2015-03-03 – EPA – West Lake Landfill – One and a half thousand billion picoCuries of Thorium 230 in West Lake Landfill

Site ID: 0714BE01 Mr. Paul V. Rosasco Project Coordinator Engineering Management Support, Inc. 7220... View Document

Post

2016-02-09 – EPA – FEEZOR – Response to Comments to the Draft Work Plan for Installation of a Non Combustible Cover for West Lake Landfill Operable Unit – I

February 9, 2016
Mr. Tom Mahler
On-Scene Coordinator – Missouri I Kansas Remedial Branch Superfund Division
United States Environmental Protection Agency – Region 7
11201 Renner Boulevard
Lenexa, Kansas 66219
Re: Response to Comments to the Draft Work Plan for Installation of a Noncombustible
Cover for West Lake Landfill Operable Unit – I
Mr. Mahler:
On January 29th, 2016, the United States Environmental Protection Agency (USE PA) issued
comments to the above-referenced work plan (hereinafter referred to as the “Draft Work
Plan”). The USEPA conditionally approved the start of field work according to the schedule
in the Draft Work Plan, provided four specific review comments were addressed prior to
the start date. These comments included specific review comment 2, specific review
comment 7, specific review comment 8, and specific review comment 9. This
correspondence addresses these four specific comments. A revised Work Plan that
addresses the remaining comments will be submitted within 14 calendar days of receipt
of the January 29, 2016 letter.
Specific Comment 2: The NCC work plan should include actions to address all
areas potentially impacted by RIM at or near the surface on the Buffer
Zone/Crossroad Property and any contiguous properties. These actions should
be consistent with those planned for the Area 1 and Area 2 disposal cells. Please
include a separate schedule for these areas.
Response:
The entire Buffer Zone is currently owned by Rock Road Industries, Inc. and is therefore
currently accessible to the Respondents for purposes of performing the required work.
The Buffer Zone will be scanned via overland gamma scan according to the procedures
specified in the Work Plan and associated planning documents (e.g., Sampling and • 406 East Walnut Street • Chatham, IL 62629
Phone (217) 483-3118 •Fax (217) 483-2356
WLLFOIA4312 – 001 – 0015975
Analysis Plan). The overland gamma survey will be performed using Ludlum 44-10 (2×2)
Sodium Iodide (Nal) detectors coupled to Ludlum 2221 survey meters modified to
integrate and transfer data from the detector at a rate of once per second to a Trimble
GeoPositioning System (GPS) which stores the gamma reading and the location of that
reading. If the scanning procedures indicate the potential for RIM, the affected areas will
be cleared of vegetation followed by placement of a geotextile fabric and a nominal 8-
inches of road base material. After clearing has occurred 10 feet beyond the extent of
surface RIM identified in the Work Plan, or as further defined by the results of the
overland gamma survey to be conducted along the along the perimeter of the outer
boundary of the extent of surface RIM/outer edge of the NCC, confirmation samples will
be collected at approximately 100 feet spacing along the perimeter except for those areas
where the outer edge of the surface RIM/NCC coincides with the edges of the Area 1 or
Area 2 waste disposal unit boundaries (e.g., along the north side of Area 1 adjacent to the
landfill access road). More frequent biased samples will be obtained from any potential
erosional depositional areas that may be identified during the vegetation clearing,
overland gamma survey or NCC installation activities.
Crossroads Lot 2A2, which is located adjacent to the Buffer Zone, is not owned or
controlled by Respondents, but is owned by others, and therefore is not accessible to the
Respondents at this time. The OU-1 Respondents’ Project Coordinator will contact the
current owner of Crossroads Lot 2A2 to obtain permission to conduct additional
characterization via overland gamma scanning and confirmation testing along the
northern perimeter of Lot 2A2 that does not currently have rock/asphalt cover. The same
procedures (overland gamma scanning and confirmation sampling) will be used as
described in the Work Plan. The results of the characterization will be provided to the
USEPA.
A specific schedule has not been established for the additional characterization of the
Buffer Zone or portions of Crossroads Lot 2A2. It is expected that it should only take a few
hours to one day to scan the Buffer Zone, and only about an hour or two to scan the
uncovered portion of Lot 2A2 (provided we receive permission to do so). This work will
be done once the contractor clears the vegetation from the Buffer Zone, which will occur
after the contractor clears the vegetation leading to the edge of the top of Area 2 and
from the slope of the landfill berm above the Buffer Zone and builds a ramp from the top
of the slope down to the Buffer Zone. A specific schedule has not been established for
these clearing and ramp-building activities.
2
WLLFOIA4312 – 001 – 0015976
Specific Comment 7: Section 2. 2, page 6: This section needs to include more
details regarding the physical placement of the NCC including planned or
potential use of staging areas or stock piles for materials/debris.
Response:
The vegetation will be cleared with a forestry mower attached to a low ground pressure
tractor such as a skid steer. The vegetation will be moistened as necessary to minimize
visible dust prior to the forestry mower advancing. Rutting will be minimized by the
equipment selection. Metal items or other debris on the surface of the existing landfill
will be moved to an area or areas within Area 1 or 2 outside of the extent of where surface
RIM exists. The debris will be stockpiled on the existing asphalt pavement in Area 1 and/or
on the existing inert fill in Area 2, or otherwise placed on an area(s) outside the extent of
surface RIM and non-combustible cover.
Rock stockpiles may be used for temporary storage of rock prior to placement within the
NCC cover area, but it is generally expected the rock material will be delivered to the NCC
cover area via tandem on-road haul trucks, and the trucks will only drive on previously
rocked areas and deposit the rock onto the advancing front of the cleared areas. The
geotextile and rock placement will occur in such a manner that all newly cleared areas will
be covered generally within 24 hours, but not more than 48 hours after clearing.
Specific Comment 8: Section 2.2, page 6: Please provide details identifying the
source of any rock materials used as part of the NCC and how that will be
documented.
Response:
Section 2.2 will be modified to explain that the rock will be provided by the Fred Weber
Quarry. Load tickets from the quarry will be collected to ensure the rock was from this
quarry.
Specific Comment 9: Please clarify what BMPs will be used to address the
potential for contaminants or other debris to mobilize after vegetation is cut.
Response:
Section 2.3 will be modified to include a discussion pertaining to the BMPs. It is
anticipated that placement of the geotextile and rock cover material will generally
occur the same day as the vegetation removal activities, but in any event should be
completed within 48 hours of the vegetation clearing in any particular area. Should
heavy rain be forecasted and an area cannot be covered the same day, storm water
waddles will be placed on any downslope areas. In addition, vegetation clearing will
3
WLLFOIA4312 – 001 – 0015977
not be performed during periods when severe thunderstorms or major precipitation
events (rainfall of a rate of over Yi inch per hour) are forecasted for the site area or
when observations by on-site personnel indicate a potential for a severe
thunderstorm or major precipitation event. Additionally, on days when precipitation
is anticipated to occur, placement of geotextile and rock cover will be coordinated to
closely follow the vegetation clearing activities and the vegetation clearing will be
closely monitored and/or suspended as necessary to ensure that the geotextile and
sufficient cover necessary to anchor the geotextile can be placed prior to the
occurrence of thunderstorms.
If you have any questions or comments, please contact me at your convenience.
Sincerely,
Daniel R. Feezor, P.E.
NCC Cover Field Project Manager
4
WLLFOIA4312 – 001 – 0015978

Post

2016-02-12 – EPA – EMSI – Work Plan for Installation of a Non-Combustible Cover over Radiologically-Impacted Material At or Near the Ground Surface in Radiological Areas 1 and 2

Work Plan for Installation of a
Non-Combustible Cover over
Radiologically-Impacted Material
At or Near the Ground Surface in
Radiological Areas 1 and 2
West Lake Landfill Operable Unit-1
Prepared for
The United States Environmental Protection Agency Region VII
Prepared on behalf of
The West Lake Landfill OU-1 Respondents
Prepared by
Engineering Management Support, Inc.
7220 West Jefferson Avenue, Suite 406
Lakewood, Colorado 80235
In association with
Feezor Engineering, Inc.
406 E. Walnut Street
Chatham, Illinois 62629
and
Auxier & Associates, Inc.
9821 Cogdill Road, Suite 1
Knoxville, Tennessee 37932
January 4, 2016 Revised February 12, 2016
WLLFOIA4312- 001 – 0015856
Table of Contents
1 Executive Summary ………………………………………………………………………………………. 1
2 Work to be Performed ……………………………………………………………………………………. 3
2.1 Extent of Surface RIM …………………………………………………………………………….. 4
2.1.1 Surface RIM Extent ………………………………………………………………………….. 4
2.1.2 Vegetation Cover ……………………………………………………………………………… 4
2.1.3 Other Cover Material ………………………………………………………………………… 5
2.2 Buffer Zone and Crossroads Lot 2A2 Vegetative Areas Investigation ……………. 5
2.3 Placement of a Non-Combustible Cover.. …………………………………………………… 8
2.4 Vegetation Clearing ……………………………………………………………………………….. 10
2.5 Performance Testing ……………………………………………………………………………… 11
2. 5 .1 Initial Testing Prior to the Start of Construction …………………………………. 11
2.5.2 Additional Testing During Vegetation Clearing ………………………………….. 12
2.5.3 Confirmation Testing ………………………………………………………………………. 12
2.6 Demonstration of No Risk of Release from Remaining Vegetation ……………… 13
2.7 Perimeter Air Monitoring ……………………………………………………………………….. 13
2.8 Occupational Monitoring ……………………………………………………………………….. 14
2.9 NCC Inspections and Maintenance ………………………………………………………….. 15
3 Anticipated Schedule For NCC Completion ……………………………………………………. 15
4 Project Team ………………………………………………………………………………………………. 15
5 References ………………………………………………………………………………………………….. 16
Table
1 Area 1 and Area 2 Non-Combustible Cover Installation Schedule- West Lake
Landfill OU-1
Figures
1 Extent of Surface RIM as Defined in the RI – Area 1
2 Extent of Surface RIM as Defined in the RI – Area 2
3 Extent of Surface RIM and Overland Gamma Results from the RI – Area 1
4 Extent of Surface RIM and Overland Gamma Results from the RI – Area 2
5 Extent of Surface RIM and Areas of Existing Cover – Area 1
6 Extent of Surface RIM and Areas of Existing Cover – Area 2
7 Preliminary Extent of Non-Combustible Cover- Area 1
8 Preliminary Extent of Non-Combustible Cover- Area 2
9 Air Quality Monitoring Stations
10 Project Team
Attachments
1 Area 2 Sloped Rock Fill- Plan and Profile View
2 Inspection and Maintenance Plan
ii
WLLFOIA4312- 001 – 0015857
List of Acronyms
Auxier
EMSI
EPA
FEI
FS
GERT
GPS
MARSSIM
MDNR
MMP
Nai
NCC
ou
oz/sy
PPE
QA
QC
RI
RIM
SAP
TAT
TLD
UAO
VOCs
Auxier & Associates, Inc.
Engineering Management Support, Inc.
United States Environmental Protection Agency
Feezor Engineering, Inc.
Feasibility Study
General Employee Radiation Training
GeoPositioning System
Multi-Agency Radiation Survey and Site Investigation Manual
Missouri Department ofNatural Resources
Materials Management Plan
Sodium Iodide
Non-combustible Cover
Operable Unit
ounces per square yard
personal protective equipment
Quality Assurance
Quality Control
Remedial Investigation
Radiologically Impacted Material
Sampling and Analysis Plan
Turnaround Time
thermoluminescent dosimetry
Unilateral Administrative Order
Volatile Organic Compounds
iii
WLLFOIA4312- 001 – 0015858
1 EXECUTIVE SUMMARY
The purpose of this project is to install a non-combustible cover (“NCC”) over those
portions ofOU-1 Areas 1 & 2 where radiologically-impacted material (RIM) is present at
the ground surface, in order to prevent potential surface fires and migration of
contaminants from those Areas, as required by the EPA’s December 9, 2015 Unilateral
Administrative Order (UAO) issued to Bridgeton Landfill, LLC, Rock Road Industries,
Inc., and Cotter Corporation (N.S.L.) (the “OU-1 Respondents”). This Work Plan
describes the work to be performed to install the NCC in accordance with the UAO.
The sequence of actions that will occur from the start of the field work until the noncombustible
cover is in place is as follows:
1) Conduct initial overland gamma survey along the outer edges of the extent of
surface RIM/anticipated extent of rock cover (as shown on the figures in the
Work Plan) in those portions of Areas 1 & 2 that are currently accessible, as
well as in the adjacent Buffer Zone and on the adjacent Crossroad Lot 2A2
property (subject to receipt of permission to access that property).
2) Install non-combustible cover in Area 1, which will include the following:
a) Perform air monitoring- both for on-site workers and for the community
1) For on-site workers -portable air sampler onjob site
2) For community- use present air monitoring program consisting of 13
air monitoring stations around perimeter of Areas 1 & 2
b) Grub and clear trees and vegetation in the areas of surface RIM
c) Chip the vegetation and place the chips on the ground in the areas to be
covered
d) Install geotextile over the cleared areas with surface RIM including the
areas containing chipped woody vegetation cuttings
e) Install 8 inches of rock over geotextile
f) Perform additional overland gamma surveys as the vegetation is cleared
from areas that were not previously accessible due to vegetation cover to
confirm extent of surface RIM
g) Install additional geotextile and rock cover as necessary to cover any
additional surface RIM that may be identified
3) Install non-combustible cover in Area 2, including the adjacent Buffer Zone,
as needed, which will include the following:
a) Perform air monitoring- both for on-site workers and for the community
3) For on-site workers- portable air sampler on job site
4) For community- use present air monitoring program consisting of 13
air monitoring stations around perimeter of Areas 1 & 2
b) Grub and clear trees and vegetation in the areas of surface RIM
NCC Work Plan
1/4/2016 Revised2-12-16
Page 1
WLLFOIA4312- 001 – 0015859
c) Chip the vegetation and place the chips on the ground in the areas to be
covered
d) Install geotextile over the cleared areas with surface RIM including the
areas containing chipped woody vegetation cuttings
e) Install 8 inches of rock over geotextile
f) Perform additional overland gamma surveys as the vegetation is cleared
from areas that were not previously accessible due to vegetation cover to
confirm extent of surface RIM
g) Install additional geotextile and rock cover as necessary to cover any
additional surface RIM that may be identified
4) Perform additional characterization including overland gamma surveying and
soil sample collection to evaluate the potential presence and if present the
extent of surface RIM that may exist on the uncovered (naturally vegetated)
portions of Crossroads Lot 2A2 (i.e., AAA Trailer property).
5) Install rock buttress in Area 2 in that portion of the berm located above the
southeast comer of the adjacent Buffer Zone (Figure 4)
6) Perform radiological soil sampling around the perimeter on the noncombustible
covers in Areas 1 & 2 (including the Buffer Zone) to confirm all
RIM at or near the surface has been covered.
a) Send soil samples to Eberline Analytical for analysis
a. request quick turnaround time for Thorium-230
b. analyze the samples using standard tum-around times for radium,
thorium and uranium isotopes plus protactimium-231 and lead-210
(i.e., the same radiological parameters that were included in the
analyses of the Phase 1D samples and the Additional
Characterization of Areas 1 and 2 samples)
b) Perform additional clearing and covering if and as necessary based on the
initial Thorium-230 results
7) Receive results of standard tum-around time radiological analyses
8) Separately, confirm that remaining trees and vegetation do not present a fire
risk that could result in potential release of RIM into the environment (if
determined necessary by the USEPA). See Sampling and Analysis Plan for
procedures to be followed.
9) Confirm of completion of project to install non-combustible cover
NCC Work Plan
1/4/2016 Revised2-12-16
Page 2
WLLFOIA4312- 001 – 0015860
Please note that many of the above items will occur concurrently, not sequentially. For
example, installation of geotextile and rock will occur concurrently with clearing of
vegetation and performance of overland gamma surveys will occur concurrently with the
vegetation clearing. Similarly, collection of verification samples will occur whenever a
sufficient length of the anticipated final perimeter of the NCC has been installed.
Surveying to provide direction for clearing and construction and to document the
construction will occur concurrently with all of the activities.
For additional information regarding the specific procedures to be followed for this
project, please refer to this Work Plan and the following documents which are an integral
part of this Work Plan:
Health and Safety Plan for Non-Combustible Cover Installation at West Lake
Landfill, Operable Unit 1, Bridgeton, St. Louis County, Missouri dated February
8, 2016.
Radiation Safety Plan for Installation of Non-Combustible Cap, West Lake
Landfill’s Operable Unit 1, 13570 St. Charles Rock Road, Bridgeton, Missouri,
63044, dated January 4, 2016
Quality Management Plan dated December 2015
Surface RIM Identification Sampling and Analysis Plan (SAP), West Lake
Superfund Site Operable Unit 1, dated December 2015
2 WORK TO BE PERFORMED
Paragraph 34.a. of the UAO identifies the following specific items to be addressed in this
Work Plan:
1. A current West Lake Landfill map clearly indicating where RIM is located at or
near the surface in OU-1. This map should also indicate which areas with surface
RIM are currently covered by vegetation or other materials and which remain
exposed to the atmosphere.
2. Plans and schedule for placement of a non-combustible cover or barrier as soon as
possible over all exposed areas at OU-1 where RIM is currently known to be
located at or near the surface and is not otherwise covered by vegetation, fill, or
other materials.
3. Plans for grubbing and clearing all trees and vegetation where RIM is currently
known to be located at or near the surface in OU -1, and placement of a noncombustible
cover or barrier over the cleared areas.
NCC Work Plan
1/4/2016 Revised2-12-16
Page 3
WLLFOIA4312- 001 – 0015861
4. Plans and schedule for the performance of testing to confirm that RIM located at
or near the surface in OU -1 has been covered.
5. Plans and schedule for ensuring the remaining trees and vegetation in OU-1 do not
present a fire risk that could result in the potential for release of RIM into the
environment.
6. Plans and schedule for air monitoring for ensuring protection of both on-site
workers and the surrounding community during grubbing and clearing of trees
and vegetation in OU-1, as well as during placement of the cover or barrier.
7. Plans for maintenance of the cover or barrier until a remedial action selected by
EPA that addresses the surficial RIM is implemented at the Site.
The anticipated activities and schedules to complete these seven items are discussed in
the following subsections of this Work Plan.
2.1 Extent of Surface RIM
The first item specified by the UAO for the NCC Work Plan is a map of the extent of
surface RIM that also shows the areas currently covered by vegetation or other materials.
2.1.1 Surface RIM Extent
The approximate extent of surface RIM was previously identified on Figures 6-1 and 6-3
of the OU-1 Remedial Investigation report (EMSI, 2000). These figures were used as the
initial basis for defining the extent of surface RIM (Figures 1 and 2). The results of the
1995 overland gamma survey (McLaren/Hart, 1996) were also reviewed to identify other
areas where surface RIM may potentially be present in Areas 1 and 2. The results of
these evaluations are summarized on Figures 3 and 4.
2.1.2 Vegetation Cover
Over the years since active waste disposal has ceased, extensive vegetative cover has
grown over the surface of Areas 1 and 2. The aerial photography used as the base
drawing for Figures 1 and 2 displays the extent of vegetation cover on Areas 1 and 2. No
survey of the extent of vegetative cover on Areas 1 and 2 has ever been performed.
Therefore, for purposes of this NCC Work Plan, the extent of vegetative cover is assumed
to extend over all portions of Areas 1 and 2 that are not otherwise covered by inert fill or
asphalt pavement (described below).
NCC Work Plan
1/4/2016 Revised2-12-16
Page4
WLLFOIA4312- 001 – 0015862
2.1.3 Other Cover Material
A feasibility study (FS) of potential remedial alternatives was completed in 2006 for OU-
1. The FS identified regrading of the surface of Areas 1 and 2 to promote drainage in
conjunction with installation of a new engineered landfill cover as likely components of
remedial action for OU -1. In anticipation of the regrading and landfill cover construction
activities, Bridgeton Landfill prepared a Materials Management Plan (MMP) (EMSI,
2006), which was subsequently approved by the Missouri Department of Natural
Resources (MDNR). The purpose of the MMP was to allow Bridgeton Landfill to accept
for disposal inert fill material that could be placed on the surfaces of Areas 1 and 2 to
assist with the anticipated regrading and cover construction activities. Pursuant to the
MMP, over the period from approximately 2006 through 2008, Bridgeton Landfill
accepted concrete rubble, brick and other inert fill material which was placed in a
topographic low (surface depression) in Area 1 and on the ground surface in Area 2. The
extent of inert fill material on the surface of Areas 1 and 2 is shown on Figures 5 and 6.
In addition to the inert fill material, portions of the surface of Area 1 were historically
covered with asphalt pavement. The extent of the asphalt pavement in Area 1 is shown
on Figure 5. Cracks and other discontinuities exist in the asphalt pavement such that
grasses, weeds and small trees have rooted in the area of the asphalt pavement.
Lastly, as part of recently performed additional investigations in Areas 1 and 2,
vegetation was cleared and geotextile overlain by a nominal 8-inch thick layer of road
base was placed along the roads and drill pads used to access Areas 1 and 2 to perform
additional soil borings. The locations of the various roads in Areas 1 and 2 are shown on
Figures 5 and 6.
2.2 Buffer Zone and Crossroads Lot 2A2 Vegetative Areas Investigation
It should be noted that, based on samples collected by McLaren Hart in 1995 (boreholes
WL-201 through WL-208), EMSI in 1997 (samples designated FP-1 through FP-8), and
Herst & Associates in 2000 (RC-01 through RC-07), the Remedial Investigation (RI)
(EMSI, 2000) also identified occurrences of radionuclides in surface soil in the southern
portion of what at that time was property owned by Ford Motor Credit (referred to in the
RI as the Ford property but after a subsequent parcel division and sales has since been
referred to as the Buffer Zone and Crossroads Lot 2A2), located immediately to the north
and west of Area 2. Reportedly, after completion oflandfilling activities in Area 2, but
prior to establishment of a vegetative cover over the landfill berm, erosion of soil from
the landfill berm resulted in the transport of radiologically-impacted materials from Area
2 onto the adjacent Ford property (EMSI, 2000). The landfill berm and the adjacent
properties were subsequently re-vegetated by natural processes, and no subsequent
erosion or other failures are present.
NCC Work Plan
1/4/2016 Revised2-12-16
Page 5
WLLFOIA4312- 001 – 0015863
Ford sold a portion of the property to Crossroad Properties, LLC (Crossroad), and sold
the remaining portion (the Buffer Zone) to Rock Road Industries to provide a buffer
between the landfill and the adjacent properties. In November 1999, third parties scraped
the vegetation and surface soil on Crossroad Lot 2A2 and the Buffer Zone to a depth of
approximately 2 to 6 inches. These activities were unauthorized and reportedly
conducted by AAA Trailer, the current tenant of the Crossroad property. The removed
materials were piled in a berm along the southern boundary of the Buffer Zone, adjacent
to the northwestern boundary of the West Lake Landfill. A small amount of removed
materials was also placed in a small pile on the Crossroad property near the base of the
landfill berm along the east side of Lot 2A 1.
In February 2000, additional surface soil samples (RC-01 through RC-07) were collected
from the dish1rbed area and submitted for laboratory testing. Only one sample (RC-02)
obtained from the Buffer Zone, below and adjacent to the toe of the landfill berm,
contained radionuclides (thorium-230) above levels that would allow for unrestricted use.
The remainder of the samples contained either background levels of radionuclides or
levels above background but within levels that would allow for unrestricted use. The
results of the additional soil sampling indicated that most of the radiologically impacted
soil that had previously been present on the Buffer Zone and Lot 2A2 of the Crossroad
property had been removed and placed in the stockpiles. Evaluation of the soil sampling
results obtained prior to and after the 1999 disturbance indicates that approximately one
acre of the Buffer Zone may at that time still have contained some radionuclides above
levels that would allow for unrestricted land use (i.e., combined radium or combined
thorium activities greater than 5 pCi/g plus background which equates to 7.9 pCi/g).
Inspection of the area in May 2000 indicated that native vegetation had been reestablished
over both the disturbed area and the stockpiled materials. The sequence of
soil sampling activities and associated results are presented in the RI (EMSI, 2000)
A 2004 inspection of this area indicated that additional soil removal/re-grading had been
performed on the remaining portion of the Crossroad property and the adjacent Buffer
Zone property by, or on the behalf of, AAA Trailer. These activities appear to have
resulted in removal of the soil stockpiles created during the previous re-grading activity
reportedly conducted by AAA Trailer, removal of any remaining soil on Lot 2A2 and the
Buffer Zone not scraped up during the 1999 event, and placement of gravel over the
entirety of Lot 2A2 and the Buffer Zone. According to AAA Trailer, all of the soil
removed during the July 1999 grading work and the May 2003 gravel layer installation
was placed in the northeastern comer of the Buffer Zone (terra technologies, 2004).
No sampling has been performed since the most recent (May 2003) grading work
conducted by AAA Trailer, and therefore the levels and extent of radionuclides, if any,
that may remain in the soil at the Buffer Zone and Crossroad Property are unknown. As
discussed above, the entire area was covered with gravel and portions of this area were
subsequently paved by AAA Trailer. In addition, as discussed in Section 2.2 below, it is
anticipated that a temporary rock buttress will be constructed on the Buffer Zone parcel
to provide for an NCC on the landfill slope in this area. Therefore, any surface RIM that
may still exist on the Buffer Zone property will be covered by the temporary rock
NCC Work Plan
1/4/2016 Revised2-12-16
Page 6
WLLFOIA4312- 001 – 0015864
buttress. Additional soil sampling to determine current conditions with respect to
radionuclide occurrences in the Buffer Zone and Crossroad Property soil are expected to
be conducted as part of remedial design activities associated with implementation of the
selected remedy for this area.
Additional discussion of the prior sampling and activities relative to the Buffer Zone and
Crossroads Lot 2A2 can be found in the RI (EMSI, 2000), Feasibility Study (EMSI,
2006) and Supplemental Feasibility Study (EMSI, 2010).
The entire Buffer Zone is currently owned by Rock Road Industries, Inc. and is therefore
currently accessible to the Respondents for purposes of performing the required work.
The Buffer Zone will be scanned via overland gamma scan according to the procedures
specified in the Work Plan and associated planning documents (e.g., Sampling and
Analysis Plan). The overland gamma survey will be performed using Ludlum 44-10
(2×2) Sodium Iodide (Nai) detectors coupled to Ludlum 2221 survey meters modified to
integrate and transfer data from the detector at a rate of once per second to a Trimble
GeoPositioning System (GPS) which stores the gamma reading and the location of that
reading. If the scanning procedures indicate the potential for RIM, the affected areas will
be cleared of vegetation followed by placement of a geotextile fabric and a nominal 8-
inches of road base material. After clearing has occurred 10 feet beyond the extent of
surface RIM identified in the Work Plan, or as further defined by the results of the
overland gamma survey to be conducted along the perimeter of the outer boundary of the
extent of surface RIM/outer edge of the NCC, confirmation samples will be collected at
approximately 100 feet spacing along the perimeter except for those areas where the
outer edge of the surface RIM/NCC coincides with the edges of the Buffer Zone. More
frequent biased samples will be obtained from any potential erosional depositional areas
that may be identified during the vegetation clearing, overland gamma survey or NCC
installation activities.
Crossroads Lot 2A2, which is located adjacent to the Buffer Zone, is not owned or
controlled by Respondents, but is owned by others, and therefore is not accessible to the
Respondents at this time. After receipt of EPA approval to do so, the OU-1 Respondents’
Project Coordinator will contact the current owner of Crossroads Lot 2A2 to obtain
permission to conduct additional characterization via overland gamma scanning and
confirmation testing within all uncovered areas of Lot 2A2 that are contiguous with the
West lake Landfill Area 2 Fence. The same procedures (overland gamma scanning and
confirmation sampling) will be used as described above for the Buffer Zone. Upon
receipt of site access to conduct the additional characterization work on Lot 2A2, such
work will be conducted in accordance with any conditions imposed by the property
owner and as soon as personnel and equipment can be made available without otherwise
disrupting work associated with construction of the NCC. The results of the additional
characterization will be provided to the USEP A.
A specific schedule has not been established for the additional characterization of the
Buffer Zone or portions of Crossroads Lot 2A2. It is expected that once sufficient
vegetation has been cleared, it should only take approximately one day to perform the
NCC Work Plan
1/4/2016 Revised2-12-16
Page 7
WLLFOIA4312- 001 – 0015865
overland gamma survey of the Buffer Zone. This work will be done once the contractor
clears the vegetation from the Buffer Zone, which will occur after the contractor clears
the vegetation leading to the edge of the top of Area 2 and from the slope of the landfill
berm above the Buffer Zone and builds a ramp from the top of the slope down to the
Buffer Zone. A specific schedule has not been established for these clearing and rampbuilding
activities.
It is anticipated that overland gamma surveying of uncovered, natural vegetation areas on
Crossroads Lot 2A2 can be completed in a few hours (provided we receive permission to
do so). Any additional characterization work associated with certain areas of Lot 2A2
will not be contingent on any work which would be performed in the Buffer Zone.
Coordination with EPA to obtain to access and additional characterization of Lot 2A2
will begin within 14 days of EPA’s approval of the work plan.
2.3 Placement of a Non-Combustible Cover
Based on the extent of RIM described in Section 2.1 and shown on Figures 3 and 4, and
also taking into account the extent of inert fill material and road base that currently exists
in Areas 1 and 2 (Figures 5 and 6), the anticipated extent of the NCC has been identified
as shown on Figures 7 and 8. Please note that the extent of asphalt pavement in Area 1 is
not included as part of the extent of existing cover material because as noted above,
vegetation has grown up through cracks and other discontinuities in the asphalt pavement
and asphalt is not considered to be a non-combustible material. By comparison, the inert
fill material and road base that currently exist in Areas 1 and 2 were included as part of
the estimation of existing cover material. The areas of inert fill that are in close
proximity to the proposed extent of new non-combustible cover will need to be visually
inspected to determine if any additional rock cover needs to be place on or adjacent to the
existing inert fill material.
Given that the extent of surface RIM in Areas 1 and 2 is approximately 1.4 acres in Area
1 and 8.74 acres in Area 2 and the extent of existing inert fill and road base cover is
approximately 0.4 acres in Area 1 and 0.79 acres in Area 2, the total area for NCC
constmction in Areas 1 and 2 is estimated to be 1.0 and 7.95 acres, respectively. In order
to ensure that the extent of surface RIM in these areas is completely covered, the bid
specifications for the NCC will require the contractor to extend the cover placement
nominally 10 ft beyond the edge of all areas where surface RIM is identified as being
present within Areas 1 and 2; however, the cover will not extend beyond the limits of the
Area 1 or 2 waste disposal units. Therefore, the total extent of the NCC cover is
anticipated to be approximately 1.2 acres in Area 1 and 8. 7 5 acres in Area 2 for a total
area of approximately 10 acres in these two areas.
Placement of a NCC over these areas will entail cutting/removal of the existing
vegetation in these areas followed by placement of a geotextile fabric and a nominal 8-
inches of road base material. The anticipated profile for the NCC is shown on Figures 7
and 8. If evidence of surface water flows and sediment deposition is noted outside of the
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areas to be covered by the NCC, a sample of the sediment area will be collected and
tested as part of the confirmation testing (see Confirmation Testing, Section 2.5.3). If the
analytical testing of the sediment sample indicates the presence of surface RIM, the area
of sediment accumulation associated with such a sample will be covered with a geotextile
and new rock fill.
The vegetation will be cleared with a forestry mower attached to a low ground pressure
tractor such as a skid steer. The vegetation will be moistened as necessary to minimize
visible dust prior to the forestry mower advancing. Rutting will be minimized by the
equipment selection. Metal items or other debris on the surface of the existing landfill will
be moved to an area or areas within Area 1 or 2 outside of the extent of where surface RIM
exists. The debris will be stockpiled on the existing asphalt pavement in Area 1 and/or on
the existing inert fill in Area 2, or otherwise placed in an area( s) outside of the extent of
surface RIM/non-combustible cover.
Rock stockpiles may be used for temporary storage of rock prior to placement within the
NCC cover area, but it is generally expected the rock material will be delivered to the NCC
cover area via tandem on-road haul trucks, and the trucks will only drive on previously
rocked areas and deposit the rock onto the advancing front of the cleared areas. The
geotextile and rock placement will occur in such a manner that all newly cleared areas will
be covered generally within 24 hours, but not more than 48 hours after clearing.
The source of the rock will be from a local quarry (most likely the Fred Weber quarry in
Maryland Heights, MO). The field engineer will collect load tickets from the drivers to
verify at the end of the day to verify the source of rock was from a commercial quarry.
It is likely that surface RIM is present along a portion of the landfill berm on the north
side of Area 2, specifically in that portion of the berm located above the southeast comer
of the adjacent Buffer Zone (Figure 4 ). Because of the steep slope (1.5H: 1 V) associated
with the landfill berm, placement of geotextile with 8-inches of road base is not
anticipated to provide for a stable cover. Therefore, in this area, a temporary rock
buttress will be constructed from the base to near the top of the landfill berm. The rock
buttress will be constructed by clearing vegetation from the Buffer Zone and from the
landfill berm slope to the extent it can be conducted in a safe manner, followed by
placing road base material on the Buffer Zone and extending up the face of the landfill
berm. Attachment 1 presents a drawing of the preliminary design for the rock buttress.
This rock buttress would be temporary, and, if necessary, most of the rock could be
reclaimed during implementation of future remedial actions that may be implemented at
the Site.
The OU-1 Respondents have employed the procurement services ofBridgeton Landfill,
Inc. and Republic Services, Inc. to procure a contractor to perform the vegetation clearing
and construct the NCC. A bid package was completed and released to the prospective
contractors on January 12, 2016 and that bids were received by January 22, 2016.
Review of the bids and notice of intent to award were completed by February 3, 2016.
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The bid package included a sample contract with the West Lake Landfill NPL Site Trust
(“the Trust”) so the prospective contractors were aware of all contract conditions.
It is anticipated that installation of the NCC will begin on February 15, 2016 subject to
weather conditions and the availability of the contractor personnel, necessary equipment
(e.g., forestry mower) and required materials (e.g., geotextile). Prior to starting any work
on site, the selected contractor personnel will be provided General Employee Radiation
Training (GERT) if they have not already received it, as well as an overall orientation to
Bridgeton Landfill safety procedures and communication of potential hazards associated
with the NCC project. EPA was provided notice of the contractor selected to perform the
work (Keusel Excavating Co. Inc.) on February 3, 2016 as set forth in Paragraph 30 of
the UAO. EPA was provided notice of the intended start of construction on February 12,
2016, in accordance with Paragraph 36(c) of the UAO.
2.4 Vegetation Clearing
Vegetation removal and construction of the NCC are anticipated to be performed using
procedures similar to those previously employed to construct the access roads and drill
pads during the prior Phase 1, Phase 1D, and Additional Characterization of Areas 1 and
2 investigations. Specifically, the vegetation will be cut near but above the ground
surface using a “brush hog”, a skid steer with a forestry cutter/grinder attachment, or
equivalent equipment. Such equipment can cut and grind woody vegetation without
disturbing the underlying ground surface or vegetation roots. The vegetation cuttings
will be chipped and placed on the ground surface. Any significantly sized wood
vegetation) that needs to be removed will be cut with tree shears and chipped in a wood
chipper. If necessary, the woody vegetation will be moistened with a water cannon prior
to grinding to minimize chipping dust. The chipped woody vegetation will be placed
beneath the extent of the NCC prior to geotextile deployment. Any material that is too
large to chip (such as larger tree limbs or trunk sections) will be cut into 10 foot sections
and placed in low lying areas and covered with geotextile and rock. The goal will be to
minimize any uncovered logs long term. Should this not be possible, the logs will be
neatly placed in an area where there is no RIM at or near the surface.
A geotextile will be laid on top of the cleared area and vegetation chips over which
approximately 8 inches of road base material will be placed. Profile views of the final
NCC are provided on Figures 7 and 8. Based on prior experience with building drill pad
access roads in Areas 1 and 2, it is anticipated that additional road base material will need
to be placed in any depressed areas or at the base of any steep slopes (e.g., steeper than
4H:1V).
The areas of the inert fill that are in close proximity to the proposed extent of new noncombustible
cover will visually inspected to determine if any additional fill placement is
necessary in the transition area between the new rock cover and the existing inert fill.
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It is anticipated that placement of the geotextile and rock cover material will
generally occur the same day as the vegetation removal activities, but in any event
should be completed within 48 hours of the vegetation clearing in any particular
area. Should heavy rain be forecasted and an area cannot be covered the same day,
storm water waddles will be placed on any downslope areas. In addition, vegetation
clearing will not be performed during periods when severe thunderstorms or major
precipitation events (rainfall of a rate of over Y2 inch per hour) are forecasted for the
site area or when observations by on-site personnel indicate a potential for a severe
thunderstorm or major precipitation event. Additionally, on days when precipitation
is anticipated to occur, placement of geotextile and rock cover will be coordinated to
closely follow the vegetation clearing activities and the vegetation clearing will be
closely monitored and/or suspended as necessary to ensure that the geotextile and
sufficient cover necessary to anchor the geotextile can be placed prior to the
occurrence of thunderstorms.
NCC construction will only occur during days where the working temperatures will be 25
degrees or higher. The average temperature for February is approximately 35 degrees
and the average temperature for March is above 40 degrees, so this requirement should
generally not limit construction. Should the temperatures drop below freezing, caution
will be used to avoid using too much water (needed for dust suppression) to avoid ice
accumulations to prevent slips, trips or falls.
2.5 Performance Testing
It is anticipated that testing will be conducted in three phases to verify the extent of
surface RIM and to confirm that the NCC extends over the full extent of surface RIM.
2. 5 .1 Initial Testing Prior to the Start of Construction
Subject to physical access constraints posed by the existing vegetation cover, an initial
overland gamma survey will be performed along the margins of the estimated extent of
surface RIM (Figures 3 and 4) to provide an initial verification of the extent of surface
RIM. Prior to conducting the overland gamma survey, a reference area or areas will be
identified and overland gamma survey background values will be obtained from this
area(s).
The overland gamma survey will be performed using Ludlum 44-10 (2×2) Sodium Iodide
(Nai) detectors coupled to Ludlum 2221 survey meters modified to integrate and transfer
data from the detector at a rate of once per second to a Trimble GeoPositioning System
(GPS) which stores the gamma reading and the location of that reading. The detectors
will be hung approximately six-inches above the ground surface and advanced at a rate of
approximately 0.5 meters per second. Separation between the scanned transit lines will be
approximately 1.5 meters unless influenced by terrain. Stored data will be downloaded
and processed using commercially available software applications and plotted on a map
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of the Areas. Individual points will be assigned colors based on the magnitude of
instrument response at that location.
Additional details regarding the data quality objectives and the procedures to be used for
the overland gamma survey can be found in the Sampling and Analysis Plan (SAP)
(Auxier, 2015a).
No problems or issues for performance of the overland gamma survey are expected to be
encountered from vegetation hindrances because the overland gamma survey will be
performed prior to or in conjunction with the clearing of vegetation from the areas
identified as containing, or potentially containing surface RIM.
2.5.2 Additional Testing During Vegetation Clearing
Based on the maps generated from the initial overland gamma survey, remaining
inaccessible areas that may contain surface RIM will be identified for vegetation clearing.
A health physicist will then be assigned to perform additional overland gamma surveys in
conjunction with the vegetation clearing activities to further verify the extent of surface
RIM. These surveys will be conducted using the same techniques described above for
the initial survey. The results of the additional surveys will be added to the map of the
results obtained from the initial survey.
2.5.3 Confirmation Testing
Once the results of the overland gamma surveys described above define the extent of
surface RIM, surface soil samples will be obtained along the perimeter to confirm the
absence of RIM beyond the extent determined by the overland gamma surveys. It is
anticipated that the surface soil sampling will be performed outside the perimeter of the
defined surface RIM/outer extent of the NCC to verify that thorium-230 (which cannot be
detected by the overland gamma survey) is not present outside the outer limit of the new
cover at activity levels greater than the level that would allow for unrestricted land use. It
is anticipated that soil samples will be collected from locations spaced approximately 100
feet apart along the perimeter of the outer boundary of the extent of surface RIM/ outer
edge of the NCC except for those areas where the outer edge of the surface RIM
coincides with the edges of the Area 1 or Area 2 waste disposal unit boundaries. More
frequent biased samples will be obtained from any potential sediment depositional areas
that may be identified during the vegetation clearing, overland gamma survey or NCC
installation activities. This confirmation testing will occur on the edge of the 10-foot
outer clearing limit, so the area will be cleared of vegetation.
Surface soil samples (if any) will be submitted to Eberline Analytical Laboratory
(Eberline) for quick tum-around-time (TAT) isotopic thorium analysis. The quick TAT
isotopic thorium analyses will allow for an initial, quick determination as to whether the
extent ofNCC is sufficient or ifplacement of additional NCC may be required while the
NCC contractor is still present at the site. The samples will also be analyzed for isotopic
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uranium and gamma spectroscopy in order to provide data comparable to the other
investigatory data obtained from OU-1 areas.
2.6 Demonstration ofNo Risk of Release from Remaining Vegetation
Upon completion of the installation of the NCC and subject to performance of routine
inspection and maintenance activities to verify that the NCC remains effective in
isolating the RIM from the atmosphere or surface events (e.g., exposure to vegetation
fire, erosion by wind or water, etc.), there should not be any potential for surface releases
from the areas covered by the NCC.
Vegetation located outside the extent of surface RIM will remain on site. The results of
the previous (2009) collection and analysis of vegetation samples demonstrated that the
site vegetation contains only background levels ofradionuclides (T.A. Woodford and
Associates, 2009). Therefore, in the event of a vegetation fire in these areas, the
remaining vegetation at the site is not anticipated to pose any risk of release of
radionuclides.
Discussions with EPA have indicated that they are still reviewing the results of the 2009
vegetation sampling event relative to the potential for release of radionuclides in the
event a vegetation fire occurs at the site. If EPA concludes that the existing sample data
provide sufficient basis to demonstrate that the remaining vegetation would not pose a
risk of release in the event of a fire, no additional sampling will be conducted. If EPA
determines that additional sample collection and analyses are required to complete the
specified demonstration, additional samples will be obtained as necessary to demonstrate
that the remaining vegetation does not pose a threat of release of radionuclides in the
event of a fire.
The Sampling and Analysis Plan (Auxier, 2015a) being submitted in conjunction with
this Work Plan contains additional details regarding the scope and procedures to be used
in the event that additional vegetation sample collection and analyses are requested by
EPA.
2.7 Perimeter Air Monitoring
Pursuant to a prior request from EPA, the OU -1 Respondents previously implemented an
air monitoring program consisting of 13 stations located around the perimeters of Areas 1
and 2 and elsewhere at the West Lake Landfill/Bridgeton Landfill site (Figure 9).
Specifically, an Air Monitoring, Sampling and QA/QC Plan was prepared (Auxier &
Associates, Inc., 2014), and was approved by EPA on December 5, 2014. Installation of
the air monitoring stations was performed in early 2015, and continuous air monitoring
began on May 1, 2015. A report of the results from the first quarter of air monitoring
activities (May, June and July 2015) was submitted to EPA on December 9, 2015 (Auxier
and EMSI, 20 15).
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The perimeter air monitoring activities include sampling for airborne radioactive
particulates, radon gas, and volatile organic compounds (VOCs), and measurements of
gamma radiation. Sampling is performed continuously at the perimeters of OU -1 Areas 1
and 2. All 13 monitoring stations include air sampling pumps equipped with air sample
filters for collection of particulate samples for analyses of alpha and beta emitters. The
particulate filters are collected every four weeks (28 days) and sent to Eberline Analytical
for laboratory analyses. One set of the three sets of filter samples obtained during each
calendar quarter are also analyzed for uranium and thorium isotopes and for radium by
gamma spectroscopy. All 13 monitoring points also include radiation dosimeters for
measurement of gamma radiation, and alpha track etch detectors for measurement of
radon emissions that are submitted for laboratory analysis by Mirion Technologies and
AccurStar, respectively, every calendar quarter.
Five of the monitoring stations house continuous passive samplers to monitor for VOCs.
Monitoring ofVOCs is performed using the Radiello Code 130 chemical adsorbing
cartridge diffusion samplers that are left in place for periods of 14 days. These sampling
devices are submitted to EuroFins Air Toxics Ltd for VOC analyses.
Data obtained from the ongoing perimeter air monitoring program are expected to be the
primary method for evaluation of protection of the surrounding community during
installation of the NCC over the surface RIM in OU-1.
2.8 Occupational Monitoring
In addition to the continued operation of the perimeter air monitoring program currently
employed for Areas 1 and 2, temporary air monitoring activities will be conducted during
the vegetation clearing and NCC placement activities. Specifically, portable air pumps
equipped with filters will be set up near active work areas and/or installed on equipment
to obtain particulate samples for analysis for alpha and beta emitters.
Ambient radiation levels in work areas will be routinely monitored during NCC
construction. In addition, all workers will wear thermoluminescent dosimetry (TLD)
badges to monitor their exposures to gamma radiation. The data obtained from analysis
of samples collected by the portable air sampling equipment and TLDs will be used to
verify that site workers are not exposed to radiation or radioactive materials above
permissible levels.
In conjunction with use of personal protective equipment (PPE) and adherence to
procedures set forth in the Health and Safety Plan (Auxier, 2015b) and Radiation Safety
Plan (Auxier, 2015c ), the results obtained from the perimeter and portable air sampling
points and TLDs will be used to ensure protection of site workers.
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2.9 NCC Inspections and Maintenance
Quarterly inspections will be performed by a designee of the OU-1 Respondents to verify
that the NCC remains intact and that stormwater runoff, burrowing animals or other
activities have not caused any impacts that would affect the performance of the NCC.
Additional inspections will be conducted after major precipitation events of sufficient
intensity and/or duration to potentially impact the integrity of the NCC.
A description of the anticipated NCC inspection and maintenance activities is included as
Attachment 2.
3 ANTICIPATED SCHEDULE FOR NCC COMPLETION
Table 1 presents an anticipated schedule for the various activities to be conducted to
place the NCC over the surface RIM, collect and analyze samples to confirm that the
NCC completely encompasses the surface RIM, and, if necessary, collect and analyze
samples of vegetation obtained from outside the extent of surface RIM to further support
the demonstration that in the event of a fire, the remaining vegetation will not result in a
release of radionuclides. Subject to weather conditions, equipment and material
availability and other factors, the OU -1 Group anticipates installation of the additional
cover material will be completed within approximately 90 days of EPA approval of this
Work Plan and the related project plans.
The status and results of the work performed to plan, construct and inspect/maintain the
NCC cover will be tracked and reported to EPA in monthly status reports, as required by
the UAO. A final report documenting the NCC installation is anticipated to be completed
within 30 days of receipt of the final analytical laboratory report for the confirmation soil
samples.
4 PROJECT TEAM
The project team will consist primarily of contractors that have previously been working
in Areas 1 and 2 along with a construction contractor to be retained to perform the
vegetation clearing and placement of the non-combustible cover.
Engineering Management Support, Inc. (EMSI) will provide overall coordination of the
work including coordination of preparation of project plans, coordination of the various
contractors, and coordination with EPA. Specifically, Paul Rosasco, P.E., the designated
Project Coordinator under the UAO, will serve as the overall Project Coordinator for the
Respondents, with assistance from Robert Jelinek, P.E. EMSI will also be responsible
for preparation of monthly progress reports and overall coordination of the final report
for the NCC installation project.
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Feezor Engineering, Inc. (FEI) will provide office and field engineering services,
including preparation of design and record drawings, supervision and documentation of
field activities, and collection of confirmation surface soil samples (as necessary). Daniel
Feezor, P.E., will serve as lead Project Engineer and Jonathan Wilkinson, P.E., will be
lead Field Engineer for this project. FEI will also perform post-installation NCC
inspections to verify that the NCC remains intact and identify any maintenance or repair
activities that may be required.
Auxier & Associates, Inc. (Auxier) will provide health physics services including
performance of radiation surveys including but not limited to overland gamma surveys,
perimeter air monitoring, occupational monitoring during NCC construction, and free
release surveys for equipment exiting Area 1 and 2. Michael R. Bollenbacher, CHP will
serve as lead health physicist and radiation safety officer. Mr. Bollenbacher will be
assisted by Cecilia Greene, MPH who will serve as the Health Physics project manager.
Alex Luna will be the on-site health physics technician and site safety officer. Auxier
will be responsible for implementation of the project health and safety and radiation
safety plans for this work.
Weaver Consultants Group (Weaver) will survey the locations where confirmation
surface soil samples are collected, provide survey control during construction, and survey
the outer limits of the final, installed NCC. Collin Carson will serve as lead surveyor for
the NCC installation project.
Eberline Analytical/Oak Ridge Laboratory will perform radionuclide analyses of soil
samples collected to provide confirmation that the NCC extends beyond the extent of
surface RIM.
Kuesel Excavating Co., Inc. was selected as the construction contractor for the vegetation
clearing and installation of the non-combustible cover over areas where RIM is present or
potentially is present at or near the ground surface in Areas 1 and 2 and the Buffer Zone.
Kuesel Excavating Co., Inc., is based in O’Fallen, Missouri and has been performing
demolition, clearing, grading, utility installation, stream back restoration, and soil
stabilization related services in Missouri for over 50 years. Relative to Bridgeton
Landfill, Kuesel recently provided demolition services and sub-grade preparation related
to construction of the leachate pre-treatment system and is currently working on
stormwater drainage improvements for the site.
5 REFERENCES
Auxier & Associates, Inc. (Auxier), 2015a, Surface Rim Identification, Sampling, and
QA/QC Plan, West Lake landfill Superfund Site Operable Unit-1, December.
Auxier, 2015b, Draft Health and Safety Plan for Non-combustible Cover Installation at
West Lake Landfill, Operable Unit-1, Bridgeton, St. Louis County, Missouri, December
21.
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Auxier, 2015c, “Radiation Safety Plan for Installation ofNon-combustible Cap, in
Operable Unit 1 of Westlake Landfill Operable Unit-1, December 21.
Auxier, 2014, Air Monitoring, Sampling and QA/QC Plan, West Lake Landfill
Superfund Site Operable Unit-I.
Auxier and EMSI, 2015, West Lake Landfill Perimeter Air Monitoring Quarterly Report,
December.
Engineering Management Support, Inc. (EMSI), 2006, Materials Management Plan, West
Lake Landfill Operable Unit 1.
EMSI, 2000, Remedial Investigation Report, West Lake Landfill Operable Unit 1, April
10.
McLaren/Hart, 1996, Overland Gamma Survey Report, West Lake Landfill Radiological
Areas 1 and 2, Bridgeton Missouri, April30.
T.A. Woodford and Associates, LLC, 2009, Vegetation Sampling Results Summary in
Support of Health and Safety Plan for Vegetation Clearing and Grubbing, March.
terra technologies, 2004, Letter to Ms. Cheryle Micinski, USEPA from David Heinze,
terra technologies re: Clarifications to Information Request, West Lake Landfill Site,
September 10, 2004.
United States Environmental Protection Agency (EPA), 2015, Letter from Alyse Stoy
(EPA) to William Beck, Esq. and Jessica Merrigan, Esq., John McGahren, Esq., Steven
Miller, Esq., and Phil Dupre, Esq. RE: In the Matter of Cotter Corporation (NSL), and
Laidlaw Waste Systems (Bridgeton), Inc. and Rock Road Industries, Inc., and the U.S.
Department of Energy, Administrative Order on Consent, EPA Docket No. VII-93-F-
0005, December 9.
EPA, U.S. Department ofEnergy, U.S. Nuclear Regulatory Commission, and U.S.
Department of Defense, 2000, Multi-Agency Radiation Survey and Site Investigation
Manual (MARSSIM), NUREG-1575, Rev 1, EPA 402-R-97-016, Rev. 1, DOE/EH-0624,
Rev. 1, August.
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Table
WLLFOIA4312- 001 – 0015876
Table 1- Westlake OU-1
Area 1 and Area 2 Non Combustible Cover Installation
ID ask Name
Submit Work Plan to USEPA
USEPA Review and Approval of Work Plan
Planning I Bidding
Send Contractors Bid Package
Pre Bid Meeting
6 Bids Due
7 Award Contract
8 Field Work
9 Conduct Overland Gamma Survey
Install NCC Area 1
Install NCC Area 2
12 Install Rock Buttress
Task
Split
Milestone
Project: West Lake NCC Constru
Date: Fri 2/12/16 Summary
Project Summary
Inactive Task
Inactive Milestone
Duration Start Finish 2016
0 days Man 1/4/16 Man 1/4/16
4wks Man 1/4/16 Fri 1/29/16
19 days Fri 1/8/16 Wed 2/3/16
1 day Fri 1/8/16 Fri 1/8/16
3 days Man 1/11/16 Wed 1/13/16
2 wks Man 1/11/16 Fri 1/22/16
8 days Man 1/25/16 Wed 2/3/16
43 days Wed 2/10/16 Fri 4/8/16
6 wks Wed 2/10/16 Tue 3/22/16
1 wk Man 2/15/16 Fri 2/19/16
4wks Man 2/22/16 Fri 3/18/16
3 wks Man 3/21/16 Fri 4/8/16
Inactive Summary External Tasks
Manual Task External Milestone
Duration-only Deadline
Manual Summary Rollup —–Manual
Summary
Progress
Manual Progress
Start-only
Finish-only
Page 1
• +
WLLFOIA4312- 001 – 0015877
Table 1- Westlake OU-1
Area 1 and Area 2 Non Combustible Cover Installation
IDl~ ~~ask IT ask Name
Mode
II!; Project Wrap Up
14 I Radiological sampling around perimeter of
NCC
15 Radiological sample testing and data
validation
16 I Final Report preparation and submittal
Task
Split
Milestone
Project: West Lake NCC Constru
Date: Fri 2/12/16 Summary
Project Summary
Inactive Task
Inactive Milestone
~Duration I Start ~Finish
Dec
2~a1n6
I Feb r I Mav I Jun I Jul
65 days Mon 3/28/16 Fri 6/24/16
1 wk Man 3/28/16 Fri 4/1/16 il
8 wks Man 4/4/16 Fri 5/27/16
4wks Man 5/30/16 Fri 6/24/16
Inactive Summary External Tasks
Manual Task External Milestone • Duration-only Deadline +
Manual Summary Rollup —— Progress
1 Manual Summary
Start-only
Finish-only
Page 2
I Manual Progress
WLLFOIA4312- 001 – 0015878
Figures
WLLFOIA4312- 001 – 0015879
M:\CUENlS\ENSI\ WESTIAKE\2015\RUBBLE -INVESTIGATION\RUBBLE -PAUL -BUILDUP.DWG-AREA 1-FIG1 01/04/2016 4:11PM
LEGEND
– – – – – – Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
(from Figure 6-3 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Notes:
x 2015 Topography And Backround Image Provided By
Cooper aerial Surveys Co. – Dated February 10, 2015
x all Elevations Are Above Mean Sea Level (amsl)
100
!
~
—__-_,j0 SCALE IN
100
FEET
Figure 1
Extent of Surface RIM as
Defined in the Rl
Area 1
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015880
LEGEND
Notes:
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
Approximately 10.6 Acres
(from Figure 6-5 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
x 2015 Topography and Backround Image Provided by
Cooper Aerial Surveys Co.- Dated February 10, 2015
x All Elevations are Above Mean Sea Level (amsl)
150
!
~
0
—..-..1 SCALE IN
150
FEET
Figure 2
Extent of Surface RIM as
Defined in the Rl
Area 2
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015881
M:\CUENlS\ENSI\ WESTIAKE\2015\RUBBLE -INVESTIGATION\RUBBLE -PAUL -BUILDUP.DWG-AREA 1-FIG3 01/04/2016 4:11PM
LEGEND
– – – – – – Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
(from Figure 6-3 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Notes:
Overland Gamma Reading,
Background or Less
Overland Gamma Reading,
2x Background or Less
Overland Gamma Reading,
More Than 2x Background
x 2015 Topography And Backround Image Provided By
Cooper aerial Surveys Co. – Dated February 10, 2015
x all Elevations Are Above Mean Sea Level (amsl)
100
!
~
0
—..-..1 SCALE IN FEET
100
Figure 3
Extent of Surface RIM and Overland
Gamma Results from the Rl
Area 1
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015882
LEGEND
Notes:
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
Approximately 10.6 Acres
(from Figure 6-5 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Potential Additional Areas Where Surface
Radionuclide Impacted Material May be Present
Approximately .74 Acres
Overland Gamma Reading,
Background or Less
Overland Gamma Reading,
2x Background or Less
Overland Gamma Reading,
More Than 2x Background
x 2015 Topography and Backround Image Provided by
Cooper Aerial Surveys Co.- Dated February 10, 2015
x All Elevations are Above Mean Sea Level (amsl)
150
!
~
0
—.-..1 SCALE IN FEET
150
Figure 4
Extent of Surface RIM and Overland
Gamma Results from the Rl
Area 2
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015883
N:\CUENTS\ENSI\ WESTIAKE\2015\RUBBLE -INVESTIGATION\RUBBLE -PAUL -BUILDUP.DWG-AREA 1 FIGS 01/04/2016 4:12PM
Notes:
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
Approximately 1.4 Acres
(from Figure 6-3 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000 )
Potential Extent of Existing Asphalt Cover
Existing Rock Cover Around Septic Tank
Area Where Inert Fill Exists
Newly Constructed Road
x 2015 Topography And Backround Image Provided By
Cooper aerial Surveys Co. – Dated February 10, 2015
x all Elevations Are Above Mean Sea Level (amsl)
120
!
~ 0 120 —– SCALE IN FEET
Figure 5
Extent of Surface RIM and Areas of
Existing Cover
Area 1
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015884
LEGEND
Notes:
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
Approximately 10.6 Acres
(from Figure 6-5 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Potential Additional Areas Where Surface
Radionuclide Impacted Material May be Present
Approximately .74 Acres
Approximate Limit of Rock Buttress
(See Attachment A for Additional Details)
Area Where Inert Fill Exists
Areas Outside Inert Fill
Where Slope Exceeds 5:1
Newly Constructed Road
x 2015 Topography and Backround Image Provided by
Cooper Aerial Surveys Co.- Dated February 10, 2015
x All Elevations are Above Mean Sea Level (amsl)
150
!
~
0
—.-..1 SCALE IN FEET
150
Figure 6
Extent of Surface RIM and Areas of
Existing Cover
Area 2
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015885
M:\CUENlS\EMSI\ WESTIAKE\2015\RUBBLE -INVESTIGATION\RUBBLE -PAUL -BUILDUP.DWG-AREA 1 FIG7 01/04/2016 4:12PM
LEGEND
Notes:
Proposed Extent of New Non-Combustible Cover
d $SS…R[ l..ffi’I.IID\ L 1 L 91 ~ ~ L $R..Hv’=
Proposed Extent of New Non-Combustible Cover
91 !! L RII\H/11- d $SS…R[ l..ffi’I.IID\ L 1 L 91 ~ ~ L
Potential Extent of Existing Asphalt Cover
Existing Rock Cover Around Septic Tank
Newly Constructed Road
d $SS…R[ LFI)I’H)\ L 1 L ~ ~ L $R..Hv’
Within Proposed Extent of New
Non-Combustible Cover)
x 2015 Topography And Backround Image Provided By
Cooper aerial Surveys Co. – Dated February 10, 2015
x all Elevations Are Above Mean Sea Level (amsl)
100
NON-COMBUSTIBLE COVER PROFILE
—–0 SCALE IN FEET
100
8 Inches (nominal) of Rock
10 oz/sy Non-Woven Geotextile
and Chipped Vegetation (if present)
Figure 7
Preliminary Extent of
Non-Combustible Cover- Area 1
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015886
LEGEND
Notes:
Proposed Extent of New Non-Combustible Cover
cJ $S’3_R[ l..ffi’\1-0\ L 1 L ~ ~ 4 ~ L $R…HJ=
Proposed Extent of New Non-Combustible Cover
91 !! L RII\H/11- L d $S’3R[ LFI)I’H)\ L v v 1 ~ T
Limit of Rock Buttress (See Attachment A for
Additional Details)
Area Where Inert Fill Exists
Areas Outside Inert Fill
Where Slope Exceeds 5:1
Newly Constructed Road
cJ $S’3R [ LFI)I’H)\ L 1 L ~ 4 L $R..Hv’
Within Proposed Extent of New
Non-Combustible Cover)
x 2015 Topography and Backround Image Provided by
Cooper Aerial Surveys Co.- Dated February 10, 2015
x All Elevations are Above Mean Sea Level (amsl)
NON-COMBUSTIBLE COVER PROFILE
8 Inches (nominal) of Rock
10 oz/sy Non-Woven Geotextile
w~~~?:!:~~i’R~~~~~Vi~~m;bi;w~~~~;:;;;:;;;~;– and Chipped Vegetation (if present)
120 0 —– SCALE IN FEET
120
Figure 8
Preliminary Extent of
Non-Combustible Cover -Area 2
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015887
0
N i :;.0::, ;
Q)
3:
/
Vi
::::;;
w
Source: Cooper Aerial Surveys Company (2014)
Legend
Environmental Monitoring Station
Meteorological Station
§ 0 600
.~ ~— I 3- EMSI
Figure 9
Air Quality Monitoring Station
Locations
West Lake Landfill OU-1
Engineering Management Support, Inc.
SCALE IN FEET
~L——————————————-~——————————————–~
WLLFOIA4312- 001 – 0015888
M:\clients\EMSI\westlake\2015\Rubble-lnvestigation \NCC-Org Chart.dwg plotted: 12/23/2015
I
Health Physics, Health & Safety,
Air Monitoring
Michael Bollenbacher, CHP, REA
Auxier & Associates, Inc.
Site Health Physicist
Alex Luna
Auxier & Associates, Inc.
I
Laboratory Analysis
US EPA Region 7
Project Manager
Tom Mahler
Project Coordinator
Paul Rosasco, P.E.
Engineering Management
Support, Inc.
Engineering
Dan Feezor P.E.
Feezor Engineering, Inc.
Field Engineer
Jonathan Wilkinson P.E.
Cover Construction
Contractor
TBD
I
Surveying
Weaver Consultants Group
Figure 10
Project Team
West Lake Landfill Superfund Site
EMS I Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015889
Attachments
WLLFOIA4312- 001 – 0015890
Attachment 1
Area 2 Sloped Rock Fill – Plan and Profile View
WLLFOIA4312- 001 – 0015891
500
490
480
470
460
450
440
430
420
-0+50 0+00
Profile View of A- A’
y
1+00
Station
0 50 100 –=::1-=::illc:J.:::=J Feet
_,_
500
490
480
470
460
450
440
430
420
——
-0+50
2+00
0+00
c::
,J
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
00
90
80
70
60
50
40
30
20
2+50
490
480
470
460
450
440
430
420
-0+50
Profile View of D – D’
1+00
Station
y
0+00
—-
2+00
/
Profile View of B – B’
-cv::
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
00
90
80
70
60
50
40
30
20
2+50
/
/
~
1+00
Station
/
/
/
500
490
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470
460
450
440
430
420
-0+50
/
/
/
2+00
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
90
80
70
60
50
40
30
20
2+50
490
480
470
460
450
440
430
420
-0+50
Profile View of E – E’
0+00
o~=::~-=:”:i’-=::::.d’ooo – Feet
7
1+00
Station
Profile View of C – C’
0+00
2+00
-cv::
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
00
90
80
70
60
50
40
30
20
2+50
BRIDGETON LANDFILL
13570 ST. CHARLES ROCK ROAD
BRIDGETON, MISSOURI 63044
0
1+00
Station
v
BRIDGETON LANDFILL
AREA 2 SLOPED ROCK FILL
AREA 2 SLOPED ROCK FILL
2+00
Thickness Map
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
90
80
70
60
50
40
30
20
2+50
Range Minimum Depth Maximum Depth Color
1 0 2 • 2 2 4 • 3 4 6 • 4 6 8 • 5 8 10 • 6 10 12 • 7 12 14 •
FILL VOLUME: 8,639 CY
LEGEND
BASE TOPOGRAPHY (2′ CONTOUR)
–•500 BASE TOPOGRAPHY (10′ CONTOUR)
COMPARISON GRADING (2′ CONTOUR)
–•500 COMPARISON GRADING (10′ CONTOUR)
001
PLAN AND PROFILE VI~EW====~==~~~~5
WLLFOIA4312- 001 -0015892
Attachment 2
Inspection and Maintenance Plan
WLLFOIA4312- 001 – 0015893
Attachmen

Post

2016-02-18 – EPA – West Lake Landfill – EMSI – Regarding work plan for cover installation

To:
From:
Sent:
Subject:
Washburn, Ben[[email protected]]
Barker, Justin
Thur 2/18/2016 5:18:14 PM
FW: Revised Work Plan for Non-Combustible Cover
From: Mahler, Tom
Sent: Wednesday, February 17, 2016 11: 11 PM
To: Barker, Justin ; Gieseke, Andrew
Subject: FW: Revised Work Plan for Non-Combustible Cover
Greene’
Subject: Revised Work Plan for Non-Combustible Cover
Juett,
Dan
‘Cecilia
WLLFOIA4312 – 001 – 0016276
Tom,
Attached is a revised Work Plan for the Removal Action- Non-Combustible Cover project. The
work plan has been revised to address EPA’ s comments provided on January 29, 2016 on the
prior (January 4, 2016) submittal. Also attached is a revised Health and Safety Plan that has
been modified to address EPA’ s comments. Because EPA did not have any comments on the
Sampling and Analysis Plan, Radiation Safety Plan, or the Quality Management Plan, I have not
included those documents with this submittal as the versions that were previously provided to
EPA on January 4, 2016 remain unchanged.
We received your e-mail this morning providing conditional approval of the work plan based on
the responses to the four comments identified in EPA’ s January 29, 2016 that we submitted to
you on February 9, 2016. EPA’s conditional approval included additional comments, in
particular a comment related to ARARs, that your e-mail indicated should be addressed in the
next submittal of the work plan. Unfortunately, we had already obtained client approval and
were in the process of preparing the final version of the work plan that is attached to this e-mail
before we received your e-mail. Due to the short time available today and the fact that it is
Friday at the start of a long holiday weekend, we could not address the additional comment
related to ARARs in this submittal. I will contact you next week to discuss how to proceed
relative to the ARARs comment.
Thank-you and have a great weekend.
WLLFOIA4312 – 001 – 0016277
WLLFOIA4312 – 001 – 0016278

Post

2016-02-18 – EPA – AAA Trailer Services Investigation

To: pau [email protected][pau I [email protected]]
Cc: Vann, Bradley[[email protected]]; Juett, Lynn[[email protected]]; Barker,
Justin[[email protected]]; Gieseke, Andrew[[email protected]]
From: Mahler, Tom
Sent: Thur 2/18/2016 9:25:17 PM
Subject: AAA Trailer Investigation
Hey Paul,
I just wanted to send you a summary of what we just discussed. MDNR and I met with John
O’Brien from AAA Trailer Services today. While there, MDNR provided John a summary table
of the analytical data from their November 2015 vicinity sampling event. I then explained that
EPA had an interest in further investigation occurring on the uncovered soil areas of AAA
Trailer services between their gravel parking lot and the West Lake Landfill Fence. I told him
that this investigation would involve conducting telemeterized gamma scanning and
confirmation surface soil sampling. I told him that the West Lake Responsible Parties’
Representative would be contacting him soon to obtain permission to have access to the property
to perform this investigation. I also mentioned you would likely send a form that would need to
be signed for this access. I told John he would be contacted at a minimum by the end of next
work week (February 26th)but likely sooner. He is ready and waiting to be contacted.
John also mentioned that he would prefer if possible for the investigation to occur on the
weekend when there would be less impacts to their day to day business. John said that he could
provide access to whatever parts of the property need investigation over the weekend.
Let me know if there are any questions,
Tom Mahler
On-Scene Coordinator
US EPA Region 7
816-604-0546
WLLFOIA4312 – 001 – 0015853

Post

2015-03-09 – USACE – Transmittal Letter Comments IB Alternatives Analysis Report Oct 10 2014

DEPARTMENT OF THE ARMY
CORPS OF ENGINEERS, KANSAS CITY DISTRICT
635 FEDERAL BUILDING
601 E 12TH STREET
KANSAS CITY MO 64106-2824
Printed on Recycled Paper
March 9, 2015
Mr. Brad Vann, Remedial Project Manager
U.S. Environmental Protection Agency Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Vann:
The U.S. Army Corps of Engineers (USACE) has completed a review of the “Isolation Barrier Alternatives Analysis – West Lake Landfill Superfund Site” Report dated October 10, 2014 and prepared by Feezor Engineering of Bridgeton, Missouri, P.J. Carey & Associates of Sugar Hill, Georgia, Auxier & Associates, Inc. of Knoxville, Tennessee, and Engineering Management Support, Inc. of Lakewood, Colorado on behalf of Bridgeton Landfill, LLC. Note that this review was a qualitative analysis as plans and specifications for each alternative was not provided. These comments were originally transmitted to you on November 6, 2014.
USACE comments are as follows:
1) Section 3.4. If no action option is implemented and the SSE moved through the north quarry into Area 1, it is likely that the surface of the north quarry would drop and any leachate collection lines could potentially be severed due to the drop in landfill surface. If that occurred, would leachate spills from severed lines cause a potential increase in odors?
2) Section 3.6. At what depth to surface is there a risk of an SSE igniting a surface fire? If the SSE is able to migrate vertically it seems that there may be a potential for an SSE to ignite surface material.
3) Section 3.6. Last sentence – recommend including a reference to the section of the report where the quantitative evaluation for the No Action Alternative is included.
4) Section 3.6.1. Descriptions of locations of heat generating material are provided in Paragraph 3; however, it is difficult to follow the description. Recommend including a figure to help show/clarify the information trying to be conveyed.
5) Section 3.6.1. Para 5, 4th sentence. Inclusion of boring log cross sections with nearby temperature probe data on a figure would help clarify this information and prevent the reader from having to dig through past reports submitted to EPA and reports submitted to MDNR to confirm the information presented. Additionally, current boring logs from the most recent sampling event where additional RIM was found would be beneficial as well.
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 2
Alternatives Analysis Report
March 9, 2015
6) Section 3.6.1. Last paragraph – overall claim that it is highly unlikely that the SSE could migrate laterally – recommend that all the data cited to support this claim be provided with this report and clearly identified.
7) Section 3.6.1. Para 4, last sentence – Approximately how many other sites indicate no pyrolysis occurs in waste depths of less than 60 feet? Refer to section 4.7, advantages bullet 4, which states alignment 1 offers the lowest potential for a SSE to original on the north side of the barrier because the alignment is located along the northern boundary of the North Quarry area. Recommend consideration that the bullet language be changed to state that it offers the lowest potential for a SSE due to the alignment and the thickness of waste being less than 60 feet.
8) Section 3.6.1, 3rd Paragraph. The 10th line states that materials below the 360 to 380 elevation are undergoing heat loss. Para states that 360 to 380 may be the depth of reactive wastes or may reflect “thermal restraints”. Has the elevation of the groundwater level in this part of the quarry been considered? Is it such that the groundwater level is serving as a “thermal restraint”?
9) Section 3.6.1, 3rd Paragraph. The final sentence in this paragraph states that a similar pattern of heat dissipation is seen as the elevation in the landfill approaches the ground surface. The on-going studies/data that support this assertion and others made within this report should be included in this report as an attachment so the assertions can be easily verified without having to search through multiple reports to find supporting data.
10) Section 3.6.1, 4th Paragraph. This paragraph builds on the assertions of the previous paragraph stating that significant reduction of waste thickness in the north section of the north quarry will increase heat dissipation and expressed doubt that any significant pyrolysis would occur in wastes of such a shallow thickness. The paragraph asserts that this is consistent with observed behaviors of other sites with waste thickness less than 60-feet. Please provide references of the cited landfill SSEs to facilitate review of the referenced performance.
11) Section 3.6.1, Pg 7, 3rd Paragraph. How is the 25 times greater heat dissipation in Area 1 over that of the South Quarry determined?
12) Section 3.6.1, Pg 7, 3rd Paragraph. The statement that “no pyrolysis in waste depths of less than 60-feet should be supported by literature and/or example sites.
13) Section 3.6.1, Pg 8, 1st Paragraph. It would be helpful to provide a figure (cross section) illustrating what is being described in this paragraph.
14) Section 3.6.1, Page 7. Typo in second paragraph “… indicating they these materials…”
15) Section 3.6.2. It would assist in evaluation to provide updated figures defining the perimeter of Area 1. Figure 4-14 from the RI shows the locations where flux sampling was conducted. Locations 105, 107, 110, 120, 121, 122, 123 and 124 appear to be outside of the defined Area 1 boundary and their use in determining average flux activity may bias the actual flux from Area 1 low, though Location 105 does appear to have elevated Ra-226.
16) Section 3.6.2. Is Subpart T (Disposal of Uranium Mill Tailings) the cited NESHAP requirement? St. Louis FUSRAP has evaluated radon releases against the 40 CFR 192.02 (b) alternate criteria of 0.5
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 3
Alternatives Analysis Report
March 9, 2015
pCi/L, which may be also be an appropriate criteria to evaluate if UMTRCA is an ARAR. This would be better criteria to evaluate what exposure there may be to members of the public, if any. Models such as CAP88, AERMOD, or RESRAD-Offsite may be helpful to demonstrate a lack of current exposure, or monitoring data taken downwind from the facility could be discussed.
17) Section 3.6.2. It may be helpful to note here that additional radon generation may also be present in effluent releases from the gas collection system and not solely through radon emanation from the surface as discussed in Section 4.4 of Appendix A.
18) Section 3.6.2. Bullets – there were a total of 7 conclusions in EMSI’s report. 5 of those conclusions appear to relate to potential impacts if an SSE were to occur of the SSE that, at a minimum, should be addressed as part of a no action consideration. This report addresses only 3 of the 5 bullets. Recommend including and addressing bullet 4 from EMSI’s report: “An SSE in West Lake Area 1 or 2 would create no long-term additional risks to people or the environment.” and bullet 5 from EMSI’s report: “Any short-term risks would be associated with the temporary increase in radon gas coming from the surface of the landfill if no cap is installed on the landfill, or if the cap called for by the 2008 ROD was not properly maintained.”
19) Section 3.6.2. Para 4. the Flux calculations in Attachment A are compared with surface radiation measurements from the EMSI RI report in 2000. Recommend including that surface measurements will be taken to confirm calculated concentrations prior to selection of any no-action approach.
20) Section 2.6.2. Para 6. states that “even if these conditions were to occur, the radon emission rate from Area 1 could still be less than the standard….” then in the last sentence of the paragraph states the magnitude of radon emissions would still be less than the establishes standard….” The use of these two words seems contradictory.
21) Section 3.6.2, p 9, 3rd Paragraph. The discussion regarding leachate generation rates is appears inconsistent with the June 2013 Contingency Plan which states, “Heating of waste which results in steam/water vapor front moving out, up, and away from the SSE, which then condenses in the cooler surrounding waste mass and gas extraction well resulting in higher localized leachate generation.” Please clarify.
22) Section 3.7, Pg 12, 4th bullet. This bullet appears redundant. Recommend removing.
23) Section 3.7. A no action alternative would still require additional monitoring to observe whether modeled radon flux corresponds to actual radon flux in the event an SSE migrates to/occurs in Area 1.
24) Attachment 1, section 2.2. The RI states that the 95% UCL of the mean for surface radium is 581 pCi/g. Because shallow/surface material will contribute more to radon flux than subsurface material, it seems like an additional surface layer should be added to the RAECOM model.
25) Attachment 1, section 2.2. Though the reviewer agrees that the average flux calculated over Area 1 is 13 pCi/m^2/s and below the 20 pCi/m^2/s standard, Area 1 seems very heterogeneous, with only 1 measurement the same order of magnitude as 13 (location WL-106 at 22.3) Most flux measurements are well below this, but measurements exist ranging from 0 to as high as 246 pCi/m^2/s. Given that sample data and flux data is available for most locations it may be helpful to run the model for each
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 4
Alternatives Analysis Report
March 9, 2015
location where surface flux and surface/subsurface sample data is available to determine how well the RAECOM model compares to actual site data.
26) Attachment 1, section 2.2. It would be helpful to justify the use of 0.2 as the radon emanation fraction, as the RAECOM online instructions recommend a value between 0.2 – 0.3 and 0.2 is the low end of this value. The RESRAD default value is 0.25, which may be more appropriate.
27) Attachment 1, section 2.2. This analysis seems to imply an SSE is impacting the top 1.7 m of soil. At what point would risk transition from increased radon release from subsurface soil to release from a surface fire? If an SSE encounters material in the top 6′ of soil it seems like ignition of surface material may pose a larger risk than increased radon production. A surface fire could potentially pose greater risk than a SSE (ie. dust kicked up with Th or U).
28) Attachment 1, section 2.2. Is the cited gas temperature increase to 80º C consistent with current observations of the SSE and assumptions used for the design and evaluation of alternatives? Discussion above (Section 6.1) seems to suggest 200ºF (~90º C) is a design consideration?
29) Attachment 1, section 2.2. Area 1 should be better defined on a drawing (similar to Figure 4-14 of the RI) to ensure that “clean” flux measurements are not inadvertently included, see comment #16
30) Attachment 1, section 4.5. Though a comparison to 10 CFR 20 may be helpful in the absence of other regulatory criteria, it should be noted that 10 CFR 20 effluent releases generally apply only to releases from an NRC licensee and may not be applicable at a CERCLA site. The effluent concentrations listed in Table 2 correspond to a public total dose of 50 millirem/year, which is above those generally allowed by EPA at CERCLA Sites. Recommend you don’t compare to 10 CFR 20 since EHA has a more stringent standard.
31) Attachment 1, section 4.5. Suggest removal of the last paragraph of Section 4.5 as the release of radon into the air from stack release is not directly comparable to radon present in soil gas.
32) Attachment 1, section 4.5. 10 CFR 20 Appendix B Table 2 contains two values for radon, one for radon in 100% equilibrium and one for radon without daughters. Suggest a clarification that radon effluent releases are being compared to the 0.1 pCi/L criteria that assumes all daughters are present in equilibrium, or provide a discussion of measured/assumed equilibrium factor.
33) Section 4.0. The analyses of Options 1 and 3 generally agree with the analyses completed by USACE and provided to the EPA in the “Isolation Barrier Alignment Alternatives Assessment” dated 25 August 2014.
34) Sections 4.0 and 6.0. The eastern limits of the Option 1 & 3 alignments shown on Drawing 002 appear to violate the location of the North Quarry wall shown on Figure 2 of Part I of the Bridgeton Landfill Contingency Plan. Please verify that the proposed alignment does not violate the quarry wall and indeed meets the assumed 45-degree offset.
35) Sections 4.2 and 6.2. The excavation volumes are based on a 60-foot wide working platform which will be wide enough to accommodate the slurry trench excavating machinery and tooling. But the typical section of the slurry trench cutoff wall shown in Dwg 16 locates the wall at the center of the 60-foot wide platform. The plan view of Alignment 1 with the Waste Cut areas shown on Dwg 003
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 5
Alternatives Analysis Report
March 9, 2015
clearly shows the alignment assumed to be at the centerline of the work platform. But to accommodate the excavating machinery, the excavated trench will need to be much nearer one of the edges of the work platform. Given that the alignment is fixed based on occurrence and non-occurrence of RIM in the foundations, and the alignment must be near the edge of the working platform, the excavation plan must be shifted laterally up to 20-feet. Similar issue with Alignment 3.
36) Section 4.2, Pg 13, 1st Paragraph. A construction platform of 45-ft was originally discussed. A comment was made on the Pre-construction work plan, section 2.1 that asked you to ensure that the proposed 45-ft wide excavation is enough to allow access for support vehicles. Is the additional 15 feet required for support vehicles? If so, please clarify what this width accommodates and how the equipment will be configured such that 60′ is required.
37) Section 4.2, Pg 13, 1st Paragraph. Based on a review of the cross sections and a comparison to Option 3 (where there is substantial change of elevation along the length of the wall), it appears that a working platform could be constructed for Option 1 with much lower pre-excavation volumes. This would result in a slightly deeper wall but may be a good tradeoff due to odor and bird mitigation issues.
38) Section 4.2, Page 14, top Paragraph. This indicates the barrier volume is 5,000 bcy, however sheet 003 indicates the barrier volume is 7,500 bcy.
39) Sections 4.3 and 6.3. The 10th line states that trench construction “using slurry would require slurry decanting/liquid”. Slurry trench construction requires large volumes of slurry (typically soil-bentonite slurry) to provide trench wall support during trench excavation. When completed this slurry is typically processed to remove as much of the soil solids that are suspended in order to reduce the volume of slurry liquids that must be properly disposed of. A 10-foot wide, 3-foot thick, and 40-foot deep panel will need 1,200 cu-ft (8,970 gallons) of slurry. In this case, if a particular trench panel encounters RIM during its excavation, how will the slurry be disposed of? How you intend to address the slurry should be included in Section 4.1 or 4.2 (and 6.1 or 6.2) as it is waste that will be required to be disposed.
40) Sections 4.3 and 6.3. USACE has studied the 3-dimensional global stability of earthen levees assuming discrete panels excavated near the levee toe. This analysis is completed using FLAC-3D. Depending on the geotechnical parameters of the various fills/wastes encountered in the trench and remaining in the adjacent excavated slopes, longer panels may be safely used thereby shortening the construction times. To complete this analysis, detailed geotechnical exploration incorporating in-situ measurements of shear modulus with pressure meter must be completed. Recognize that this is a design issue to be addressed later; however, it can impact the quoted schedule.
41) Section 4.3, Pg 14, 1st Paragraph. Recommend changing “reaction” to “SSE”.
42) Section 4.3, Pg 14, 1st Paragraph. Recommend expanding on the limitation associated with storm water management.
43) Section 4.3, Pg 14, 1st Paragraph. The design timeframe (103 wks) has increased substantially over what had been previously discussed. Based on a review of the schedule there appears that there are places where durations could be reduced. For example, investigations could begin prior to completion of the heat extraction study.
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 6
Alternatives Analysis Report
March 9, 2015
44) Section 4.3. Last Paragraph. EPA will have to make determination on requirement regarding the need to test waste above the 1975 topographic surface. This is a landfill and although there may not be RIM above the 1975 topographic surface, there may be other constituents of concern and testing may be warranted.
45) Section 4.6. Recommend that laboratory data and boring logs from last sampling event be provided along with an updated dwg of currently know extent of contamination and information regarding vertical distribution of contamination if the information is to be relied upon for this report to back up a no action response. Recommend including a dwg showing estimated 1975 topographic surface and 1975 aerial photographs upon which this estimated surface is based. Would need to include that information that is being relied upon in this report to support the no action option.
46) Section 4.6. Para 2 – recommend the specific section in Attachment A that contains the info being referenced in this text be added within the parentheses so it is easy for reader to locate the information.
47) Section 4.7, Pg 17, 6th bullet. Although there is a caveat later in the document regarding acceptability of leaving excavated RIM waste on-site, that is far from certain so recommend not listing it as an advantage.
48) Section 4.7. It would be helpful in evaluating alternatives if an estimate of the potential amount of RIM to be excavated was discussed.
49) Section 4.7. The extent of RIM has not yet been determined. Recommend author considers qualifying the language in the first paragraph by indicating that the statements are based upon data collected to date and that the extent of RIM has not yet been determined.
50) Section 4.7. Report states, “Radon emissions from the RIM material located outside of the barrier would not result in an exceedance of the Radon NESHAP.” Because the extent of RIM has not yet been identified and because of the heterogeneity of the waste placement, recommend that this text be revised to allow for this consideration.
51) Section 4.7. Disadvantages – can non-rad waste removed as a result of barrier installation be placed back in the landfill? If this has not yet been determined, then it is recommended that it be captured as a disadvantage because there is a possibility that it would not be approved. If not approved, it would significantly impact the construction duration.
52) Attachment B, para 1.1.2. Another opportunity to provide clarity to the design would be to assume that the “maintenance” of the wall would include re-adjustment of the top of fill elevation on the “hot-side” of the wall. As the pyrolysis induced settlement (accelerated settlement due to consumption of waste materials due to SSE) occurs, the ground surface on the “hot side” of the wall could be raised to limit the difference in ground surface between the “hot side” and “cold side” of the wall. Use of careful compaction techniques (from just spreading fill to fully compacting the fill) could keep the in-place unit weight of the fill to within acceptable levels to equalize the geostatic horizontal stress placed on both sides of the wall.
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 7
Alternatives Analysis Report
March 9, 2015
53) Attachment B, para 1.1.2. The first paragraph states that it has been determined that anchoring the NCE into the alluvium/bedrock is not feasible. Dwg 004 shows the Option 1 NCE proposed to extend down to elevations 420 to 430. Cross section AA in Figure 2 of Part I of the Bridgeton Landfill Contingency Plan shows bottom of wastes or top of bedrock at/around elevation 425 under OU-1 Area 1. It seems that the top of rock may be quite close and if so, anchoring the NCE into the bedrock may not be as infeasible as first thought. Use of hydro mill technology to key into the bedrock is a common technique. Keying into bedrock will provide clarity on the fixity of the bottom of the NCE.
54) Attachment B, para 1.1.2. Perhaps the responsible party should consider a limited application of the heat extraction technology installed on the “hot-side” of the wall. If successful, it could limit the temperature applied to the concrete surface and thereby limit the heat induced stresses/strains.
55) Attachment B, para 1.1.3. See comment #42 concerning 3 dimensional slope stability using FLAC-3D.
56) Attachment B, para 1.1.3. A monitoring system will also include surveys of the ground surface adjacent to both sides of the wall. Also, replaceable temperature gages should be installed in the wall interior. Given the proposed life span of the wall, the temperature gages would have to be accessible for maintenance and replacement as necessary. Also some kind of telltale extending to the base of the wall to determine its elevation (if not embedded into bedrock) should be considered. It is recognize this is a design consideration and would be addressed during design.
57) Section 6.2, Pg 22, 1st Paragraph. Recommend explaining why a barrier width of 5.0-ft was assumed versus the 3.0-ft width of Option 1. It is assumed this is for structural considerations due to the greater depth of the wall.
58) Section 6.2, Pg 22, 1st Paragraph. Sheet 010 indicates a barrier volume of 7,500 bcy for Option 3 as opposed to the 11,000 bcy sited here in the text.
59) Section 6.7, Pg 25, 2nd bullet. Recommend not listing the potential to leave excavated RIM waste on-site as an advantage.
60) Section 6.7. The extent of RIM has not yet been determined. Recommend author considers qualifying the language in the first paragraph by indicating that the statements are based upon data collected to date and that the extent of RIM has not yet been determined.
61) Section 7. It is stated that for Option 4, the heat extraction points would be installed such that depths of the extraction points would be relatively shallow. Does this shallow installation still include installation down to the bedrock as indicated in drawing sheet 16?
62) Section 7.1. It is stated for Option 4, that the cooler would consist of an adiabatic air cooler installed with a closed loop liquid circulation system. While Attachment C., Heat Extraction Barrier Design Memorandum, describes a close circuit cooling tower. Please verify that a close circuit cooling tower is the current design concept.
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 8
Alternatives Analysis Report
March 9, 2015
63) Section 7.1. The limiting criteria for any barrier system would be to maintain the waste on the north side of the barrier at an average temperature of 175 degrees Fahrenheit. What is the best guess for the entering and leaving temperatures of the cooling liquid at this time?
64) Section 7.1. The heat extraction points would be driven in place vs. drilling a well. What is the typical depth that the pipe can be driven into place? What is the depth of the bedrock at the proposed locations? What is the possibility of success with this method of installation?
65) Section 7.6. Para 2. Potential RIM outside the barrier is not expected to pose a significant risk (see attachment A) and RIM outside barrier would not result in exceedance of Radon NESHAP. Recommend the specific section in Attachment A in which the information that supports this can be found is cited in the parentheses.
66) Section 7.7. It is stated for Option 4, that “The RIM material that would remain outside of the barrier wall is currently covered by 25 to 50 of solid waste and a landfill cover that prevents direct contact with the RIM and provides shielding from gamma radiation.” Recommend units of measurement be inserted (ie. “…25 to 50 ‘feet’ of solid waste…”).
67) Section 7.7. It is stated for Option 4, that “Installation of heat extraction points is a common technology used for geothermal energy development and therefore this alternative is technically feasible.” However, it comes down to the numbers. How do the proposed conceptual design conditions compare to the design conditions for a typical system that comprises this common technology? Do geothermal systems exist that have design conditions that are in the same neighborhood of the conditions that will exist within the SSE?
68) Attachment C, Section 1.1. It is stated that “The primary data parameters recorded…” from the single well, GIW-4, “…were the inflow and outflow water temperatures, flow rate and the temperature within the casing as measured by thermocouples at multiple depths. Where is that data, specifically the water flow rates and the entering and leaving water temperatures? Recommend that data be included in the report to as an attachment to support the claim of feasibility.
69) Attachment C, Section 1.3. It is stated that “Estimates of the maximum heat flux in the south quarry have been in the range of 14 Watts/sqm, as of July 2013.” This rate is very low. This rate is slightly less than 5 Btuh/sqft, which, as a comparison, would not fully heat a typical building to typical occupied conditions in the warmest areas of this country. Over what area is this rate determined? What is the total heat to be rejected by the system?
70) Attachment C, Section 2.2. It is stated that the vertical heat extraction elements be comprised of corrosion resistant metal (low carbon stainless steel) or nonmetallic materials. Metallic materials underground may required cathodic protection while temperature limitations maybe an issue for nonmetallic materials. It is recognized that this is a design issue that will need to be considered during design.
71) Attachment C, Section 2.3. Please confirm that the proposed design delta temperatures for a cooling tower powered system are 175 degrees F minus 85 degrees F or 90 degrees F.
72) Attachment C, Section 2.3. Please confirm that the proposed design delta temperatures for a chiller powered system are 175 degrees F minus 40 degrees F or 135 degrees F.
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 9
Alternatives Analysis Report
March 9, 2015
73) Attachment C, Section 2.3. It is stated that “These systems will be above ground HDPE pipe with flex connections to the extraction points.” Typically, we only see HDPE pipe installed below grade due to issues with UV. How will this be addressed? It is recognized that this is a design issue that will need to be considered during design.
74) Attachment C – General. The issue with utilizing typical HVAC machines in this situation is that the equipment pretty much does what it was designed to do, which is not a delta temperature of 90 to 135 degrees F. Specifically, vapor compression chillers typically will not produce a delta temperature above 20 degrees F and will shut down on a safety if entering water temperatures become too extreme. With a flowing fluid, do you intend to use equipment in series to achieve the necessary temperature differential? Do you know of a specific chiller that is capable of these high temperature drops?
75) Attachment C, Pg 3, 2nd Bullet. Why was a point of compliance of 15-ft north of the cooling elements selected for Option 4?
76) Drawing 16. The Option 1 and 3 Typical Inert Barrier shows the barrier centerline located in the center of the flat work area. To accommodate the heavy excavation machinery and tooling, the Inert Barrier must be located approximately 45 to 50 feet away from either edge. USACE studies of slope stability show that better global stability factors of safety are obtained when the heavy excavation machinery and tooling is located on the side of the trench opposite the taller excavated slope.
77) All Drawings. All drawings show historical boundaries. Recommend these drawings be updated to reflect current contaminant boundaries with a dashed line where the extent of contamination has not been determined.
78) Drawings 002 and 009. The eastern limits of the Option 1 and Option 2 alignments shown on Drawings 002 and 009 appears to violate the location of the North Quarry wall shown on Figure 2 of Part I of the Bridgeton Landfill Contingency Plan. Please verify that the proposed alignments do not violate the quarry wall and indeed meets the assumed 45-degree offset.
79) Drawings 003 and 010. Each of these drawings include values of pre-excavation and barrier excavation volume. Recommend also showing the overall volume needing to be relocated.
80) Sections 3.5, 3.6, 3.7, 4.5, 4.6, 4.7, 5.0, 6.5, 6.6, 6.7, 7.4, 7.5, 7.6, 7.7, and Attachment D. There is still no Bird Monitoring and Control Plan to review. The sections reviewed considered the concerns of the St Louis Airport Authority and consistently assessed the concerns of quantity of waste and duration of exposure and the impacts those two things have on Bird Airstrike concerns. A new Alternative, Heat Extraction Barrier, was introduced that has less bird airstrike implications than the other options. There was not much emphasis placed either on covering excavated waste or in handling and transport of waste for installation of the isolation barrier. This should be covered in the forthcoming Bird Monitoring and Control Plan.
USACE Comments – Bridgeton Landfill Thermal Isolation Barrier 10
Alternatives Analysis Report
March 9, 2015
USACE is available to participate in a comment resolution meeting upon request.
Respectfully,
Robyn V. Kiefer
Project Manager
CC: Scott Young-CENWK-PM-E
Jason Leibbert-CENWK-ED-E

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