank integrity, secondary containment
integrity, and the location and condition of small containers. Mr. Cummings also assisted EPA
conduct a CEPP investigation to determine the cause of the explosion and develop
recommendations for preventing future similar occurrences.
Training Group Member, Ecology and Environment, Inc., Region 7 TAT Contract, 1988-1992.
As a Training Group Member under the TAT contract in Region 7, Mr. Cummings conducted 36
chemical safety audits in Region 7 as a project manager or an audit team member. These audits
involve evaluation of facility and corporate chemical risk management and accident prevention
programs and development of recommendations to improve facility and community emergency
response plans and preparedness. Local and state planning and response officials were requested
to participate in. the CSA process if facility management agreed. Mr. Cummings has also
developed and delivered custom training programs for state and local government agencies
pertaining to hazards identified at facilities being audited. In all cases, these programs were
developed and delivered in a cooperative effort with the audited facility.
Mr. Cummings has responded to 118 chemical and oil-related emergency responses during the 6
years that he worked on the TAT contract. These emergency responses included train
derailments, chemical plant explosions, significant chemical releases at facilities, in transportation,
and abandoned chemicals on public and private property. Mr. Cummings has proven both his
management and technical skills for dealing with emergency situations. He responded to an
explosion at the ChemTech facility in Kansas City, MO, to assess remaining bulk storage
containers in the tank farm where the explosion occurred and determine whether or not chemicals
were released. He responded to a request for assistance by the Kansas City, KS, Fire Department
where an unplacarded load of ammonium perchlorate had been involved in a truck fire in a
residential area. Mr. Cummings provided investigative support, technical assistance and detailed
documentation of site activities during the overpacking, transport, sampling, and detonation of
over 3,000 pounds of this Class 4 oxidizer in 22 deteriorating drums.
Mr. Cummings has managed or participated in over 15 CERCLA removal support activities at
several sites. At the Chemical Commodities site in Olathe, KS, he managed the emergency
response that led to the site assessment and managed the initial site assessment. Assessment
activities at the removal support sites included multi-media sampling and air monitoring for worker
health and safety and public exposure potential, structural integrity evaluations for structures on
the site, chemical field screening, and contingency planning. Mr. Cummings provided air
monitoring, contingency planning support, and multi-media sampling during the emergency
removal of a potentially shock-sensitive soil sterilant cylinder from a residential area in Fremont,
NE, to a remote quarry where the cylinder was intentionally detonated.
Mr. Cummings conducted several site investigations during six-plus years on the TAT contract.
He conducted multi-media sampling, supervised installation of monitoring wells, conducted air




..

monitoring activities with field instrumentation, and assisted in geophysical surveys. He
maintained detailed documentation of all activities and finding and forwarded that information to
EPA.
In addition to the chemical safety audits, Mr. Cummings assisted local emergency planning
committees (LEPCs) in Region 7 to develop hazards analysis programs, analyze impacts of
hai.ardous materials routing through major population centers, critique response and exercise
activities, and evaluate emergency plans, operating procedures, and training programs. Mr.
Cummings coordinated with state and local officials throughout the region to develop full-scale
hazardous materials simulations, table-top exercises, and small-scale response simulations.
Mr. Cummings researched, developed and presented over 308 hazardous material prevention and
emergency response training programs for Federal, state and local government organizations. He
developed much of the 240-Hour Hazardous Materials Technician training program for EPA
Region 7 and conducted 6 presentations of this comprehensive training program. Training
programs that Mr. Cummings has developed range from custom OSHA 8-Hour health and safety
refreshers to multi-day chemical accident prevention programs and include toxic air release
computer modeling training programs, a variety of response programs, and hazardous materials
management and accident prevention programs.
Gladstone, MO, Public Safety Department, 1971-1988.
During his 18 years with the Gladstone Department of Public Safety, Mr. Cummings held
progressively more responsible position in both fire and law enforcement activities that culminated
in 7 years as the commander of the fire division. He has commanded police patrol units, fire
suppression units, fire prevention and code enforcement units, and hazardous materials response
units. As fire division commander, Mr. Cummings managed an annual budget of $940,000, the
complexity of which is indicated by the budget’s consisting of 16 accounts. During this tenure,
he organized formal certification programs for all operational classifications and advance training
program requirements accordingly. Mr. Cummings participated in all contingency planning
activities for the city and headed several planning committees, as well as coordinating mutual aid
and state emergency planning coordination. He developed and implemented all budgets associated
with these programs and reported directly to the public safety director.
U. S. Amiy, 1968-1971.
Mr. Cummings served in the U. S. Army for three years. He was an instructor for the avionics
communication equipment repair course in Fort Gordon, GA. While assigned at ARADMAC in
Corpus Christi, TX, he assisted personnel from Frankford Arsenal develop and present basic
transistor theory and a basic transistor trouble shooting courses.








___ _j I __ _j ‘ __ J’ . __ .J. -_J .. ___ J ‘· ___ J :_ _ J •- – _ ] I __ _J __ J ______ J _ __j 1 __J . _____ J ,_ __ _J

Post

1997-03-17 – EPA – West Lake Landfill – Alternative Dispute Resolution Work Plan – Narrative

WEST LAKE LANDFILL
ALTERNATIVE DISPUTE RESOLUTION
WORK PLAN
Volume I: Narrative Work Plan
Contract No. 68-W4-0039
Work Assignment No. C07023
March 17, 1997
Prepared for:
U. S. Environmental Protection Agency
Region VII
Kansas City, KS 66101
Prepared by:
Dynamac Corporation
15720 W. 108 St.
Suite 300
Lenexa, KS 66219
WEST LAKE LANDFILL
AL TERNA TI VE DISPUTE RESOLUTION
WORK PLAN
Volume I: Narrative Work Plan
Prepared for:
U. S. Environmental Protection Agency
Region VII
Kansas City, KS 66101
Contract No.
Work Assignment No.
Dynamac No.
Site No.
Date Prepared
Date Amended
EPA Work Assignment Mgr.
Telephone No.
Dynamac Project Manager
Telephone No.
: 68-W4-0039
: C07023
: 7023
: 14
: March 17, 1997
: Steve Kinser
: (913) 551-7728
: Alan Cummings
: (913) 888-7080
CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. C’07023
TABLE OF CONTENTS
1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.1 WORK ASSIGNMENT HISTORY/BACKGROUND . . . . . . . . . . . . . . 1
1.2 SCOPE OF WORK ASSIGNMENT . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2.0 TECHNICAL APPROACH . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
2.1 TASK 1: PROJECT MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . 4
2.1.1 Provide Required Reports of Work . . . . . . . . . . . . . . . . . . . . . . 4
2.1.2 Conflict of Interest Screening . . . . . . . . . . . . . . . . . . . . . . . . . 4
2.1.3 Oversight by the Program Manager . . . . . . . . . . . . . . . . . . . . . 5
2.2 TASK 2: WORK PLAN DEVELOPMENT . . . . . . . . . . . . . . . . . . . . . 6
2.3
2.4
2.S
2.6
2.7
2.2.1 Work Plan Initiation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.2.2 Technical Scoping Meeting . . … … . …………….. .
2.2.3 Work Plan Development ………. .. . . ………. . … .
TASK 3: CONTRACT REQUIRED REPORTS …………… . . .
TASK 4: CLOSEOUT …… . . . . … .. …. .. . …………. .
TASK 5: ALLOCATOR SELECTION .. …….. . ………… .
TASK 6: CONVENING ACTIVITIES ………… . ………. .
TASK 7: ALLOCATION ACTIVITY SUPPORT …………… .
6
7
8
9
10
11
12
3.0 DELIVERABLES AND SCHEDULE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
4.0 PERSONNEL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
5.0 SUBCONTRACTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
6.0 EXCEPTIONS TO THE WORK ASSIGNMENT OR ANTICIPATED
DIFFICULTIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
7.0 QUALITY ASSURANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
ATTACHMENT A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Work Pinn
West Lake Landfill
March 17, 1997
Page i
CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
1.0 INTRODUCTION
1.1 WORK ASSIGNMENT HISTORY/BACKGROUND
Alternative Dispute Resolution
Work Assignment No. C07023
West Lake Landfill (the “Site”), Operable Unit No. 1, involves a remedial
investigation/feasibility study (Rl/FS) being performed by Cotter Corporation (N.S.L.),
Laidlaw Waste Systems (Bridgeton), Rock Road Industries, Inc., and the U.S. Department
of Energy.
In 1966, the Atomic Energy Commission (AEC) sold 8,700 tons of leached barium sulfate,
together with other radioactive residues to Continental Mining and Milling Company. The
radioactive residues were generated as by-products of uranium processing performed by the
AEC’s contractor. These processing residues were stored at the AEC St. Louis Airport
Storage Site (SLAPSS). Continental Mining moved the radioactive residues to its facility
at 9200 Latty Avenue in Hazelwood, Missouri. Eventually, Cotter purchased the radioactive
residues and shipped all but the 8,700 tons of leached barium sulfate to its processing
facility in Colorado.
In 1973, approximately 8,700 tons of radioactively contaminated leached barium sulfate
residues were mixed with approximately 39,000 tons of soil, and the entire amount was
disposed of in two areas of the Site. This material resulted from decontamination efforts
undertaken by Cotter at 9200 Latty Avenue, where the residues had been stored. Studies
have indicated that these two areas of the landfill are contaminated with uranium-238,
uranium-235, thorium-230, and radium-226. In addition to the radioactive materials in the
landfill, groundwater at the Site is also contaminated with radioactive materials as well as
other hazardous substances.
In 1993, EPA entered into an Administrative Order on Consent (AOC) for the performance
of a RI/FS at the Site. As indicated, Cotter Corporation, Laidlaw Waste Systems, Inc.,
Rock Road Industries, Inc., and the U. S. Department of Energy were signatories to this
AOC.
To date, the four respondents to the AOC have shared the cost of the work equally. While
this allocation has worked for the Rl/FS phase of the work, the upcoming remedial
design/remedial action (RD/RA) will be substantially more costly, and some of the parties
may have difficulty paying a 25% share. The RI/FS is currently in progress, so no Record
of Decision (ROD) has been issued and it is not expected that a ROD will be issued before
this allocation process is complete.
Despite the absence of projected remedial costs, the four respondents to the AOC have
Work Plan
West Lake Landfill
Mnrch 17, 1997
Page I
l
[
CERCLA Enforcement Support Sciviccs, Region VII
Contract No. 68-W4-0039
Altcrirntive Dispute Resolution
Work Assignment No. C.07023
indicated a willingness to proceed with an allocation effort. Since DOE is a respondent to
the AOC and a sister federal entity to the U.S. EPA, AOC respondents have agreed to use
a third-party neutral allocator, and that this process would best serve the interests of the
parties and satisfy EPA’s desire to maintain neutrality.
Additionally, the private party PRPs have requested that in any allocation performed, that
the allocator give consideration and possibly allocate some responsibility to an “orphan”.
The orphan is B&K Construction Company, which acted as the transporter of the
radioactive materials for Cotter Corporation. It has been alleged that B&K actually chose
the Site for disposal of the wastes, although there appears to be some conflicting
information on this point.
As described by the U.S. Environmental Protection Agency (EPA) in the Work Assignment
Statement of Work (SOW), EPA requires that a third party-neutral allocator be obtained
to assist the AOC respondents develop a voluntary allocation of costs associated with this
site. Dynamac will locate and retain an allocator agreeable to all respondents and the U.
S. EPA, wbo will represent the orphan share in this process.
Dynamac will provide the allocator and perform the oversight functions described in the
SOW in such a manner as to maintain a neutral approach to all parties involved in the
allocation process.
1.2 SCOPE OF WORK ASSIGNMENT
In the Statement of Work within the work assignment, EPA has identified three primary
functions to be performed by Dynamac:
1. Dynamac wilJ locate and obtain a professional allocator/arbitrator with experience
in dispute resolution pertaining to environmental Jaws and regulations to facilitate
the voluntary allocation process;
2. Dynamac will identify and contact the affected parties in this process pursuant to
SOW requirements and conduct activities described in Section B of the SOW,
“Convening Activities”; and
3. Dynamac will provide subcontract oversight and assist the allocator as required in
Section C of the SOW, “Allocation”.
1l1e Statement of Work also provides for project management, work plan development, and
the preparation and submission of contract required reports.
Work Plan
West Lake Lindfill
March 17, 1997
Page 2
CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
These functions are organized into seven tasks:
Task 1 – Project Management
Task 2 – Work Plan/Cost Estimate
Task 3 – Contract Required Key Reports
Task 4 – Closeout
Task 5 – Allocator Selection/Subcontracting Activities
Task 6 – Convening Activities
Task 7 – Allocation Activity Support
Alternative Dispute Resolution
Work Assignment No. OJ7023
All support provided under this Work Assignment is described in Section 2.0, Technical
Approach, which was developed based upon the following:
1) The SOW dated March 10, 1997; and
2) The technical guidance and clarification provided during the technical scoping
meeting conducted on March 5, 1997.
Work Plan
West Lake Landfill
March 17, 1997
Page 3
CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
2.0 TECHNICAL APPROACH
Alternative Dispute Resolution
Work Assignment No. 0>7023
This section describes the technical, management, and administrative activities proposed by
Dynamac to meet the Work Assignment objectives as described in Section 1.2 and as
provided in the ESS contract Section 2.1 describes project management activities. The
remaining sections outline the Dynamac Team’s approach to completing the technical
requirements defined in the Work Assignment Scope of Work and further clarified at the
March 5, 1997 technical scoping meeting.
2.1 TASK 1: PROJECT MANAGEMENT
Performance of this task requires the successful completion of the following sub-tasks that
are identified and discussed in this section:
* Provide required monthly work assignment technical status reports to EPA;
* Provide personnel conflict of interest control;
* Oversight by the Program Manager; and
* Subcontractor oversight and reporting.
Quality Assurance/Quality Control (QA/QC) is an integral part of performance of each task
of the Work Assignment. The level of effort and costs associated with providing QA/QC
are included in the costing of each task.
2.1.1 Provide Required Reports of Work
This work assignment specified a period-of-performance (POP) of four and one-half months,
from March 10, 1997 to July 31, 1997. Under this task, Dynamac will prepare the Work
Assignment Monthly Status Reports (monthly status reports or MSRs) throughout the
period that this Work Assignment is active. The MS Rs will describe the legal, technical and
financial progress of the Work Assignment during the previous month and substantiate any
expenditures, including direct labor, other direct costs (ODC), and travel associated with
the Work Assignment.
2.1.2 Conflict of Interest Screening
Dynamac initiated both organizational ilnd personal conflict-of-interest (COi) screening
activities upon receipt of the Work Assignment. Following this initial step, Dynamac’s
Work Plan
West Lake Landfill
March 17, 1997
Page 4
CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. 0)7023
Contracts Manager and Officer-in-Charge wiJl complete the COi screening and submit the
results to EPA within 20 days of receipt of the PRP list.
Concurrent with the processing of the organizational COi screening and certification,
Dynamac staff assigned to this Work Assignment also completed personal COi screening
and disclosure forms. This information will be maintained on file by Dynamac.
2.1.3 Oversight by the Program Manager
The Dynamac Acting Program Manager, Mr. Alan Cummings, will provide oversight for the
Work Assignment as the Dynamac Project Manager. This oversight includes:
• Monitoring the work assignment to ensure that it remains on schedule and within
budget;
• Ensuring that appropriate Dynamac resources, including qualified personnel, are
available for the Work Assignment;
• Ensuring that all subcontract activities are properly monitored and reported; and
• Ensuring compliance with provisions of the ESS contract.
LOE and costs estimated for this task include completing the Dynamac corporate and
personnel COI searches and certifications, subcontractor monthly technical reports,
monitoring deliverable schedules and financial progress, and the preparation of
correspondence required by the ESS 7 Contract. Dynamac estimates include the following:
P-4 4 hours:
P-3 18 hours:
Work Plan
West Lake Lindfill
This time includes COi certification, work plan and cost estimate
review and approval, approval of the allocator solicitation (contract
elements and requirements), and approval of the allocator subcontract.
This time includes the preparation of local technical reports required
by the contract, oversight for the subcontractor for technical and
budget issues (including scheduled deliverables), and preparation of
correspondence required by the contract.
March 17, 1997
Page 5
CERCLA Enforcement Support Scivices, Region VII
Contrnct No. 68-W4-0039
2.2 TASK 2: WORK PLAN DEVELOPMENT
2.2.1 Work Plan Initiation
Alternative Dispute Resolution
Work Assignment No. C07023
Upon receipt of the Work Assignment, Dynamac initiated activities necessary to
development of a work plan. Activities completed include:
“‘ Acknowledgement of receipt of the Work Assignment;
“‘ Establishment of master and project files specific to this Work Assignment;
* Copying and distribution of the Work Assignment document to appropriate
staff;
* Assignment of Work Assignment-specific tracking numbers to accurately track
all Work Assignment expenditures; and
* Conducting initial meetings to determine the staffing approach for the Work
Assignment to best meet EPA’s requirements.
2.2.2 Technical Scoping Meeting
Dynamac prepared for and attended a technical scoping meeting with EPA staff on March
5, 1997: l11e purpose of this technical scoping meeting was to obtain clarification of the
SOW and a better understanding of technical requirements and upcoming deadlines
associated with the Work Assignment to enable Dynamac to develop a focused work plan
and cost estimate.
Dynamac representatives at the technical scoping meeting were:
Mr. Alan Cummings, Acting Program Manager
EPA representatives included:
Mr. Steve Kinser, EPA W AM
Mr. Ron Stewart, EPA CO
Mr. Larry Stafford, EPA
Mr. Dave Hoefer, EPNCNSL
Several issues that impact the technical approach, deliverables, and expenditures associated
Work Plan
West Like Landfill
March 17, 1997
Page 6
CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. C07023
with this Work Assignment were discussed during the technical scoping meeting. Important
direction and clarification provided by EPA during the meeting are discussed in Sections
2 and 6 of this work plan.
2.2.3 Work Plan Development
Following the technical scoping meeting, Dynamac completed development of this Work
Plan and associated Cost Estimate. The Work Plan and Cost Estimate were reviewed by
the Dynamac Contracts Manager, Mr. David Biver, to ensure compliance with the Region
VII ESS Contract. Dynamac submitted the work plan on March 17, 1997.
The estimated cost of accomplishing the tasks set forth in this work plan was presented in
Volume II of the original work plan. The initial cost estimate submitted with the work plan
does not include allocator costs. Since Task 5 requires that an allocator be selected who is
agreeable to all parties concerned, subcontract costs cannot be included at this point. The
first cost estimate only contains estimated costs for Dynamac personnel.
Dynamac will submit an updated cost estimate that includes subcontractor (allocator)
estimates after the allocator selection process is completed, and pursuant to the SOW for
this work assignment, after completion of the convening phase of this work assignment.
LOE and costs listed for Task 2 include the effort necessary to attend scoping meetings,
develop the work plan and related assumptions, and complete a cost estimate for this work
assignment that details labor, ODCs, and travel at the task level and by professional labor
level. Dynamac estimates the following:
P-3 25 Hours:
P-2 6 Hours:
Work Pinn
West Lake Landfill
This includes attending technical scoping meetings, preparation of the
initial work plan, preparation of the original cost estimate, preparation
of the second cost estimate to include allocator costs from the initial
allocator acquisition, and the third cost estimate required by the SOW
upon completion of convening activities.
This includes the review and approval of three cost estimates (as
required by the SOW) by contract specialists to ensure that they are
accurate and are compliant with contract requirements.
March 17, 1997
Page 7
CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
Altenrntive Dispute Resolution
Work Assignment No. 0)7023
2.3 TASK 3: CONTRACT REQUIRED REPORTS
Dynamac will prepare and submit all reports required by the contract with the exception of
the Monthly Status Reports, which will be prepared pursuant to Task 1. LOE listed for this
task is for the preparation of the work assignment monthly financial reports and
subcontractor financial tracking reports. Dynamac estimates include the following:
P-2 24 Hours:
Work Plan
West Lake Landfill
This includes generation of work assignment monthly financial
reporting and invoice backups in Kansas City, and financial tracking
and reporting on subcontractor invoices in Rockville for the specified
period of performance.
March 17, 1997
Page 8
CERCLA Enforcement Support Services, Region VII
Contrncl No. 68-W4·0039
2.4 TASK 4: CLOSEOUT
Alternative Dispute Resolution
Work Assignment No. C07023
This task includes efforts related to the support of project completion and closeout activities
in both the technical and financial areas as well as file maintenance and record indexing.
Typical activities include: review and consolidation of all project and master files to ensure
files are complete and in order according to EPA Region VII file guidance; preparation of
Work Assignment file indexes identifying all relevant file material; QA review of the final
structure and index, copying and providing relevant files to EPA; preparation of Work
Assignment files for archived storage; and review an documentation of the final financial
status of the Work Assignment. Dynamac estimates 6 P-2 hours and 4 P-3 hours to
complete the work described.
Work Plan
West Lake Landfill
March 17, 1997
Page 9
CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. C07023
2.5 TASK 5: ALLOCATOR SELECTION
The statement of work for this work assignment requires that Dynamac select an allocator
professional to act as the convener and allocator for this process. Since pre-approved
subcontractors for this contract either do not have professional arbitrators/allocators or are
prime contractors on other EPA contracts, Dynamac will solicit proposals from professional
arbitration/allocation persons or organizations to ensure, to the greatest extent possible, that
third-party neutrality is obtained.
Dynamac will develop a statement of work for the allocator that will include a series of
assumptions contained in the EPA SOW for this work assignment and obtained from the
technical scoping meeting conducted on March 5, 1997. Dynamac will develop a list of
professional allocation/arbitration persons and organizations who have experience in
negotiations processes pertaining environmental Jaw and regulation issues. Dynamac will
then solicit proposals from the identified allocators for a time and materials subcontract.
To minimize costs, Dynamac will attempt to loc;ite allocators/arbitrators in the general area
of St. Louis and Kansas City, Missouri to minimize travel costs associated with this effort.
Based on the proposals and the technical qualifications provided by the candidate allocators,
Dynamac will select an allocator to perform the tasks identified in the SOW. Proposal
review, allocator selection, and execution of the subcontract will be conducted by the
Dynamac Program Manager in Kansas City and Dynamac professional contract staff in
Rockville, Maryland. Dyncunac will attempt to ensure that the allocator selected will be
able to competently execute the tasks identified in the EPA SOW and minimize costs
associated with this process.
LOE estimated for this task includes the effort necessnry to identify allocators close to the
St. Louis and Kansas City, Missouri area; develop the solicitation for bids; review submitted
bids for costs and qualifications; select an allocator; and facilitate subcontract execution.
Dynamac estimates include the following:
P-3 10 Hours:
P-2 27 Hours:
Work Man
West Lake Landfill
This includes drafting a detailed statement of work and deliverable
schedule for inclusion in the allocator solicitation, review of proposals
received from allocators, and selection of the allocator to perform the
work.
TI1is includes drafting the solicitation for the allocator, mailing,
tracking and reviewing allocator responses, participation in the
selection process, and drafting and executing a time and materials
subcontrnct with a cost ceiling.
March 17, 1997
Page 10
CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
2.6 TASK 6: CONVENING ACTIVITIES
Alternative Dispute Resolution
Work Assignment No. C07023
Pursuant to the requirements contained in the EPA statement of work for this work
assignment, Dynamac will, in conjunction with EPA, identify and contact the key parties
who have agreed to participate in this voluntary allocation process. Dynamac will determine
the following from each key party to this process:
1. What the perceived goals and objectives are for this process;
2. What format that each key party requests be used for the allocation process and any
format to which the key party would object; and
3. Whether or not each party will agree to continue with the voluntary allocation
process utilizing the third-party neutral allocator selected by the process described
in Section 2.5 of this work plan.
1l1is process will be conducted in conjunction with allocator selection activities described
in Section 2.5 of this work plan to ensure that all parties agree to this process before the
final selection of an allocator. Dynamac is utilizing this approach to minimize costs should
one or more parties not agree to continue with the voluntary allocation.
EPA has provided Dynamac with a list of four key parties to th is allocation process.
Dynamac anticipates that approximately two hours LOE will be necessary to contact and
discuss the items listed with each key party, and approximately two hours to complete a
letter report to EPA summarizing the results of the interviews and discussions. This task
will be performed by the Program Manager. Dynamac estimates include 10 Hours of P-3
time for this effort.
The deliverable for this task will be a brief letter report that identifies the responses of each
key party to the proposed allocation process and the desire of each party to participate in
the process.
Work Plan
West Lake Laud(ill
March 17, 1997
Page 11
CERCLA Enforcement Support Services, Region Vll
Contract No. 68-W4-0039
2.7 TASK 7: ALLOCATION ACTIVITY SUPPORT
Altcruntivc Dispute Resolution
Work Assignment No. 0)7023
Dynamac will provide oversight and support for the allocator selected for this voluntary
allocation process. This support will include the following efforts and tasks:
1. Provide a liaison between the selected allocator and EPA for issues other than
scheduled deliverables. This liaison is necessary to limit direct contact between the
allocator and EPA for issues other than EPA’s participation in the allocation process
representing the orphan share. LOE for managing scheduled deliverables, other
than meeting summaries, is included in the Project Management section of this work
plan.
2. Provide support to the allocator in arranging for meeting facilities and ensuring that
meeting notices and agendas are distributed to key parties in a timely manner.
3. Provide support to the allocator in dealing with contract issues not identified in the
Project Management section of this work plan.
4. Review and comment on the allocator’s meeting summaries and forward the
information to the EPA WAM.
Dynamac anticipates that at least eight meetings will be necessary to complete the voluntary
allocation process described in the EPA SOW. LOE indicated is based on facility
arrangement requirements for these meetings and providing notification to key parties. If
the allocator performs these tasks, Dynamac will not charge hours to this task. Total LOE
estimated for this effort is 2 hours per meeting.
Dynamac anticipates that issues will arise that will require liaison between the allocator and
EPA that are not addressed in this work plan. LOE listed for liaison activities allows
Dynamac to be responsive to allocator requests for guidance for issues not addressed in the
SOW. Dynamac estimates that 19 hours LOE should be sufficient to provide liaison
activities and contract issue support to the allocator for the period of performance specified
in the work assignment form received on March 6, 1997. Dynamac estimates that 35 hours
P-3 time will be sufficient to address all of the previously described issues.
All subcontractor liollrs will be charged to this task.
Work Plan
West Lnke Landfill
March 17, 1997
Page 12
CERCLA Enforcement Supporl Services, Region VII
Contract No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. C07023
3.0 DELIVERABLES AND SCHEDULE
Deliverables identified in the SOW, the technical scoping meeting, and described m
individual technical approach tasks in Section 2.0 are summarized below.
Table 3-J. Deliverables Schedule
I DELIVERABLE II SUBMITTAL DATE I
TASK 2: Work Plan/Cost Estimate
Work Plan/Cost Estimate March 17, 1997
COI Certification March 31, 1997
Cost Estimate, 1st Revision Witl1in 5 working days of allocator
selection
Cost Estimate, 2nd Revision Within 5 working days of receipt of
allocator convening report and cost
estimate
TASK 7: Allocation Activity Support
Convening Activity Report
Fina] Allocation Repott
Interim Reports/Briefings
Work Plan
West Lake Landfill
Within 10 working days of the conclusion
of convening activities
Within 15 working days of the
completion of allocation activities
As needed
March 17, 1997
Page 13
FOIA Exemption 4
CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
5.0 SUBCONTRACTING
Altentative Dispute Resolution
Work Assig11me11t No. C07023
Tile statement of work for this work assignment specifies that a third-party neutral allocator
be selected to conduct the voluntary allocation process therein described. Since Dynamac
is a prime con tractor for the EPA Region VII Enforcement Support Services Contract and
the pre-approved subcontractors for this contract either do not have a professional
arbitrator/allocator or have other EPA contracts, Dynamac will subcontract with a
professional arbitrator/allocator to ensure that the allocator can function as a neutral third
party to this process. 1l1e allocator will be selected pursuant to the procedures contained
in Section 2.5 of this work plan.
TI1e statement of work for the subcontractor will contain the elements contained in Section
B of the EPA SOW, Convening Activities, and Section C, Allocation.
No other subcontracting or professional services are anticipated based on the current scope
of this work assignment.
Subcontractor costs are not included in the initial cost estimate for this work assignment,
since selection of the subcontractor other than a pre-approved subcontractor is a part of the
initial work assignment. Dynamac will submit a second cost estimate to EPA after proposal
have been received from the subcontractor solicitation process.
Work Plan
West Lake Landfill
March 17, 1997
Page 15
CERCLA Enforcement Support Services, Region Vil
Contr:ict No. 68-W4-0039
Alternative Dispute Resolution
Work Assignment No. C07023
6.0 EXCEPTIONS TO THE WORK ASSIGNMENT OR ANTICIPATED DIFFICULTIES
111e technical approach for this Work Assignment is based upon the SOW provided by EPA
and additional clarification and technical guidance provided during the March 5, 1997
technical scoping meeting. This Work Plan is based on assumptions and limitations which
were defined at the technical scoping meeting.
This Work Plan and subsequent Cost Estimate is based upon the following assumptions:
1. That the period of performance is not extended beyond July 31, 1997. If the POP
is extended, Project Management and Key Report functions will increase. These are
calculated on a monthly basis times the POP.
2. That the number of meetings for completion of the process will be eight or less, and
that the meetings will not exceed one day each. An increase in the number of
meetings will increase the effort necessary to review meeting summaries and address
issues with the allocator.
Work Pinn
West Lake Landfill
March 17, 1997
Page 16
CERCLA Enforcement Support Services, Region Vil
Contract No. 68-W4-0039
7.0 QUALJ1Y ASSURANCE
Alternative Dispute Resolution
Work Assignment No. C07023
The Dynamac Quality Assurance/Quality Control (QNQC) Program Plan is incorporated
by reference into the contract governing this Work Assignment. The Work Assignment and
all subsequent activities and deliverables may be the subject of a random audit by the EPA
Contract QA Officer pursuant to the EPA QA Program Plan. If an audit is conducted, any
corrective action will be addressed in meetings with the key management staff of the ESS
contract.
All deliverables submitted under this Work Assignment are subject to the deliverable QA
review process described in Dynamac’s QA Program Plan.
Work Pinn
West Lake Landfill
Mnrcb 17, 1997
Page 17
CERCLA Enforcement Support Services, Region VII
Contract No. 68-W4-0039
ATIACHMENT A
DIRECT LABOR MATRIX
Alternative Dispute Resolution
Work Assignment No. C07023
I
TASK
Tnsk 1
Tnsk 2
Tnsk3
Tnsk 4
Tnsk S
Tnsk 6
Tnsk 7
DIRECT LABOR MATRIX
PERCENTAGES BY TASK AND P LEVEL
Work Assignment No. C07023
TECHNICAL LADOR
LOE Jlours
(l’crccnl or Tot.nl Tcchnicnl LOE)
P-4 P-3 P-2
4 16
25 6
0 24
4 6
10 27
10
35
WA Totnls II 4 I 100 I 63 I 0 I 0
(2%) (60%) (38%)
Task 1: Project Management Task 5: Allocator Selection
Task 2: Work Pinn Development Task 6: Convening Activities
Task 3: Contract Required Key Reports Task 7: Allocation Activity Support
Task 4: aoseout
TOTAL
20
(12%)
31
(19%)
24
(14%)
10
(6%)
37
(22%)
10
(6%)
35
(21%)
I 167
(100%)
CERCLA Enforccmcnl Support Services, Region VII
Contract No. 68-W4-0039
ATIACHMENT 8
RESUMES
Alternative Dispute Resolution
Work Assignment No. C07023
Alan S. Cummings
Academic Qualifications: B.A., Liberal Arts, University of Missouri at Kansas City, 1992
Specialized Training: OSHA 40-Hour Haz.ardous Waste Site Health and Safety Training
OSHA 8-Hour Hazardous Waste Site Supervisor Training
Experience:
EPA 40-Hour Air Surveillance for Hazardous Materials (165.4)
NOAA 40-Hour Oil Spills in Riverine Environments
EPA 32-Hour Chemical Safety Audit (165.19)
EPA/NOAA 16-Hour CAMEO-II DOS
University of Missouri 16-Hour Hazardous Materials Incident Analysis
PVCC 48-Hour Chemistry of Hazardous Materials
PVCC 48-Hour Hazardous Materials Tactics
UPRR 16-Hour Introduction to Haz.ardous Materials Incident Response
MO DNR 4-Hour Recognition and Identification of Hazardous Materials
DOT 8-Hour HMT-181 Training and Certification
8-Hour Radiation Safety Course
8-Hour Environmental Law
American Reel Cross First Aid and CPR
Program Manager, ESS 7, DYNAMAC Corp., 1995-Present.
Mr. Cummings is the program manager for the EPA Region 7 Enforcement Support Services
contract. He is responsible for providing technical leadership as well as ensuring compliance with
contract requirements. During his tenure, Mr. Cummings has conducted industrial surveys and
technical reviews for PRP searches and is a member of the EPA Region 7 chemical accident
investigation team that investigated the cause of a chemical explosion that occurred in Iowa in
1994.
Training Group Leader, Ecology and Environment, Inc., Region 7 TAT Contract, 1992-1995.
As the Training Group Leader, Mr. Cummings was responsible for managing 4 persons in that
TAT 7 Training Group. He has managed Superfund and CEPP projects, coordinated
multidisciplinary teams on concurrent projects, and tracked and reported on administrative and
financial issues. He also served as the project manager on CERCLA responses and removals.
In his capacity as Training Group Leader, Mr. Cummings was charged with managing TAT
planning support, task-based hazards analysis programs, training development and delivery
programs, the chemical safety audit program, review and recommendations for developing
environmental health and safety regulatory requirements, the regional TAT health and safety
program, and all of the necessary coordination with Federal, state and local agencies as well as
the private sector. He managed all resources associated with this portion of the TAT contract.
As a project manager, Mr. Cummings was responsible for developing and reviewing all project
work plans and reports as well as conducting field supervision and management of these activities.
He conducted field work reviewed resultant data and reports, tracked project budgets and
scheclules, and performed other miscellaneous contract administrative activities associated with his
position. As a manager of TAT programs, Mr. Cummings was responsible for the development
of more than 66 work plans and their associated cost estimates and supervised teams comprised
of diverse disciplines (engineers, industrial hygienists, fire fighters, scientists, hazardous waste
specialists). He was responsible for hiring, development, supervision and evaluation of his staff.
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During the 1993 midwestem floods, Mr. Cummings performed and supervised hazardous
substance and oil recovery from land and rivers. He directed aerial and river reconnaissance
surveys, orphan container recovery operations, chemical field screening, and waste stream
sampling and bulking. He also provided contractor oversight, conducted hazardous waste storage
facility inspections and inspections for compliance with SARA Title III. He provided key safety
plan support for Des Moines River activities and Perryville, MO, activities through development,
evaluation, updating and training. During his ti meas Training Group Leader, Mr. Cununings also
managed the chemical emergency response to the Terra International chemical plant explosion in
Sergeant Bluff, IA. He managed and conducted around-the-clock air surveillance operations
documenting off site releases of anhydrous ammonia for public exposure evaluation. He worked
closely with EPA and the local incident commander providing potential exposure information and
recommendations for public safety. He entered the facility during the emergency phase of this
operation with EPA lo assess other chemical storage tank integrity, secondary containment
integrity, and the location and condition of small containers. Mr. Cu1runings also assisted EPA
conduct a CEPP investigation to determine the cause of the explosion and develop
recommendations for preventing future similar occurrences.
Training Group Member, Ecology and Environment, Inc., Region 7 TAT Contract, 1988-1992.
Asa Training Group Member under the TAT contract in Region 7, Mr. Cummings conducted’36
chemical safety audits in Region 7 as a project manager or an audit team member. These audits
involve evaluation of facility and corporate chemical risk management and accident prevention
programs and development of recommendations to improve facility and community emergency
response plans and preparedness. Local and state planning and response officials were requested
to participate in the CSA process if facility management agreed. Mr. Cummings has also
developed and delivered custom training programs for state and local government agencies
pertaining to hazards identified at facilities being audited. In all cases, these programs were
developed and delivered in a cooperative effort with the audited facility.
Mr. Cummings has responded to l 18 chemical and oil-related emergency responses during the 6
years that he worked on the TAT contract. These emergency responses included train
derailments, chemical plant explosions, significant chemical releases at facilities, in transportation,
and abandoned chemicals on public and private property. Mr. Cummings has proven both his
management and technical skills for dealing with emergency situations. He responded to an
explosion at the ChemTech facility in Kansas City, MO, to assess remaining bulk storage
containers in the tank farm where the explosion occurred and determine whether or not chemicals
were released. He responded to a request for assistance by the Kansas City, KS, Fire Department
where an unplacarded load of ammonium perchlorate had been involved in a truck fire in a
residential area. Mr. Cummings provided investigative support, technical assistance and detailed
documentation of site activities during the overpacking, transport, sampling, and detonation of
over 3,000 pounds of this Class 4 oxidizer in 22 deteriorating drums.
Mr. Cummings has managed or participated in over 15 CERCLA removal support activities at
several sites. At the Chemical Conunodities site in Olathe, KS, he managed the emergency
response that led to the site assessment and managed the initial site assessment. Assessment
activities at the removal support sites included multi-media sampling and air monitoring for worker
heallh and safety and public exposure potential, structural integrity evaluations for structures on
the site, chemical field screening, and contingency planning. Mr. Cummings provided air
monitoring, contingency planning support, and multi-media sampling during the emergency
removal of a potentially shock-sensitive soil sterilant cylinder from a residential area in Fremont,
NE, to a remote quarry where the cylinder was intentionally detonated.
Mr. Cummings conducted several site investigations during six-plus years on the TAT contract.
He conducted multi-media sampling, supervised installation of monitoring wells, conducted air
monitoring activities with field instrumentation, and assisted in geophysical surveys. He
maintained detailed documentation of all activities and finding and forwarded that information to
EPA.
In addition to the chemical safety audits, Mr. Cummings assisted local emergency planning
committees (LEPCs) in Region 7 to develop hazards analysis programs, analyze impacts of
hazardous materials routing through major population centers, critique response and exercise
activities, and evaluate emergency plans, operating procedures, and training programs. Mr.
Cummings coordinated with slate and local officials throughout the region to develop full-scale
hazardous materials simulations, table-top exercises, and small-scale response simulations.
Mr. Cummings researched, developed and presented over 308 hazardous material prevention and
emergency response training programs for Federal, state and local government organizations. He
developed much of the 240-Hour Hazardous Materials Technician training program for EPA
Region 7 and conducted 6 presentations of this comprehensive training program. Training
programs that Mr. Cummings has developed range from custom OSHA 8-Hour health and safety
refreshers to multi-day chemical accident prevention programs and include toxic air release
computer modeling training programs, a variety of response programs, and hazardous materials
management and accident prevention programs.
Gladstone, MO, Public Safety Department, 1971-1988.
During his 18 years with the Gladstone Department of Public Safety, Mr. Cummings held
progressively more responsible position in both fire and law enforcement activities that culminated
in 7 years as the commander of the fire division. He has commanded police patrol units, fire
suppression units, fire prevention and code enforcement units, and hazardous materials response
units. As fire division commander, Mr. Cummings managed an annual budget of $940,000, the
complexity of which is indicated by the budget’s consisting of 16 accounts. During this tenure,
he organized formal certification programs for all operational classifications and advance training
program requirements accordingly. Mr. Cummings participated in all contingency planning
activities for the city and headed several planning committees, as well as coordinating mutual aid
and state emergency planning coordination. He developed and implemented all budgets associated
with these programs and reported directly to the public safety director.
U. S. Anny, 1968-1971.
Mr. Cummings served in the U. S. Army for three years. He was an instructor for the avionics
communication equipment repair course in Fort Gordon, GA. While assigned at ARADMAC in
Corpus Christi, TX, he assisted personnel from Frankford Arsenal develop and present basic
transistor theory and a basic transistor trouble shooting courses.
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Post

1997-03-06 – EPA – West Lake Landfill – Enforcement Support Services Contract – Alternative Dispute Resolution

ENFORCEMENT SUPPORT SERVICES CONTRACT
Funding: CERCLA
W10029
No.: 97T07WGBX
2. Contract No.: 68-W4-0039
5. Prime Contractor: DYNAMAC
8. Priority: Ex edi te
3. Work Assignnent #: C07 02 3
6. Amenctnent Nunber:OOOOO
ite/Facil ity Name: WEST LAKE LANDFILL
.ocation:
3. EPA Site/Facility ID#: MOD079900932
5. CERCLA ONLY:FMS Site/Spill ID: 14
7. CERCLIS/Event/Actlvlty/NSS: 2101- 1701·
18. Purpase: Initiate New Work Assignment
19. Task Type: Alternative Dispute Resolution
!1. Comient:
22. Total Funding Received
Previously Approved:
This Action:
Total:
LOE
0
301
301
Cost/Fe
0
so,ooo
so,ooo
2.,eriod Of Performance From: 03/10/97
,2.6.. ..I ,nit iator: Work Assigr1wnen¥t Ma nager CWAM> Name: steve kinser
30. Approval: Project Officer
(SIGN) _________________ _
Name: N/A N/A
34. Cont~Offl

Post

1997 – EPA – West Lake Landfill – Conflicting information on who chose West Lake Landfill for illegal disposal of uranium residues

Site Background
West Lake Landfill (the “Site”), Operable Unit No. 1, involves a remedial
investigation/feasibility study (“RI/FS”) being performed by Cotter Corporation (N.S.L.),
Laidlaw Waste Systems (Bridgeton), Inc., Rock Road Industries, Inc. and the U.S. Department of
Energy.
In 1966, the Atomic Energy Commission (“AEC”) sold 8,700 tons ofleached barium
sulfate, together with other radioactive residues, to Continental Mining and Milling Company
(“Continental Mining”). The radioactive residues were generated as by-products of uranium
processing performed by the AEC’s contractor. These processing residues were stored at the
AEC’s St. Louis Airport Storage Site (“SLAPSS”). Continental Mining moved the radioactive
residues to its facility at 9200 Latty Avenue in Hazelwood, Missouri. Eventually, Cotter
purchased the radioactive residues and shipped all but the 8, 700 tons of leached barium sulfate to
its processing facility in Colorado.
In 1973 approximately 8, 700 tons of radioactively contaminated leached barium sulfate
residues were mixed with approximately 39,000 tons of soil, and the entire amount was disposed
of in two areas of the Site. This material resulted from decontamination efforts undertaken by
Cotter at 9200 Latty A venue, St. Louis, Missouri, where the residues had been stored. Studies
have indicated that these two areas of the landfill are contaminated with uranium-238, uranium-
235, thorium-230 and radium-226. In addition to the radioactive materials in the landfill,
groundwater at the Site is also contaminated with radioactive materials as well as other
hazardous substances.
In 1993 EPA entered into an Administrative Order on Consent (“AOC”) for the
performance of an RI/FS at the Site. As indicated above, Cotter Corporation (N.S.L.), Laidlaw
Waste Systems (Bridgeton), Inc., Rock Road Industries, Inc. and the U.S. Department of Energy
were signatories to this AOC.
Allocation Support
To date the four respondents to the AOC have shared the cost of work equally. While
this allocation has worked for the RI/FS phase of the work, the upcoming remedial
design/remedial investigation (“RD/RA”) will be substantially more costly, and some of the
parties may have difficulty paying a 25% share. The RI/FS is still underway, so no Record of
Decision (“ROD”) has been issued and it is not expected that a ROD will be issued before this
allocation process is complete.
Despite the absence of projected remedial costs, both the PRPs and DOE are willing to
proceed with an allocation effort. In particular, DOE seeks a greater degree of certainty in its
budget planning process, and along with the PRPs may see allocation as an opportunity to adopt
more equitable basis for its liability than the current per capita scheme.
On December 5, 1996, a meeting of the St. Louis Site Task Force meeting was held in St.
Louis, Missouri, which was attended, inter alia, by DOE Assistant Secretary Thomas Grumbley,
EPA Region VII’s Administrator, as well as various other representatives of DOE, EPA, the
State of Missouri, the City and County of St. Louis and staffers from interested Congressional
offices in the state and affected district.
At this meeting DOE Assistant Secretary Grumbley announced that with regard to West
Lake Landfill OU-1, EPA would “allocate the responsibility at the site as best as it can over the
next six months or so, so that they can tell us what percentage of the responsibility that [DOE]
needs to take … . “(Italics added)
As any allocation of responsibility that EPA may prepare, such as an non-binding
allocation of responsibility, may expose EPA to charges of favoritism as DOE is a sister federal
entity. Discussions were held among the four identified potentially responsible parties (“PRPs”)
regarding how best to conduct an allocation. It was agreed that using a third-party neutral
allocator would best serve the interests of the parties and satisfy EPA’ s desire to maintain
neutrality.
Additionally, the private party PRPs, Cotter Corporation (N.S.L.), Laidlaw Waste
Systems (Bridgeton), Inc. and Rock Road Industries, Inc. have requested that in any allocation
performed the allocator give consideration and possibly allocate some responsibility to an
“orphan.” The orphan is B&K Construction Company, which acted as the transporter of the
radioactive materials for Cotter Corporation. It has been alleged that B&K actually chose the
Site for disposal of the wastes, although there appears to be some conflicting information on this.
Therefore, In order to accomplish the allocation, EPA would envision starting as soon as
practicable in order to meet the six-month deadline mentioned above, that is, six months from the
Task Force meeting, or May 5, 1997. While that may be ambitious, EPA still envisions that the
parties would be substantially involved in the process or nearly complete in their efforts by that
date.
The process would involve allocation, with the four PRPs, plus EPA as a party to
represent the “orphan” share mentioned above. An initial convening meeting is expected, with
several additional one-day meetings with all parties in attendance to follow until resolution.
Appropriate shares for costs may include consideration of PRP ability to pay issues, as
driven by a range of estimated costs for various likely, but as yet not selected, remedial
alternatives. Additional costs or liabilities to throw into the mix may include credit for past
contributions under the per capita allocation scheme, EPA’s “orphan” share contribution in the
form of forgiveness of oversight costs, or other mechanisms or sources that may come forward as
the allocation proceeds. EPA would expect that the convening phase of the allocation would
resolve may of these issues to further clarify what the parties expect from the process.
Scope of Work
A. Preliminary Work
1. The contractor shall select an allocator professional to act as convener and allocator for
this process in consultation with the Project Officer (PO) and Delivery Order Project
Officer (DOPO).
2. The allocator professional shall meet with the EPA PO and DOPO and members of
EPA’s team to discuss substantive and procedural issues and define potentially involved
interests and parties. At this meeting EPA representatives will provide more detailed
information with regard to the goals and outcomes expected of the process, list of
potential parties to be included in the process and a list of issues to be addressed through
the process.
3. The contractor shall submit a workplan to EPA in accordance with the requirements of
this contract.
4. The contractor shall be responsible for oversight of deliverables on this delivery order
and shall be responsible for transmission of monthly reports and invoices as required by
the contract.
B. Convening Activities
1. In consultation with the EPA DOPO, the contractor shall identify and contact the affected
parties to discuss the goals and purpose of the proposed allocation process, as well as the
technical or substantive issues involved in the allocation process.
The contractor shall contact parties identified by the EPA DOPO as “key parties” first. If
no barriers to an allocation process are identified, the contractor shall proceed to contact
all parties.
If initial contacts with the key parties reveal that an allocation process is not feasible, the
contractor shall notify the EPA PO and DOPO, explain the difficulties (lack of interest,
unequivocal opposition of a key party, disagreement about the definition of the problem,
wrong forum or process, etc.) and await EPA’s decision on whether to proceed with the
allocation process.
2. The contractor shall provide oral reports weekly to the DOPO on the general progress of
the convening effort.
3. The contractor shall provide one copy of the draft convening report to the EPA Project
Officer and five copies to the DOPO. The report will:
a. Summarize the results of convening contacts including such things as:
( 1) what parties were contacted during the period; and
(2) identification and a discussion of those issues which the parties agree will
be considered as part of the allocation process, and well as those issues
which the parties choose not to have addressed in the allocation process.
b. A discussion of the chances of a successful allocation process and the goals and
purpose of the process from the viewpoints of the parties affected;
c. Recommendation of potential additional parties that should also participate in the
consultative process.
d. If an allocation process appears to be feasible, the report shall include a design for
the process including such things as:
( 1) the structure and type of meetings between/among the allocator
professional and affected parties;
(2) the expected number, length, location and frequency of meetings;
(3) the research, data or information necessary prior to, or during the process;
( 4) the estimated budget for the process as designed and proposed by the
contractor; and
(5) whether an orientation session is recommended prior to the first meeting.
e. If a consultative process is not recommended, the contractor may suggest other
processes that could accomplish some of EPA’ s goals.
The PO and DOPO will review the draft convening report and provide comments and
revisions as necessary. The contractor will prepare the final report incorporating the PO’s
and DOPO’s comments and revisions.
The contractor shall distribute the final report to the PO (2 copies), the DOPO (5 copies)
and to each of the parties interviewed for the report.
4. If EPA decides to proceed with the allocation process, the contractor shall assist it in
contacting potential parties to obtain commitments to participate in the allocation process.
5. As a part of the convening effort, the contractor may arrange for and facilitate an initial
organizational meeting of the parties to discuss the form of the process and the parties to
be involved, to get commitments to go forward from each of the parties, discuss the
issues involved, and/or the ground rules for the process.
C. Allocation
This phase will implement the design of the allocation process as accepted by the EPA
DOPO and PO based upon the final convening report recommendations.
1. The contractor shall propose an initial draft of operational ground rules. At the initial
meetings, the contractor shall assist the group in further developing and refining the
ground rules or operating procedures of process.
2. The contractor shall provide a draft agenda to the PO and DOPO for each meeting. Upon
receipt and incorporation of the PO’s and DOPO’s comments, the contractor shall
distribute the final agenda to the PO, DOPO and participants in the allocation process.
3. The contractor shall facilitate all plenary, subcommittee and workgroup sessions. As
facilitator the contractor shall assist participants in articulating their interests, identifying
areas of agreement, and developing consensus solutions to the problems that divide them.
As facilitator, s/he shall keep the parties talking, listening, and moving – as much as
possible – towards the goal of the process.
4. The contractor shall communicate in person, by phone or in writing with process
participants to ensure that issues and concerns have been communicated accurately and
that all participants are adequately prepared for the next meeting.
5. The contractor shall provide draft meeting summaries to the PO, DOPO and the
participants. Upon receipt and incorporation of comments, the facilitator shall distribute
final meeting summaries to the PO, DOPO and participants.
6. The contractor shall provide meeting facilities and support for all meetings.
7. The contractor shall furnish a draft final report of the allocation process to the PO (one
copy) and DOPO (five copies). The contents shall include:
(a) A two page executive summary of the process including the background, the
issues discussed, and the resolutions of the issues;
(b) Final meeting summaries with relevant and necessary attachments;
( c) Copies of all documents compiled by the allocator during the allocation process;
( d) Relevant substantive correspondence between the allocator and the participants
and between the participants themselves (if available to the allocator); and
(f) A process evaluation by the allocator summarizing results of the process, analysis
of issues and balance of parties, procedural lessons learned, and recommendation
for improvements.
The PO and DOPO will review the draft final report and provide comments and revisions as
necessary. The contractor shall prepare the final report incorporating its comments and revisions.
The contractor shall provide 2 copies of the final report to the PO, and 5 copies to the DOPO,
and one copy to each party involved in the process.

Post

1997 – EPA – West Lake Landfill – Allocations of Responsibility – INDEX – Research and Back-Up Information

INDEX
RESEARCH AND BACK-UP INFORMATION
FOR
WESTLAKE LANDFILL OU-1
1. Undated, Allocation Strategy for Representing the Orphan Share in
Allocatiaon Pilots Doc #7
2. Dated June 3, 1996, Memorandum from Steven A. Herman, Assistant
Administrator ofU. S. EPA Office of Enforcement and Compliance
Assurance; to: Regional Administrators; Subject: Interim Guidance
on Orphan Share Compensation for Settlors of Remedial
Design/Remedial Action and Non-Time-Critical Removals
3. Copy of the Bureau of National Affairs, Inc. Article, Dated 8/26/94;
Subject: Superfund Allocation Strategies and Outcomes, written by
Steven F errey.
4. Undated, Annotation: Right to Perpetuation of Te stimony under Rule
27 of Federal Rules of Civil Procedure, written by Elaine K. Zipp,
J.D.
5. Lexis Report, Undated, Missouri Secretary of State, Corporate
Record for B & K Construction Co., Inc.
6. Undated handwritten note with addresses & info re: USNRC
Investigation Report
7. Undated Definitions of terms in the Document Request
8. 11/12/97 handwritten notes of Westlake OU-1 Allocations Meeting at
Spencer Fane
9. Dated 11/12/97 list of attendees at the Westlake Landfill Site PRP
Group Mediation Convening Meeting Spencer Fane, Kansas City,
MO
10. 8/6/97 narrative introducing William E. Hartgering, Esq., a full-time
mediator and arbitrator
11. 8/21/97 Guide to the Allocation Process in a Superfund Case attached
to a 3/31/97 United States’ Initial Bried on Behalf of The
Environmental Protection Agency
12. Undated Site Background on West Lake Landfill Operable Unit No.
1, involving a remedial investigation/feasibility study being
performed by Cotter Corporation (N.S.L.) Laidlaw Waste Systems
(Bridgton), Inc., Rock Road Industries, Inc. and the U.S. Department
of Energy.
13. 3/17/97, West Lake Landfill Alternative Dispute Resolution, Work
Plan, Volume 1: Narrative Work Plan

Post

1997-12 – EPA – West Lake Landfill – Allocations of Responsibility – INDEX – Correspondence

INDEX
CORRESPONDENCE
1. 12/8/97 letter from Alan Birnbaum, DOJ, to: Wm. Werner, Esq.;
James Gunn, Esq., Charlotte L. Neitzel, Esq.; Subject: West Lake
Landfill Site
2. 12/8/97 Memo from Charlotte L. Neitzel, Holme Roberts & Owen
LLP and John L. Watson (Freeborn & Peters); to: Alan Birnbauh,
Angela Foster, Michael Hockley, David Hoefer, Bill Werner and
Mike Fisher; Subject: West Lake Landfill – Response to Rock Road’s
Draft “Document Request” Distributed on December 1, 1997 and
Proposed Deponent List
3. Dated 12/8/97, letter from Michael Hockley, Spencer Fane; to:
Charlotte L. Neitzel, Esq., William R. Werner, Esq., David Hoefer,
Esq., and Angela Foster, Esq., Subject: West Lake Witness List
(Laidlaw concurring with the draft “Document Request” circulated by
Rock Road.
4. Dated 12/8/97, memo from the Stolar Partnership, Mike Fisher, and
Bill Werner; to: Alan Birnbaum, Angela Foster, Michael Hockley,
David Hoefer, Charlotte Neitzel; Re: West Lake Landfill (list of
persons Rock Road Industries would like to depose)
5. Dated 12/8/97, memo from David Hoefer; to: The Stolar Partnership,
Mike Fisher and Bill Werner; Re: West Lake Landfill OU-1
(responding to document production and witnesses to be
interviewed/deposed with regard to the allocation/mediation)
6. 12/8/97 letter from Michael D. Hockley, Spencer & Fane; to:
Charlotte L. Neitzel, Esq, William R. Werner, Esq., David Hoefer,
Esq., Angela Foster, Esq.; Re: West Lake Witness List (Laidlaw
Waste Systems concurs with the draft “Document Request”)
7. 12/8/97 memo from The Stolar Partnership and Mike Fisher and Bill
Werner; to: Alan Birnbaum, Angela Foster, Michael Hockley, David
Hoefer, Charlotte Neitzel; Re: West Lake Landfill list of persons
from Rock Road Industries pursuant to Rule 27 of the Federal Rules
of Civil Procedure.
8. 12/1/97 Memo from The Stolar Partnership, Mike Fisher and Bill
Werner; to: Alan Birnbaum, Angela Foster, Michael Hockley, David
Hoefer and Charlotte Neltzel; Re: West Lake Landfill (cover letter for
a draft of a proposed joint Document Request)
9. 11/14/97 Memo from Bill Hartgering, Mediator/Allocator to:
Charlotte Neitzel, Michael Hockley, David Hoefer, Bill Werner,
Angela Foster and Alan Cummings; Re: West Lake Landfill ADR, St.
Louis, Missouri, 11112 Kansas City Meeting: Schedule to Complete
Convening Process
10. Fax dated 11/10/97 from Charlotte Neitzel; to: Bill Hartgering, David
Hoefer, Alan Birnbaum, Mike Hockley and Bill Werner; Subject:
Attaching the Respondent’s joint proposed agenda for the November
12th Meeting
11. 11/4/97 letter to William D. Brighton, Esq. DOJ, from: David Hoefer;
re: West Lake Landfill Superfund Site Operable Unit No. 1,
Bridgeton, Missouri – Site ID “14” cost allocation
12. Confirmation of fax that went to Cate Tierney dated 11/5/97 with a
copy of the above-mentioned letter to William Brighton.
13. 4/24/97 Letter from Kathleen M. Whitby, Director of Settlement
Services of Clean Sites, 901 N. Washington, Street, Suite 604,
Alexandria, Virginia 22314; to: Dynamic Corporation, Attn: Mr.
David A. Biver, Vice President; Re: West Lake Landfill (St. Louis,
Missouri); Response to Request for Proposals for Mediation or
Allocation
14. 10/9/97 Memo from Bill Hartgering, Mediator; to: Charlotte Neitzel,
Michael Hockley, David Hoefer, Bill Werner and Steve Miller; Re:
West Lake Landfill ADR, St. Louis, Missouri 10/14/97 Short
Conference Call
15. 9/24/97 Memo from Bill Hartgering, Mediator; to: Dave Hoefer, Esq.,
Re: West Lake Landfill (cover letter to copy of proposal forwarded
byDYNAMAC
16. 5/21/97 fax cover sheet from Dave Hoefer to Mike Hockley with
attached description of William E. Hartgering, Esq, a full-time
mediator and arbitrator.
17. 5/20/97 letter from David A. Biver, Vice President ofDYNAMAC, to
Mr. Ron Stewart of EPA, REG VII; RE: Consultant Consent
18. 12/16/96 Letter from Michael Hockley, Spencer Fane; to: David
Hoefer, Esq.; Re: Transcript of Proceedings, December 5, 1996, St.
Louis Site Remediation Task Force

Post

1996-06-06 – EPA – West Lake Landfill – Cotter’s response to Rock Road Laidlaw submission

‘…
TB:E STOLAR p .ARTNERSHI:P
ATTORNEYS AT l..AW
THE LAMMERT BUILDING
911 WASHINGTON AVENUE
JAMES F’. GUNN ST. LOUIS. MISSOURI 63101 . H .M. STOLAR
nse to.the Rock
Road/Laidlaw submission was waiting for t;11e~ Since Charlotte did not indicate.that she had sent
. a copy directly to you, I am enclosing one for your information. I trust you -will review this. ·
doeument and 12repare your informal comments. We_ will be dohig the same; however, Bill
Werner is out_ of the office on vacation until the middle of June. We will contact you and Mike
Hacicley for your comments following Bill’s return. · · ·
,..- •• • I
JFG:mc
Enclosure, . ,.
cc: Michael D. Hockley, -~~ .
. ·- – · • • I
I .. ‘ •, “•,
.. … ·. :”. ~ :._: , , .;. . . .
._·- { .·. ··• ~ ~· .’. :. ,. :.-. ,! :.: …
• : ~ .. ;.”. l
,,,,
ine€reiy,

.. .
· .
…. . …
. ‘
… -~·· … … – .. …. ..
~ . · ~ … ‘1 ‘ .•• . ‘ : !

Post

1988-10-25 – MDNR – West Lake Landfill – Letter to EPA requesting determination of Hazard Ranking Score

_. vfv . < • • » . . . • . ,,;;, • . i. i .• /: tfd JOHNASHCROFT \y(li*Ir>
DuiMcin ol I mironnu-m.il Otulii
UIVIMOM ,,| („…,!,w jnj |J1Klsi,n
FREDERICK A. BRL’NNKR “”X” “”VM-m ,» M.in^-tm-m x-rvuvi)
irix.t,,r STATI: (>i MI>S(>riu nm>i,,n ,,f |.arkv R^…^,,,,.
DEPARTMENT OF NATURAL RESOURCES “” “1N”W”””Jllim
Di\’isioN OF I:NVIRONMI;NTAL gi’Ai.nv
I’.O. Box 176
Jefferson City. MOdSI()2
October 25, 1988
Mr. David Wagoner, Director
Waste Management Division
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
Dear Mr. Wagoner:
The U.S. Nuclear Regulatory Conmission (NRC) staff recently released
a report (NUREG-1308, June, 1988) on the radioactive wastes at the
Westlake Landfill in St. Louis County, Missouri.
In the report the NRC staff concludes that “(1) measures must be
taken to establish adequate permanent control of the radioactive
waste and to mitigate the potential long term impacts from its
existing storage conditions and (2) the information developed is
inadequate for a determination of several important issues, i.e.,
whether mixed wastes are involved, and whether on-site disposal is
practical technologically, and, if so, under what alternative
methods.” However, the report does not indicate whether the NRC will
take any further action at the site and informal communication with
the NRC staff indicates that NRC does not intend to take further
action.
The suggestion has been made by a number of state and local officials
and citizen’s groups that the U.S. Department of Energy should
undertake action at the site under the Formerly Utilized Sites
Remedial Action Program (FUSRAP). However, a letter from DOE was
received by the Missouri Department of Natural Resources on
October 30, 1987 which states that [‘the DOE has reviewed the
possibility of the Westlake Landfill being designated as a FUSRAP
site and has concluded, based on the criteria used to designate
FUSRAP sites, that the Westlake Landfill is not eligible for
consideration as a FUSRAP site. The radioactive waste was under
Nuclear Regulatory Commission license when it was brought to the
landfill and, consistent with current DOE policy, would not be
disposed of at a DOE site.”
Mr. David Wagoner
October 25, 1988
Page 2
Since no further activity is planned at the site by either the NRC or
the DOE, I request that the U.S. Environmental Protection Agency
(EPA) determine the Hazard Ranking Score (HRS) for this site and, if
appropriate, place the site on the National Priorities List (NPL).
This ranking should be conducted using all currently available
information on the site. Further, I request that EPA initiate the
Superfund process to determine potentially responsible parties and,
if necessary, initiate enforcement action to begin an appropriate
remedial action.
The Missouri Department of Natural Resources believes that the
current uncontrolled condition of the radioactive waste at the
Westlake Landfill is unacceptable and we are interested in expediting
action at this site. Please contact me if you have any questions
regarding MDNR’s position on this matter.
Sincerely,
DIVISION OF ENVIRONMENTAL QUALITY
William C. Ford/Director
WCF/dbc
cc: Mr. Jim Fiore, DOE
Mr. Germain LaRoche, NRC

Post

2015 – EPA – USACE – West Lake Landfill – Communication Summary for St. Louis District FUSRAP

Key Messages:
Key Stakeholders~
Congressional, public, community
groups, state and federal agencies.
Communication Goal:
Communicate the authority, missions and status of the
USAGE St. Louis FUSRAP Program
1. Public Health: FUSRAP protects public health and the environment by removing low-level radioactive contamination generated by activities of the
Manhattan Engineer District and the Atomic Energy Commission (MED/AEC) during the early atomic weapons program in the 1940s and 1950s.
2. FUSRAP has moved more than 1 million cubic yards of contaminated materials since USAGE took on the mission, and maintains an outstanding safety
record (4,288 days without injury.)
3. FUSRAP’s objectives are to protect public health, execute the approved alternative for cleaning up the radioactive contamination above health-based
cleanup guidelines, and minimize adverse effects on area business operations.
Key Talking Points:
Mission: USAGE St. Louis District, is conducting a radiological cleanup program for four Missouri sites (SLDS, SLAPS, SLAPS VPs, HISS).
These sites contain soils contaminated with radium, thorium, and uranium as a result of activities associated with the Manhattan Engineer
District/Atomic Energy Commission during the nation’s early atomic program in the 1940s and 50s.
Authority: Congress transferred execution of FUSRAP to USAGE, in the 1998 Energy and Water Appropriations Bill. Prior to this bill, FUSRAP
had been managed by the U.S. Department of Energy.
Sites: The complete list of active St. Louis area FUSRAP projects includes:
St. Louis Downtown Sites (SLDS, the Mallinckrodt plant areas and adjacent properties), St. Louis Airport Properties (SLAPS … completed in
FYO?), SLAPS Vicinity Properties, Latty Avenue Properties (HISS, Futura and adjacent properties) Also in the District FUSRAP Program is the
Iowa Army Ammunition Plant.
Madison Site, in Madison, IL, remediation was completed in 2000 and following the 2 year monitoring period, was removed from the list of active
FUSRAP sites in 2002.
Progress: In FY13, 28,500 cubic yards of contaminated material were shipped from the St. Louis FUSRAP sites to an out-of-state, licensed and
permitted disposal facility.
Completion: Tentative dates for completion are 2017-2019 timeframe. Completion dates depend upon future funding levels which are uncertain.
Public Involvement: The St. Louis Oversight Committee is an independent group of community leaders which serve in consultative and
participatory roles with the cleanup of the St. Louis FUSRAP Sites.
As a consultant, the Committee provides comments, recommendations, and community feedback for USAGE in its efforts to clean up these sites.
The Oversight Committee hosts public meetings semiannually, with FUSRAP and other state, local and federal agencies (EPA, Missouri Health
and Senior Services, MO DNR).
1) by Dept of Energy (in which cas
WLLFOIA4312- 001 – 0054055

Post

2011-03-23 – NRC – Fukushima Daiichi – DOE Consequence Management Field Team – HPGe Data Sets

From:
Sent:
To:
Subject:
OST02 HOC
Wednesday, March 23, 2011 5:02 PM
Hoc, PMT12; PMT11 Hoc; PMT02 Hoc; PMT01 Hoc
FW: HPGe Data sets
Attachments: Triage Report- TE-11-0721 Final (OUO).pdf; Triage Report- TE-11-0721 Final
(OUO).docx
-Original MessageFrom:
HOO Hoc
Sent: Wednesday, March 23, 20114:58 PM
To: LIA07 Hoc; OSTOl HOC; OST02 HOC; OST03 HOC
Subject: FW: HPGe Data sets
–Original Message—From:
Sheron, Brian
Sent: Wednesday, March 23, 20114:57 PM
To: HOO Hoc
Subject: FW: HPGe Data sets
Please pass on the ET, RST, and PMT Directors. Thanks.
—Original Message—–
From: Aoki, Steven [mailto:Steven.Aoki@nnsa.doe.gov]
Sent: Wednesday, March 23, 20114:38 PM
To: Pitts, William Karl; Bowyer, Theodore W; cjb@lanl.gov; Brinkman, Bill; Hurlbut, Brandon; Sheron, Brian; McFarlane,
Harold; Adams, lan; Kelly, John E (NE); Grossenbacher, John (INL); Owens, Missy; Per Peterson; Finck, Phillip; Dick
Garwin; Bob Budnitz; Rolando Szilard; Aoki, Steven; Koonin, Steven; Steve Fetter; Binkley, Steve; Richard L Garwin
Cc: NITOPS; Adams, lan
Subject: HPGe Data sets
FYI -just to make sure you are seeing the data.
1
DB 407 of696
Date(s):
Event Type:
Location:
Submitted by:
Triage Web:
Contact(s):
Responder(s):
Report Date:
22 Mar 2011
Actual
Japan
OFFICIAL USE ONLY
DISTRIBUTION LIMITED TO NNSA/NA-40
Triage Event: TE-11-0721
DOE Consequence Management Field Team
TE-11-0721
A. Aragon (Triage FTL); R. Spa nard (Triage FTL)
J. Bounds (LANL), W. Casson (LANL), S. Myers (LANL), N. Wimer (LLNL)
22 Mar 2011
List of data files used in the analysis.
2011_03_21_12_ 49_350.spc 2011_03_21_13_25_360.spc 2011_03_21_13_58_ 490.spc
2011_03_21_14_29_090.spc 2011_03_21_15_01_510.spc 2011_03_21_15_35_350.spc
2011_03_22_22_17 290 BKGD.spc
Summary
These ORTEC Detective-EX HPGe spectra were provided by the DOE Field Monitoring Teams in Japan.
Triage analysts were asked to examine these spectra for characterization of reactor damage.
As with other spectra analyzed to date, Triage analysis shows coolant release nuclides only; anticipated
since the data was collected at a distance from the reactor site. There were no features in these spectra
that would indicate core melting.
Analysis
The spectra are of good quality and well suited for comprehensive nuclide identification; they were
collected in uniform fashion across a range of distances from the plant (along three distinct highways).
With the understanding the spectra reflected ground deposition of unknown distribution, nuclide
identification and relative activities can be reported, while absolute activities cannot.
The spectra were consistent with the suite of radionuclides that had been observed earlier this week.
The radionuclides observed are indicative a coolant release only, expected for spectra taken at a
distance from the Fukushima plant. No refractory nuclides, indicators of core release, were observed in
any of these spectra; spectra from the grounds of the plant would be more definitive. The nuclides
present in the spectrum are here listed:
Major Radionuclides
1-131
1-132
Te-132
1-133
Cs-134
Cs-136
Cs-137
Minor Radionuclides
Te-129
Te-129m
La-140
1
DB 408 of 696
OFFICIAL USE ONLY
DISTRIBUTION LIMITED TO NNSA/NA-40
No other radionuclides were evident in the spectra. The nuclides Mo-99, Zr-95, and Nd-147, all high
melting point species and indicators of core melting, were specifically sought and not observed. The
spectrum plot below shows the spectrum analyzed, along with a modeled fit which used attenuation
through air to fit the full spectrum.
Cai.PCF,33-!
Energy (keV)
llve·lime(s) = 580 >I
chr·sc;uare = 2~ ~5
1 &o~~-2~oo~~~-6,a_o,_s~oo~1~oo_o~1-2~oo~~~,7~o~o~~2~2~oo~~2~7o~o~
03
c
~ 1tr
.s::::. u
C/) c 111
:l
0 u
1cf
• j.j : .. •\ • • • •
Channel Number
I.: …
• i311
[I
Figure 1. Screen dump of GADRAS fit to one of the spectra for TE-11-0721. All peaks were identified as
being from the nuclides listed above. Attenuation through air was used to perform full spectrum
fitting.
Ratios may provide some additional information. All spectra were analyzed assuming a Detective EX and
a one meter detection distance. However, since the source is distributed over a wide area and is not a
point source, absolute activity calculations are not being attempted. Instead, we report the ratios of
activities which should be consistent for similar situations. Table 1 shows average values of relative
activities. If 1-131 has an activity of 1 (arbitrary units), the other detected nuclides had approximate
activities in the proportions as given. Ground spectra taken at various times can be compared in this
fashion to observe variations in deposition composition and the effect of the various halflives.
2
DB 409 of696
OFFICIAL USE ONLY
DISTRIBUTION LIMITED TO NNSA/NA-40
Table 1. Relative activities of radionuclides evident in TE-11-0721.
Latitude 37.29076 37.442435
Longtitude 140.61472 140.52471
2011_03_2 2011_03_
2_18_14_1 22_17_35
Filename 20.spc 500.spc
mR/h 0.090 0.148
Ban- Ban-
Highway Etsu Etsu
Exit2 Exit 3
Distance 40km 45km
129Te
129mTe
1311 1.000 1.000
132Te 0.272 0.300
1321 0.269 0.299
1331 0.003 0.002
134Cs 0.145 0.201
136Cs 0.025 0.030
137Cs 0.134 0.177
140La 0.007 0.008
Comments on distributions:
Relative
1-131
3.5
3
2.5
2
1.5
1
0.5
0
0


20
37.590206 36.797261 36.903004
140.41986 140.72635 140.75162
2011_03_ 2011_03_ 2011_03_
22 16 43 21 15 35 21_15_01
51o.s”Pc 3SO.s”Pc 510.spc
0.605 0.329 0.696
Tohuku Joban Joban
Exit 20 Exit 14 Exit 15
58km 74km 62km
0.246 0.474
0.139 0.320
1.000 1.000 1.000
0.516 0.283 0.715
0.387 0.442 0.741
0.000 0.008 O.D13
0.301 0.034 0.041
0.043 0.006 0.006
0.240 0.034 0.044
0.010 0.000 0.001
• •
• •

• • •
40 60
km from Fukushima
37.001973 37.067582
140.81259 140.83824
2011_03_ 2011_03_
21 14 29 21_13_58
OSO.spc 490.spc
0.98 0.446
Joban Joban
Exit 16 Exit 17
50km 42km
0.420 0.343
0.241 0.211
1.000 1.000
0.573 0.220
0.762 0.577
0.013 0.015
0.028 0.020
0.004 0.004
0.034 0.024
0.001 0.001
mR/h
3.5
3
2.5
2
1.5
• 1
• 0.5
0
80
37.124803
140.94779
2011_03_
21 13 25
36o.sP<: 0.56 Joban Exit 18 33km 0.130 0.101 1.000 0.194 0.268 0.005 0.023 0.003 0.022 0.001 Figure 2. Dose rates and 1-131 relative activity versus distance SSW of Fukushima on Joban Expressway. The other Table 1 data sites represent different directions and are not included here. 3 DB 410 of 696 37.235578 140.98569 2011_03_ 21 12 49 3SO.spc 3.0 Joban Exit 19 20km 0.160 0.100 1.000 0.092 0.257 0.007 0.018 0.005 0.020 0.001 OFFICIAL USE ONLY DISTRIBUTION LIMITED TO NNSA/NA-40 Figure 3. Map of data locations Figure 3 shows the locations where the data was taken, relative to the Fukushima nuclear plant. Note that exit 20, exits 2 and 3, and exits 14 through 19 are from three different highways. Figure 2 shows the variation of dose rates and iodine intensities on the Joban Expressway SSW of the plant, Exits 14 through 19. Note that the radiation does not fall off linearly with distance, rather it is affected by the local winds and weather patterns. Recommendations for follow up activities: Definitive determination of whether core releases have occurred is expected to require HPGe assays from grounds of the plant itself. A spectrum of the quality that was submitted for this report, but taken from an air filter from the Fukushima Daiichi site, would provide the best data for determination of the status of core damage via gamma spectroscopy. 4 DB 411 of 696 Date(s): Event Type: Location: Submitted by: Triage Web: Contact(s): Responder(s): Report Date: 22 Mar 2011 Actual Japan -ofFICIAL USE ONL't' DISTRIBUTION UMITED TO NNSA/NA-40 Triage Event: TE-11-0721 DOE Consequence Management Field Team TE-11-0721 A. Aragon (Triage FTL); R. Spanard (Triage FTL) J. Bounds (LANL), W. Casson (LANL), S. Myers (LANL), N. Wimer (LLNL) 22 Mar 2011 List of data files used in the analysis. 2011_03_21_12_ 49_350.spc 2011_03_21_13_25_360.spc 2011_03_21_13_58_ 490.spc 2011_03_21_14_29_090.spc 2011_03_21_15_01_510.spc 2011_03_21_15_35_350.spc 2011_03_22_22_17 290 BKGD.spc Summary These ORTEC Detective-EX HPGe spectra were provided by the DOE Field Monitoring Teams in Japan. Triage analysts were asked to examine these spectra for characterization of reactor damage. As with other spectra analyzed to date, Triage analysis shows coolant release nuclides only; anticipated since the data was collected at a distance from the reactor site. There were no features in these spectra that would indicate core melting. Analysis The spectra are of good quality and well suited for comprehensive nuclide identification; they were collected in uniform fashion across a range of distances from the plant (along three distinct highways). With the understanding the spectra reflected ground deposition of unknown distribution, nuclide identification and relative activities can be reported, while absolute activities cannot. The spectra were consistent with the suite of radionuclides that had been observed earlier this week. The radionuclides observed are indicative a coolant release only, expected for spectra taken at a distance from the Fukushima plant. No refractory nuclides, indicators of core release, were observed in any of these spectra; spectra from the grounds of the plant would be more definitive. The nuclides present in the spectrum are here listed: Major Radionuclides 1-131 1-132 Te-132 1-133 Cs-134 Cs-136 Cs-137 Minor Radionuclides Te-129 Te-129m La-140 1 DB 412 of 696 OFFICIAL USE ONbY DISTRIBUTION LIMITED TO NNSA/NA-40 No other radionuclides were evident in the spectra. The nuclides Mo-99, Zr-95, and Nd-147, all high melting point species and indicators of core melting, were specifically sought and not observed. The spectrum plot below shows the spectrum analyzed, along with a modeled fit which used attenuation through air to fit the full spectrum. Cal.PCF,33- ! Energy (keV) lrve·time(sl = 58() SJ tho SGUJI·~ - 2~ ~5 lif~~·--~/~OO~--JC~·0~~60~0~8~00~1~C~00~1/~0C~~--1~70~0--~/~/~00~--/~7~00~ Hf" Q) c:: c ro 1cf .c. .0.._ ~ 1o3 c ;::, 0 0 1rl 10' . ·; .. •• Channel Number •. :.1· • ··:11 Figure 1. Screen dump of GADRAS fit to one of the spectra for TE-11-0721. All peaks were identified as being from the nuclides listed above. Attenuation through air was used to perform full spectrum fitting. Ratios may provide some additional information. All spectra were analyzed assuming a Detective EX and a one meter detection distance. However, since the source is distributed over a wide area and is not a point source, absolute activity calculations are not being attempted. Instead, we report the ratios of activities which should be consistent for similar situations. Table 1 shows average values of relative activities. If 1-131 has an activity of 1 (arbitrary units}, the other detected nuclides had approximate activities in the proportions as given. Ground spectra taken at various times can be compared in this fashion to observe variations in deposition composition and the effect of the various halflives. 2 DB 413 of 696 OFFICIAL USE ONLY DISTRIBUTION LIMITED TO NNSA/NA-40 Table 1. Relative activities of radionuclides evident in TE-11-0721. Latitude 37.29076 37.442435 37.590206 Longtitude 140.61472 140.52471 140.41986 2011_03_2 2011_03_ 2011 03 2 18 14 1 22 17 35 22 16 43 Filename io.sp{; - 500.Six: 510.spc mR/h 0.090 0.148 0.605 Ban- Ban- Highway Etsu Etsu Tohuku Exit2 Exit 3 Exit 20 Distance 40km 45km 58km 129Te 129mTe 1311 1.000 1.000 1.000 132Te 0.272 0.300 0.516 1321 0.269 0.299 0.387 1331 0.003 0.002 0.000 134Cs 0.145 0.201 0.301 136Cs 0.025 0.030 0.043 137Cs 0.134 0.177 0.240 140La 0.007 0.008 0.010 Comments on distributions: Relative 1-131 3.5 3 2.5 2 1.5 1 0.5 0 0 <> •
<>

20
36.797261 36.903004
140.72635 140.75162
2011_03_ 2011_03_
21 15 35 21 15 01
3SO.spc 510.spc
0.329 0.696
Joban Joban
Exit 14 Exit 15
74km 62km
0.246 0.474
0.139 0.320
1.000 1.000
0.283 0.715
0.442 0.741
0.008 0.013
0.034 0.041
0.006 0.006
0.034 0.044
0.000 0.001
<>
<> <>
• • •
40 60
km from Fukushima
37.001973 37.067582
140.81259 140.83824
2011_03_ 2011_03_
21_14_29 21 13 58
090.spc 490.spc
0.98 0.446
Joban Joban
Exit 16 Exit 17 ·
50km 42km
0.420 0.343
0.241 0.211
1.000 1.000
0.573 0.220
0.762 0.577
0.013 0.015
0.028 0.020
0.004 0.004
0.034 0.024
0.001 0.001
mR/h
3.5
3
2.5
2
1.5
<> 1
• 0.5
0
80
37.124803
140.94779
2011_03_
21 13 25
3SO.spc
0.56
Joban
Exit 18
33km
0.130
0.101
1.000
0.194
0.268
0.005
0.023
0.003
0.022
0.001
Figure 2. Dose rates and 1-131 relative activity versus distance SSW of Fukushima on Joban
Expressway. The other Table 1 data sites represent different directions and are not included here.
3
DB 414 of696
37.235578
140.98569
2011_03_
21 12 49
3SO.spc
3.0
Joban
Exit 19
20km
0.160
0.100
1.000
0.092
0.257
0.007
0.018
0.005
0.020
0.001
OFFICIAL USE ONLY
DISTRIBUTION LIMITED TO NNSA/NA-40
Figure 3. Map of data locations
Figure 3 shows the locations where the data was taken, relative to the Fukushima nuclear plant. Note
that exit 20, exits 2 and 3, and exits 14 through 19 are from three different highways. Figure 2 shows the
variation of dose rates and iodine intensities on the Joban Expressway SSW of the plant, Exits 14 through
19. Note that the radiation does not fall off linearly with distance, rather it is affected by the local winds
and weather patterns.
Recommendations for follow up activities:
Definitive determination of whether core releases have occurred is expected to require HPGe assays
from grounds of the plant itself. A spectrum of the quality that was submitted for this report, but taken
from an air filter from the Fukushima Daiichi site, would provide the best data for determination of the
status of core damage via gamma spectroscopy.
4
DB 415 of 696

Post

1978-02-01 – DOE – Summary of Manhattan Project Uranium Flow Sheet

J. L. Livenaan, ASEV
8~ B. Creenleigb, cc
t. G~ Hnlatt, H:latorian ‘a
Office, XS
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Xa our effort• to dnelop a ~late 1de:at1l1cati01l of fol”CCU’lJ.:
devalop the ancloaecl s..-ary of ralaticmah1.pe -.oug the a1tea frora tb.8
.
MID hiatory. The re•iev pray idea a tnterutina perapect~•• a4 ida.ctfi-
the fU11Ctiona of tbe var1oua titea ccma1dered 1D the Pcmaerl7
ft111Ad Mm:J/AE.C Site Survey l’ro&r•·
IDcloaurea
u atated
cc v/o uc.ll A. J. Whi.t:ma:n. ~
bee: V. E. Mot t, ECT
R. Fros t , Aerospace
J j?:~
/sl
VUliam. E. Matt” Director
Dlrisiou of Rnviroum.ental
Caatrol TecbQology
Doe GermantoWJl
Records Ho1dlng Mea
REPOSITORY—:=:EM~S:-::UBJ~J~~FII=~fB~
COLLECTION J08 t~
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01/lB/7 8 01/ ;:.. :}78,
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!<- •• • .. Memo to the rues THRU: :Robert W. Ramsey, Jr., Assistant Director for Nuclear Programs ·Division of Environmental Control Technology, OOE-HQ DECON'l'AMINA.TION Al'm DECOMMISSIONING: REVIEW OF MANHATTAN DIS'IRICT HIS'IORY ( CIASSll''IED OOCUMENTS) - MED .:.· The subject history is comprised of eight ( 8) books containing J6 volumes which are further di v.Ld.ed into parts am sections. The historr. covers the activities of the Manhattan District frOm prior to its inception on August 16, 1942, untU the. entire project was turned over to the U.s. AEC through the Atomic Energr Act of 19 46 on December 31, 1946. Hr. Robert W. Ramsey, Jr. asked that I review the subject documents to ascertain i! the list of si.tes, previously used (during the Manhattan ..... D1strict activities) for operations involving Uranium ores, oxides, . daughter products or other related radioactive materials, was complete in that no locations associated with the MED were omitted from the previously compiled list o! si.tes. I understood. that the subject documents were not reViemed by those that compiled the original list ?t "~AEC-ERDA Previously Used Sites." To make an indepth review of the MED history would take an undue length· or time and produce much unusable data (in regard to the information required). Therefore, Book I, volume I, which contained general information includ.Ulg a combined tab~e of contents_ (appendix B) was reviewed. · This table of contents was broken down by book, volume, chapter, section, and/or par~graph arn appendices. Also within the table of contents was an introduction to the history which inc~u.des, in paragraph number 1-5, page 1.15, "What tha History Contai.ns." This paragraph gives very briefly (a paragraph to a few pages) a description of the content for the various books and volumes. The comprehensive table of contents was reviewed to determine what 'books would be applicable to, :m::l .furnish the information requested by, Mr .. Ramsey. It appeared from this study that Book VII, Volume 1 and 2, entitled "Feed Material, Special Procurement and Geographical Exploration," 'ht)uld furnish the required. data. In conjtmction with Book VII, Book I, volume 9, was also read. '!1lis volume entitled "Priorities Program" only mentions uranium once when the "Uranium Project" was given the highest priority by President Roosevelt. The volume does mt discuss "feed material" and talks to non-ra.d.ioacti ve materials, re: steel, aluminum, silver, machinery, lumber, etc. Based on the above, attention was focused on the content of Book VII, Volume 1. The ir..formation contained therein contained data relative to .feed r::.aterials and special procurement. Part A wa.s "General Features.'' "Part B-Procurement" dealt with materials from Africa, Canada, and the U.S., Market and !1iscellaneous Procurement., and Pr-ocurement of Other :·11'·, . . . ~- .. . , .·.·.~ lt·; • . I 1 l I i 1 r ! ..~. . ~ . -.··.: ~.·-.-· .. . :· ... ;•. .. · .,.. . ,..,. •· Radi.oacti ve Materials. Part C talked ·to the refining, treatment, sZJd . · . .·., production of the various ores, oxides, metals, Thorium, Quality · -···· Control., and. Accountability. . ·c:·#~~ 'lbe procurement, storage, am processing of the basic raw materials . containing uranium is summed up as follows: •·. ·:·····. -~:-· The ores ard/or oxides received from the African sources -were stored · ·. in various warehouses. These storage areas were: (l) Archer-Daniels-Medlend co. 'Warehouse, Port Richmond, staten Island, NY (prior to the _ , MED); (2) Seneca Ordanance Depot, Romulus, NY}· (3} Clinton ~er· .,!'"-::-, Works, Clinton (Oak Ridge), Tennessee; and (4 Perry Warehouse, Hiddl.esex, NJ. The main storage area was the Perry Warehouse. The. bulk of. the African ores were stored there. This location also became a sampling, weighing, and assaying facility. Inasmuch as the contract · 14th the African source called for only the black oxide, the tailing and residue containing the radium and other precious metals were returned to the verrlor. Those residues from ores conta:i.id.ng greater· than l~ U o8 were stored at the Clinton Engineer Works, Tennessee, ·or at the ~erry Warehouse, Middlesex, NJ, prior to shipment. back to the -vemor. Residues from ores containing less than 1~ tr1o8 were stored at t.he Lake Ontario Ordanance WOrks prior to sh:l.pment to the wmor. Some of the residues were returned to the Belgium f'acility of African Metals, aDd some is still at the U.S. storage sites. The .A.tri.can ores samples were assayed arrl weighed by Lucius Pitken, Hew York City, NY; Ledoux and CO., New York Ci.ty, NY; and Frick Chemical. Laboratory, Princeton University 1 Princetown, NJ. Tbe African ores t-rere refined to black oxides (U10~) at facilities of the Linde Ai.r Products Co.,. Tonawanda, NY; Eldo~do Mining and Refiiii.ng Ltd., Fort Hope, Ontario, Canada; and Vitro Manufacturing Co. , Cannonsburg, PA. The Canadian ores were refined at the Port Hope facility of the Eldorado M1ning and Refinery Ltd. The .American ores (Carnotite) ~:ere processed tor Vanafll.um by U.S. Vanadium Corp. at Uravan, Colorado. The Vanadium sand tailings were also processed at the USV Uravan plant for Uran:i.um Oxide. These went d.irectly to Linde. They (USV) also had a plant at Dur~o, CO, for processing Vanadium tailings and sands to produce a green sluge. The output from the USV Durando and Uravan facilities went to Grand Junctio~, Colorado, for processing to yellow sluge (15% U10g) that in t-.;...-n went to the Linde refinery at Tonawanda, NY. anies and locations noted in flow o£ Uranium ores, tailings,
or slimes to the :finished product have been accounted for in the listing
of “MED-AEC-EliDA Sites Previously Used’f as complied by ECT. There were
;oo companies or organizations ttat could not be accounted for in this
particular phase of the MED history that I reviewed.
_a., a side note, the Thorium obtained for RMl at Iowa State College was
all procured by Lindsay Light and Chemical Co., West Chicago, IL. This
COmpallT i!J also accounted for in the aforementioned listing.
Quality control of various processes in the ore/metal chain tiere done by
University of Chicago, Hetallurgy Lab, Chicago, n.;. Princeton University,
Princeton, NJ; MIT, Cambridge, I-!A; and t..”BS, Washington, DC. All these
organizations are on the aforementioned listings. ) AI .,;) L~
‘- /t[& ,-~~z-:~;~
.kthur ,- • Whitman, Assistant
to the Director
Bioenvironmental Sciences Division
StOIUOl!
All.a4EII- ~IEU-MDL.MD
~:a.. WAREHouse
f’Ofl’f RtolliiOICI• STATEN IS
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LUCIUS PITKIN
NVC, N.Y.
LI’!DOUX a Co.
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~ICIC <:H£1111. LA& f'RINC:n'ON UNIV. f'RINCIEfOM, N.J. VARsoui A£FIJIIMitS ----------------------~ TAILINGS Slt)IWIE P'Oit ,._ _______ ., AI'IIICAN Mf:TALS C.. 4/SV- li!oiR:II $'1af(S -oiiDoW ~ ve"- ~~~ .... ~ ,. ._.,," IIIICW- tMLLI'-CKIIOOT (;~·~~ C. MCW MUIHI.Aitt wew 4otrot1T ILICTIIIOI«t

Post

1977-07 – DOE – Preliminary Report on the Results of a Radiological Survey Conducted at the Former Cotter Property

Data Capture
Document Discovery
(Iltis form will be used in recording the document information in the Site Research Database after the completion of the
scanning of the document.)
Reviewers-fill o11t all information. tbat applies to the document then place Ust in front of the document
Siw/Facility of Review: Date of Review:
N/fl-
Site That Document Applies To: Documem Type:
DOESile 0
Name:
AWE Site
Other:
Document Title/Comment;: _________ _
t?10rJ- ifl-!& ,k. 51Te retprfm
r-r3vlt of= 4olrllkfgd 5’vN>tJ-Irt7
Keyword(s): ——-
0
D
D
~
D
D
D
HistoricaJ Ia formation
En.vironmental Data
Radiologieallncidents/Accidents
Workplace Monitoring Data (i.e.; contamination
s~s, general area/breathing zone air sampling,
radonlthoron monitoring, area radiation surveys,
fix.ed location dosimeters, missed dose information,
Radiologi~ Ccntrollimits, Radiation Work Pennits)
Process Descriptions (i.e.; general description,
source tenns, encapsulation/containment practices)
Site Dosimetry:
D
D
D
0
Medi~aVX-ray & External Dosimetry
(i.e.; TLD Film Badges, Pocket Ion Chambers)
Internal Dosimetry {i.e.; urinalysis, feca~
In-Vivo, breath sampling, radon/thoron, nasal
sm~:ars)
Monitoring PrograiU Data (i.e.; analytical
methods for bioassay, dosimeter performance
characteristic~. detection limits, exchange
.frequencie!i, record keeping practices,
meastnment units)
Internal Information (i.e.; radionuclides
and associated chemical forms, particle size
distributions, respiratory protection practices,
solubility class).
CJaimaut Specific Document
Re<:ords Staff- flU o~~-tb¢ f~U.o~~g.prior to sc:arf~ing ·or wpyi&g () /000 ls-!l. . . . . Project Box Number: :·· Pr~j~~Dol:ument ~umber: ·: . ~ Folder Title:_·_.·_·.....__ ___. ....;-.,._. ......._ _._..,..:~-~.. ....,_--;--...:..;.;._...,...... ___- -.:.·-:·:. ._,·, .,..:.;...•. .....;-.·- '-:'-........... ;...._7------'-_...;_--...o........: . . . . : ,.;. ~· : .. ~ · .... -..... :-, .: ·. ·.· .. .. ·.· ~: • • -:4 '.:· : ~.:·:~~:· · . ...·.· .. . . . . -: ··. ·· . . _, .... :·· . :'. ·;·. · .... " . . ',1: . ',• ... : . OCT 21 1983 ~tr. John E. Baublitz. D1 rector';:.:_ D1v1s;on of Remedial Action Programs Office of Terminal waste Dhp!osal and Remed1 a 1 Act 1 on · ....... Office of Nuclear Energy Oepartment of Energy wasn1ngton, o.c. lOS4S Dear Mr. Baublitz: .. - This is fn response to your letter of October s. 1983 regarding the Department of Energy•s (DOE) research and development project at the fonmer Cotter Corporation site on Latty Avenue 1n Hazelwood. Missouri. ~Regarding the preliminary survey conducted in late September 1983, by your contracto·r. ·Oak .Ri.~s.e tlational Laboratory. we are aware that not all of the contamination is c~1ned to the p11e of contaminated soil. As indicated in the letter frQn w~ T. Crow to E. Dean Jarboe dated August 22, 1979 (enclosed) only the area identified as Parcel I has been released for unrestricted use. The decontam1nat1on of Parcel 11 was never completed because all decontamination efforts were stopped in January 1979 wnen Colonel Griggs. A1rport Director. requested that we delay transfer of the contaminated soil to the airport until quest1ons raised by Congressman Robert A. Young were resolved. After Congressman Young's concerns were addressed and he agreed that the contaminated soil should be moved to the airport site, the St. Louis Airport Authority decided not only d1d they not want the wastes from Latty Avenue but they wanted DOE to reassume title to the atrport site. We were pleased to note that Congress gave DOE authority and funds to take act1on at the Latty Avenue site. because our planned remedial actions have been ~ont1nually oe·t~ Missouri 63130
Norfolk and Western R.R.
ATTN: Mr. R.S. Michels
Regional Manager
Industria1 Rea1 Estate
.Railway Exchange Building
St. Louis~ Missourj 63101
Commonwealth Edison company
ATTN: Mr . J.J. O’Connor
Executive Vice President
P.O. Box 767
Ch icago , Il linoi s 60690
Missouri Di vision of Heal t h
-2-
AITN: Mr . Ken Mj11er, Acting Director
Bu~eau of Radiological Health
1407 Southwest Boulevard
P.O. Bux 570
Jefferson City, Missouri 65101
Missouri Department of Natural Resources
ATTN: M~. Car~1yn Ashfuro. Director
1014 Madison Street
J efferso!! City, ~·1issouri 65101
Mr. Ed McGrath
28 Fr€de rick Avenue
Gaithe rsburg, Mary1and
: ..• ~ … -~ .-= ··: ··.·
,.-……
‘• !
PRELIMINARY REPORT ON THE RESULTS OF A RADIOLOGICAl. SURVEY
CONDUCTED AT THE FORMER COTTER PROPERlY
Introduction
A radiofogica( survey was conducted during the periods June 27 throush
July 1 and July 11 through July 14, 1977, at the former Cotter property,
located at 9200 Latty Avenue in Hazelwood, Missouri. A summary of the
results is presented here. AH information presented in this report is of a
preliminary nature and wiU be updated when further analysis has heen completed.
There a~e four buildings, covering a total of approximately 18,000 ft
2
,
on this ll-aere site. The· buildings are presently being prepared for use in a
chemicoJ coating operation. At the time of the survey, there .were four construcfion
workers on the site. Scaled drawings of the property are shown m
Figs. l and 2.
Summary of Survey Ke.sults
Building 1: This structure measures 120 ft x 100 ft, has a 30-ft ceiling, a
dirt floor, and open areas along the wells (including spoces for
~; 33 windows) totaling approximately 2500 ft2.
Beta-gamma close rates were measun:cl at 1 em above the surface with
G-M wrvey meters on the floor, walls, ceiling, and ~supports. Measurements
on the floor and lower walls were mode at points determined by a 20 ft x 20 ft
grid (see Fig. 3), and additional measurements were made at potnts showing
hiehest external gamma radiation levels. . .. O~erheod measurements were mci§TI
. ‘AUG 8 ·· ~ . . . • –· .dJi;::..- • …..tj;.
. : ·;·i·- -~. .. •. – • . ; :.; : .
. . …..~. -·~: ,~y~~
·— ·-……—– “: ~-~~~’ -~’ — _,_ …. —- —

.,. .. f
.—…
-2- .·,
at uniformly and closely spaced points. Results ore given in Table:. J and 3
and Fig. 3. Beta-gamma dose rates in the building exceeded 0.20 mrod/hr
at most poinfl and were as high os 2.4 mrod;hr of 1 em above the dirt floor.
External gamma radration levels at l m above the surface were measured
with Nal scintillation meters and with closed-window G-M meters. Readings
were taken at the points of the grid mentioned before (see Table 1}, and
maximum external gamma radiation levels were determined within alternate
squares formed by the same grid (see Fig. 4). Readings were generally in
·the range of J00-500 JJR/hr.
Direct alpha readings wer~ taken on the walls, ceiling, and supports
with alpha scinti11otion. survey meters. Results ‘ore reported in Fig. 3 and
Table 3. Maximum readings within the grid blocks on the lower walls (that
is, Jess than 6 ft above the floor) exceeded 600 dpm/100 cm2 throughout.
The highest reading ·~as JS,OOO dpm/100 em2• Maximum readings generally
were observed on a steel ledge. Direct alpha readin9s WerP. tt.:~ken at
approximately 5 em above thP. dirt flo~r at a few points; these readi;,g:»
exceeded 5,000 dpm/100 cm2 at some points and probably resulted from
radon emanating from the soi I.
·Transferable alpha and beta contamination lttvels were measured on the
ceiling, wa11s, and supports. Results are reported in TabJe 4. Transferable
alpha contamination levels were s~nerally higher than transferable beta levels;
transferable alpha levels averaged JJS dpm/100 cm2 on the lower walls and
55 dpm/100. crn2 on overhead .surl’aces.
,. · . . ::·· .
. . __ ….. ……,…..:—-·-··-··-·–.. —– ~·-·—–· .. – . .. .
:.
‘ I ‘
·:.::· ..
.-:-•
Roden concentrations in air were measured continuously over 24-hr
periods with Wrenn chambers. Results are reported in Tobie 5. Although
the building was open at all times and underwent several air exchanges per
hour, radon concentrations were as high as 57 pCi/Jiter.
Building 2: This structure measures 60 ft x 50 ft and hos a dirt and
gravel floor. At the time of the survey, the building had
uncovered door, wall, and window operungs totaling approximately
500 ft2•
A survey plan identical to that for Buildjng 1 was employed except
that fewer grid blocks were used; each grid block measured approximately
20 ft X 17 ft (see fig. 5). Results for beta~amma cose rates ore presented
in Tables 2 and 3 and Fig: 5. Beta-gamma dose rates were gencrofly lower
than in Building 1 but exceeded 0.20 mrad/hr in some places. It appeared
that high gamma rodl~tion levels outside the building were in pc~t re~po11S•Lie
for the elevated beto-gam’!’O dose ro~e~ and P.xternol ;om:.:~ :-odi.:;io;·, it:vt:i:i
(see Table 2 •”Jnd F:g. 6) inside the structur~. Maxi.rr.um direct aipha readings
within srid block~ on the lower walls (fjg. 5} were generally in the range
1,300-2,600 dpm/100 cm2. Again, highest readings were on a steel ledge.
Traruferabfe alpha and beta contamination levels we~re slightly lower than
those in Building l (see Table 4). Radon concentrations in air in this open
building were as high as 7 pCi/liter.

·-·-··– —··—-·–······ .. ·.
.:
t
‘ \ ! l i
, –.
“– :’
– 4-
Building 3: This structure measures 42 ft x 28 ft and has a 1.5-20 ft ceiling
and a concrete floor.
The floor and lower walls were divided into 7 ft x 7 ft blocks, and
maximum direct alpha readings and beta-gamma dose rates were detemined
for each .block (see Fig. 7). Direct alpha readings and beta-gamma dose
rates on overhead surfaces are given in Table 3. Transferable alpha and beta
contamination levels ore given in Table 4. E~ternaf gamma radiation levels
at J m above the surface at randomly selected points are given in Fig. 8.
Radiation levels were generally lower than in Buildings J and 2, except for
alpha contamination levels. Radon concentrations in air did not exceed
1 pCi/liter.
Building 4: This small structure (56 ft x 20 ft) was partially destroyed
in a fire and is undergoing extensive construction modifications,
particularly on thg v·,alls and ceiling. The buildhig has a
concrete floor.
Radiation levels were generC!!Iy low except for alpha contaminct!on on
the concrete floor. Direct alphc.! readings on the floor were in the range
50-530 dpm/100 cm2 (see Fig. 9), and transferable alpha contamination levels
were· as high as 60 dpm/100 cm2 (Table 4). fxternaJ gamma radiation levels
. – at randomly selected points are given in Fig. JO. ·
Outdoor Measurements:· The property was divided into .blocks by a .50 ft x 50 ft
grid system (see Fig. 11). At each intersection of grid line.s,· beta-gamma dose

rates at· J an and external gamma radiation lewis at 1 m were determined •
. • ….. · . . . . . : .. ·· …..
~~———-··· , …
-· ‘-!.

\
– 5-
Results ore given in lobi e 7. J n cddi ti on, within each block maxi mum
beta-gamma dose rates were determined. Readings for those blocks where
. the maximum within the block exceeded the ~axirMJm of the four corners
are given in Fig. 11. It is evident from the resutb shown in Table 7 and
Fig. 11 that beta-gamma dose rates at t em above the surface exceed 0.20
mrad/hr outdoors over o significant portion of the property.
Resu I ts .o f S0 1” I Sa mp I e A ro I yses: Co ncentrah•o ns o f 226Ro , 238U , on d 227A c
i.n soi I sampt es coli ected during a presurvey visit and in one samp I e taken
from a surveyor’s work boots are presented in Table 6. 227
Ac is in the
235u
chain and is a daughter of
231
Pa which is known to have been present in
large quantities in some of the residues once stored at the former AEC St.
Louis Airport Storage Site. Strictest NRC limits ·ror ~emitters apply to this
ra d1• 0nucl “• de . 1t appears t ho t sJ• gm·!!n” cant quan t•1t •1 es o f 226Ra , 238U , and 227Ac
ore contained in the soil on the proper!)’, porticli!~dy in the dirt floor in
Po U·I1 d·• ng 1. Be cause no spec:•· r·J C e r~r orts were mao·e to cemove 230rh f rom
pitchblende residue~ stored at the airport site, it must a,e assumed that’ this
radionudide may be present in large quantities. A linited number of samples
will be analyzed for
230
Th. The ~ample whose locotigq is described as “in
.
and aroond BuHdings 1, 2, 3, and 4” was token from ·C surveyor’s boots and
was soil and mud from the area shown in fig. 2. This sample contained t20
pCi
226
Ra/g and 110 pCi
227
Ac/g; the concentration .tJi 230
Th hos not yet
been determined. This sample should be representative of the contamination
beins carried into homes by workers ond visitors on the sfte. •
..
i f
t
t l
1
I • ‘;
.:.:·.·.:.
•__ :
….
~:..
==:;
~
:· • .,!
….. _~
Table 1. Building 1, floor: measurements at grid points of beta-gamma
dose rates and external gamma radiation levels
Grid point Beta-gamma dose r~te External gamma radiation
(Sec Fig. 3) at 1 em level at 1 m
(mrad/hr) {~R/hr)
Al 1.40 320
Bl 2.40 300
Cl 0.35 240
01 1.50 220
El 1.20 190
Fl 1.00 220
Gl 1.30 240
G2 1.00 160
F2 0.60 160
E2 0.40 190
D2 0.30 160
C2 0.30 160
B2 · u.s:> 180
….
“”” ·1.30 220
A3 1..30 240
B3 0.50 220
C3 0. 75 240 ..
D3 0.75 220
E3 0.70 210
F3 o.so 160
G3 o.so 120
C4 0.65 140
..
~
. ···-
~:
~===
:;:;
Table 1. (ccn~’d.)
Grid point
(See Fig. 3)
F4
.E4
D4
C4
84
A4
AS
BS
cs
05
ES
FS
…. ~
…. ¥
G~
F6
E6
D6
C6
86
A6
,,–.
.\ ‘ I
.Builcilng 1. floor: measurements at grid points of beta-gar.m:a·
dose rates and external gamma radiation levels
Beta-gamma dose rate
at I’ em
(mrad/hr)
o.so
0.40
0.35
0.70
0.50
0.20
0.20
0.25
o.so
0.80
0.90
1.00
l.lU
1.60
l.SO
0.90
0.90
1.40
0.65
0.1~
External gawma radiation
level at· 1 m
(lJR/hr)
140
160
160
240
180
120
90
180
210
160
270
190
180
240
240
130
130
160
110
100
..:

.
-··
I
~-~
•.
Table 2. Building 2, floor: measurements at grid points of beta-gamma
· dose rates and external_ gamma radiation levels
Grid point Beta-gamma dose rate External. gar.:..”na radiation
(See Fig. 5) ~t !’em level at 1 m
(mrad/hr) (lJR/hr)
Al 0.08 80
Bl 0.08 45
Cl o.os 40
Dl 0.07 70
D2 0.15 80
C2 0.28 80
B2 0.13 55
A2 0.06 40
A3 0.08 55
83 0.10 45
C3 0.15 55
D3 0.15 105
D4 0.10 95
C4 0.08 65
84 0.14 65
A4 0.15 80


..:
Building
.. 1
2
3
4
Table 3. Direct measurements of a and B-y contamination levels
on upper walls and ceiling in Buildings 1, 2, 3, and 4
Number of Direct a measurements e-y dose
measurement5 Average Maximum Average
(dpm/lOOcm2 ) (dpm/100c:m2 ) (mr::~d/hr)
67 900 ssoo 0.24
36 280 1144 0.16
-16 so 360 0.07
10 cc. a~cause some radon an~ progeny from previous 2000-
cond intervals remain in the Wrenn chamber, each reading act1.:::1ly rep:::csents a concentr.l’!’:i.C;-,
ich has been intet:;J.·ated over a period of 2 to 4 hr.
: ~· t .. ·–· — . ·-· ·–· -~-….,.—:—–.. ·-………….. -. ______ …. ..
… –·
I ”
::-:-:”:”
·.
Table 6. Concentration of radionuc1ides in soil
samples taken inside and near buildings
Sample
location Depth 226Ra 2380
(pCi/g) (pCi/g)
In and around Buildings
1. 2, 3. and 4 surface 120 N.D. a
Building 2, grid point C3 surface 28 20
Building I. near grid
point 04 6 – 9 in. 240 190
Building 1, near grid
point 04 0 – 6 in. 130 200
Building 2, grid point B2 surface 16 17
Outdoors, near grid
point GlO surface 3 2.1
Outdoors, near grid point
a
JCS • near railro~d spur surfa.ce 2700 N.D.
Building 1. grid point Gl surface 430 860
Building 1. grid point E4 surface 320 550
On railroad spur. near Sh’
~u .. wer of 8uilding 1 surface 470 530
Building l, grid point C3 surface 190 420
Building 1, grid point Al surface 540 1100
aN.D. : not determined.
• : . , ….
.. ..
227Ac
(pCi/g)
110
16
260
140
11
.: 1.3
1300
530
370
390
230
700
.. l
. I
–·
• ~~
-.
~
§=
~-
;=; ;
~– m..
I
,_ \. ··- .
Table 7. Outdoor measurements at grid points of beta-gamma
dose rates and external gamma radiation levels
Grid point Beta-gamma dose rate External gamr.la radiation
(See Fig. ll) at 1 em level at l m
(mrad/hr) (llR/hr)
Al 0.04 20
A2 0.50 125
A3 0.50 220
A4 0.30 220
AS 0.”35 1SS
A6 . 0.20 155
A7 0.18 180
AS 0.18 170
A9 0.25 155
AIO 0.10 80
All 0.10 65
Al2 0.18 110
Al3 . 0.18 140
Al4 1.20 375
A15 0.18 110
Al6 0.13 45
Al7 0.13 45
Al8 0.11 80
Al9 o·.u 80
Bl 0.03
•. 25
..
82 0.08 55
83 0.20 95
– ··-·- – – ____ … _. .. _.. .. –·”•• .
.:
t : . . ·-· ·- ‘ .
table 7. (coat~d.) Outdoor measurements at grid points of beta-gaE~a
dose rates and external_ gamma radiation levels
—-
” M ~.:.:
==
~~
::-::.
!’!” :.:..
=
:y;~ .
-~·· .
:
./ “”. \
‘-•:
Table·,. (cont’d.) Outdoor measurements at grid points of beta-gamma
dose rates and external· gamma radiation levels
Grid point Bet~~amma dose’rate -External_. ga.t-nma radiation
(See Fig. 11) at 1 em level at l rn
(mrad/hr)
.
(llR/hr)
C8 0.08 30
C9 0.09 40
ClO 0.08 45
Cll 0.04 20
Cl2 o.os 25
Cl3 0.04 20
C14 0.03 20
ClS 0.04 25
Cl6. 0.05 20
Cl1 0.23 85
C18 0.21 125
Cl9 0.80 3 ….. f;)
C20 ·0.25 220
Dl 0.05 45
02 0.30 170
03 0.08 45
04 0.08 45
OS 0.10 40
06 0.1·3 ss
D7 0.06 . 45
D8 . 0.08 45
·’ ,” .
.· .. , ..
.. •. •
….. -·
)
I
\ ·.. ·1
. . I
!
.: ….

= ~
:c…·

~
···t
Table 7. (cont rd.) Outdoor measurements at grid points of beta-gcurJna
dose rates and external gamma radiation levels
Grid point Bet~-gamma dose rate External gamma radiation
(See Fig. 11} at l em level a’t 1 m
(mrad/hr) (~R/hr)
09 0.10 45
010 0.08 45
Dll 0.04 25
D12 0.03 20
Dl3 0.03 20
014 0.03 20
DIS o.os 30
Dl6 0.08 45
Dl7 0.08 45
018 0.08 45
Dl9 0.08 65
020 0.15 220
El 0.55 190
E2 0.06 40
E3 0.04 40
E4 0.06 30
ES 0.05 40
E6 0.06 45
E7 o.os 30
E8 o.os .30
E9 0.04 20
.ElO 0.03 25 .
·- …. -···-. -.– ·–· – —–·
.– — ··-··· … –

‘ !

• ‘:””-:.:,.
:
~
==·
~
~~;
-~~i
‘ ,
Table 7. (cont’d.) Outdoor measurements at grid points of b~~a-garr~a
dose rates and external. gamma radiation levels
Grid point
{See Fig. ll)
Ell
El2
El3
El4
ElS
El6
E17
El8
E19
E20
Fl
F2
F.3
f4
F5
F6
F7
F8
F9
FlO
Fll
Fl2
Beta-gamma dose rate
at l em
.. : . >
(mrad/hr)
0.03
0.04
0.04
0.08
0.08
0.14
0.06
0.06
0.06
0.55
0.15
0.10
0.10
0.18
0.28
0.08
0.06
0.06
0.10
0.06
0.05
0.06
External ga~”a radiation
level at· 1 m
(JJR/hrj
20
25
30
35
40
85
35
30
45
150
140
45
80
140
95
65
25·
45
50
45
40
40
..

… – — ·- ··–~— -..
_.
i
i
t
t
t
-·~)
—‘ /-·.. .
; .) \ …
Table 7. {cont’d.) Outdoor measurements at grid points of beta-ga~~a
dose rates and external gamma radiation levels
…..
il ·-~·~”!
. . ~
:=.! ..
~
~
~
!..:.~. === :
;;;; -‘l .
.- ‘””;
Table 7. (cont’d.) Outdoor measurements at grid points of beta-garr~a
dose rates and external gamma radiation levels
Grid point Bet~-gamma dose rate External gar..rna radi. ~··:
.:’:~.).’.”
.. … . . ‘ ‘ .
··. ·::.:. ~ ::· ? ·~.:. .~ :.: . ·:·. .. :~~~·:;~.~:-.~;~-?·::. .
Enci~~ur~s -·.. = : ; ·· ‘\/.-:· ~:
, \ . .-:·:·:~._; ~::-::~: ….. ·-.. … .. .. .
PKF:pac
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.. . ; -··
. ~ … .:. . … . . : :..: .
….. ~
: …. ·· . !,: :.:· .. · . ·~ .. · .
. ..
,, .,:~:~’i ·. ”-;::\}.~ .
. .. . ~ .
. . · ··:.· ..
‘ t • •• • . . ~ …
I ) ‘ •.., • •• •., • • ; ·•
‘. :.,._. ………….- …’!’·” _… ..:. .·.: ;•’. ._: _;,.·;~.·..·;..:;·..:·._,..· :_.···-,.::….,.; ….;…..·. ~.·;, ..· ~.
: .· ·:
Auome·y Work ·P•o··du· ct·· · ·, . .· .. …..· .. ·. .. · ·· ·.-·~ ··::.. ~ :.: ,t ·:’. ·.~
. . . · ~ · -~ … ~ ~-.. ·:·;~:~:-·.-: ·:.·~ ~.:;~:- ~·:.~: · :·:·.~ :
Prepared .In Anticipation of ~~n’: . .. :. .. :~. .~ !r:.~·~>:·, ::. .~ ‘
.•
.. . ….. ! • • … ..- :.
· … · …. ·. ~· ·
…… , . ;- ~ ……. .
n.ew”+ n /.;._-.. ~——–=l·:_· 1>====9
:!l lia~~.;~;r;m~; win~u~ec======== · ….. ·.·
. · …….. .
.. ‘:-:.:._ ~
~. .. . •.
:-.:~·~;; ….. · .. · .. ·
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~; .
~:.·~ -~· ….
:..~ .–~
“!·. . : . ; .
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..!…-. · -:.·
~.· .. . .
……….
._…,._
···.: :·, …. ..
‘ .. · … –
G
D
m
settling
-P-o-n-d·s· _ _
Colorado
Raffinate
– ·· ..
‘ ~·-·-·
….•.
£
·.~ …… . -· . ;”” .
. ….
.!, ‘ .. ., … ·.~~~
… .. .·, – ··… .
.. :
. f
…. · .• …
l .•f . …;.·_ . :.,.. .
?.~i~t-:., .. •, ·.
0 I . ,……:.
..
.. ·.···
, … ~ •• . • ‘!’:.• •
•• • : :; ·#
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. ·:· ………. .
::..:,·.; .
…: .· . …
··-~
~.:…::• .- ••! .. • . ,. …
. . . ···-·· ·-,. .. · ·:.~· · . ~ tT-·.·.”~ .. ttt ¢ .• !4 . .I A.
Litty Avenue
. . .
0.30
Yellow
B~
0.06 o.os
. ……
c 0 06 0 30 0.100 0~0.02 . • . . • .. – 0.03
.· …. .
.. . … • …. -· • • .;.· .
~—-~o.2o 0 03 ·o.o2
0 0.10 • -0.02
0
· .. ;:-.’. . .
o.o<- -- ·'· \ .. . · ....... . ·- .-.. ·.•·:~ . : ~··: . •. -·. .·: .. .... :~ ~:~-~ ~~ . ..: ·- . ~~ ... -~··· r·...-- .:~· ;~~ ......... - ~:·r~- . ·:. . .·: ..... :, . ... · . ; ..... , ... ~,. 0.01 .,#~'" • .• ---· .• '.*· .• o.os 0.15 0.01 0.02 0.02 o.o1 0.02' 0.02 0.100.02 0.01 0.01 0.04 0.15 o. 04 o. 03 o.os RADIATION MONITORING SURVEY 0.04 0.03 0.07 Values of Gross Activity in MR/hr. at approximately three feet above qrade. April 29, 1974 0.1 0.25 ·"' ;. ~.. . .. .. . .. . :: ·. . . : .· ._.. .. . ..•.. 0.03 .. ~ o. 07 :..-: .. ~·7 .. ;. .·,.. 0~ 0 0.40 0.12

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