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



U.S. Army Corps of
Amendment 1
Environmental Protection Agency Region 7
Superfund Program
DATE: 20 November 2015
WLLFOIA4312- 001 – 0055680
Table of Contents
Isolation Barrier Alignment Alternatives Assessment
West Lake Landfill, Bridgeton, Missouri
Section Page
Introduction …………………………………….••………………………… 2
Background ………………………………….••••••………………………… 3
RIM Isolation Alternatives ……………..•••••••…………………………… 3
Concrete Isolation Barrier Wall ……… ,. •••…. v •••••••••••••••••••••••••••••••••• 4
Excavation to Create an Air Gap .. “‘ ……………. ,~ • .; ••…………………….. 5
Heat Extraction Barrier ………•.••••………………. ~,~”””•~•.• ……………….. 6
IB Alternatives Assessment ……………………………. · .. ,'””” …………… 7
Assessment Factors ……………….. , ……………………… · ………………. 7
IB Alternatives -Advantages and Duadvantages ………….. ·····~· …….. 7
Relative Comparison of Alternatives by Assessment Factor …………… 10
Structural IB Alignment 1 Advantages Dis~ussion …………………….. 10
Structural IB Alignmentl Disadvantages Diseus~ion ………………….. 11
Structural IBAlignment 2 Advantages Discussion …………………….. 12
StructurafiB Alignment 2 rii:sa.dvantsrges Discussion …………………. 12
Structn:tal IB Alignment 3 Advantages Discussion ……………………… 14
Structural IB Alignment 3 Disadvantages Discussion ………………….. 14
Heat.Extraction IB Advantages Discussion …………………………….. 19
Heal Extraction IB Disadvantages Discussion …………………………. 19
Design Considerations …………………………………………………… 20

Design Schedule Consider.ations …………………………………………. 22
Airport Negative EasementAgreement …………………………………. 24
Table 1 Relative Comparison of Alignment Alternatives …………………… ll
Table 2 Options to Address Remaining RIM ………………………………… 21
References ………………………………………………………………………… 25
WLLFOIA4312- 001 – 0055681
1. Introduction
Isolation Barrier Alignment Alternatives Assessment
West Lake Landfill, Bridgeton, Missouri
In 2014, the U.S. Environmental Protection Agency (EPA) requested the United States Army
Corps ofEngineers (USACE) evaluate information conveyed by the Responsible Parties (RPs)
during discussions between US ACE, the RPs, EPA Superfund nersonnel (EPA), and EPA’s
Office ofResearch and Development (ORD) regarding proposedJocations and alignments of an
Isolation Barrier (IB) at West Lake Landfill in Bridgeton, Missouri. The purpose for
constructing an IB is to prevent a subsurface smoldering event (SSE) in the adjacent Bridgeton
Sanitary Landfill from coming into contact with radiologically rmpacted materials (RIM) located
in Operable Unit 1 (OU1) Area 1 of the West Lake Landfill. In August, 2014, USACE
submitted an Isolation Barrier Alignment Alterriatives Assessment Report. The 2014
assessment focused on the proposed alignments,the feasibility of constructing the IB, the
comparative advantages and disadvantages of the proposed alignments, anCI the associated risks.
One of the key findings from the repprl was that the extent of radiological material in the West
Lake Landfill was not fully characterized which was necessru:y to be able to quantify risks
associated with RIM remaining south of any battier. and inform EPA’s decision on alignment.
During spring and summer of2015, the RPs perforllfed additionalinvestigations to determine the
extent of RIM. In ad~iti()11, ~ver the last year,the RP~shave been performing a thermal barrier
pilot study in which 1iqqid is circulated through.converted Gas Interceptor Wells ( GIW) south of
the neck area (narrow section betWeen south and north quarry landfills) to determine if this could
remove sufficient heat from the waste to halt advancement of the SSE.
This 2015 a:Ssessment amends the 2.014 assessment to take into consideration results of the
additional RIM investig~tiadvantages and disadvantages by
assessment factor.
WLLFOIA4312- 001 – 0055690
Odor Potential
Bird Hazard
South of

Potential for
Future SSE
North of
On-Site Safety
Table 1: Relative Comparison of Alignment Alternatives
Alignment 1
Least volume than
Least odor
potential due to the
lowest volume of
waste handling
Least bird hazard
potential due to the
lowest volume of
waste handling
Mostrunount of
RIM to remain
south ofiB
… ~o~pared to the
other :aligmneilts
Anticipated to have
the lowest potential
for future SSEon
, the north side ofm
Largest volume to be
excavated due to
excavation for working
platformand 180-foot
depth in North Quarry,
and increased thickness
of wall to resist
increased loads
Highest odor potential
than both Alignment 1
and 3 due to highest
volume of waste
handling. Wouldbe
similar to active landfill
operations. ….. .
Highest bird hazard·
potenti;1l than both ……. .
Alignment} and 3 due ···
to lii~est v:oiume of
expos.ed waste. Would
be similar to active
landfill operations.
.. ·····
None -assum.es that no
RIM material wa:s
placed in the North
Qiuu:ry .landfill
Anticipated to be the
higbestpotential for a
future SSE on the north
side of the IB due to
highest volume of
newer, less degraded
waste remaining north
due to waste being
oldet and likely
more fully
degracted: .> of the lB.
Potentially greater
on-site safety risk
than Alternative 3
due to known RIM
being excavated.
Greatest on-site safety
risk compared to
Alignment 1 and 3 due
to the significantly
higher volume of waste
excavated and handled.
Lowest on-site safety
risk due to RIM.
Approximately twice as
much as Aligmnent 1
~95,000 CY ±.,.
significantly less than
Higher odor potential than
Alignment 1 due to higher
volume ofwaste handling
Htgner bird hazard
pQ’tential than Aligmnent ··
1 due to higher volume of
waste handling
Least amount of RIM
would remain south ofiB
compared to Aligmnent 1
and potentially no RIM
would remain .
Anticipated to be higher
potential than Aligmnent
1for a future SSE on north
side of the IB due to
newer, less degraded
waste remaining north of
the IB but less than
Alignment 2 due to less
volume of newer waste
remaining north of the IB
Lower on-site safety risk
than Aligmnent 1 if little
or no RIM excavated but
higher general safety risk
than Aligmnent 1. Higher
on-site safety risk than
Aligmnent 2 if RIM is
Least amount of
excavated volume of all
alternatives. System
requires wells and near
surface coolant loop
Least odor potential of all
options. Least amount of
waste to be removed
during well and cooling
loop installation.
Minimal bird hazard
potential due to limited
waste handling.
No RIM anticipated to be
located south of the
thermal lB.
Anticipated to have the
highest potential for a
future SSE north of the
lB. Can be offset by
flexibility and ease of
system expansion.
Lowest on-site safety risk
due to no open excavation
and no limited RIM
WLLFOIA4312- 001 – 0055691
Criteria Alignment 1 Alignment2 Alignment3 ThermaliB
Off-Site Safety Potentially higher Highest off-site safety Lower off-site safety risk Lowest off-site safety risk
off-site safety risk risk due to the than Aligmnent 1 if no due to limited dust from
than Alignment 3 significantly higher RIM (dust generation). well installation and
during installation volume of waste being Higher off-site safety risk surface line excavation.
due to RIM excavated requiring off- than Alignment 1 due to Lowest risk for RIM
excavation (dust site transportation, off-site transportation exposure.
generation) and which increases truck (traffic accidents)
off-site traffic and risk for
transportation of traffic accidents.
RIM (traffic
Off-Site Waste RIM waste Largest volume of off- Off-tsitedisposal No offsite waste transport
Transportation excavated as part site disposal of non- potentially not required if anticipated.
and Disposal of wall installation RIM waste will be ~1 RIM is located north
will require off-site required due to limited .· ofaligmnent
disposal. on-site waste dispo:sal
Duration of Shortest design Longest design i.l. ··u•· ration Longer design dl.lration Shortest design duration
Design duration due to due to more than 180- than Alignment 1 due to due to well design
shortest wall and foot depth requiring longer duration of pre._ completed. Requires
shorter pre-design pre-design investig~tion des~gn investigations and surface equipment and
investigations an.d. highly complex more complex wall design coolant design
de&J:gn (:lue to increased depth preparation.
Duration of Shortest Loirgest construction ~onger construction Shortest duration of
Construction construction duration than both driration than Alignment construction. No
duration due to Alignment 1 and 3due 1 due to 30 to 40-foot excavation, just well
shortest wall to 180-foot depth, increased~epth of wall installation and cooling
significantly }Vider w:all loop installation.
to handle increase
loading ·.
Impact to No impaetto Greatest impacts to the Moderate impacts to the No impact to existing
Existing existing North Quarry North Quarry infrastructure on North
Infrastrucwre infi:astn,1cture on Inffastrt,u::.ture used to Infrastructure used to Quarry and no impact to
North Quarry brit balance lanilfill·gas balance landfill gas operation of the transfer
may impact extraction and extraction and station.
operation of the control/monitor the control/monitor the SSE
transfer station, SSR
which could result
” in delayed or
reduced trash
servi’ce to impacted
customers •··
Technical Technically At the limits of Technically Feasible Technically feasible –
Feasibility Feasible- however technical feasibility – although more difficult Application of heat
there are no known potentially not feasible than Aligmnent 1 – extraction wells for this
past application of Feasible- however there purpose has had limited
the use of concrete are past application of the testing (the RP’s pilot
as a heat barrier in use of concrete as a heat study)
a landfill. Studies barrier in a landfill.
have shown Studies have shown
degradation of degradation of concrete
concrete strength strength properties from
properties from prolonged exposure to
prolonged exposure high heat
to high heat
WLLFOIA4312- 001 – 0055692
4.4 Structural IB Alignment 1 Advantages Discussion
Of the three structural IB alignments, Alignment 1 is considered the most technically feasible
and will require the least volume of waste to be excavated. The RPs have estimated the total
volume of waste for Alignment 1 to be approximately 50,000 cubic yards. Because this
alignment requires excavation of the least amount of waste, it is expected that it will have the
shortest construction duration. A shorter construction duration will reduce the duration in
which the community is exposed to odors from the excavation. Landfill odor has been an
ongoing concern for the surrounding community and reduced duration for odor emissions
would be a favorable advantage.
Bird hazards to air traffic are a significant safety conc~m t0 the St. Louis Airport Authority
as West Lake Landfill is located within 10,000 feet o£ the nearest Lambert St. Louis Airport
runway (see Section 7). Alignment 1 will resultinthe least amount of excavated waste and
will therefore present less risk of bird hazards and other nuisance species (insects, rodents)
that can, in tum, attract more birds, when compared to the other alignments. While this
alignment offers the least bird hazard risk, mitigation efforts will still be.required to
minimize waste exposure during excavation ahd handling o{ waste materiaL
Based on a 2013 bird survey performed during well i:l:lstallation and toe drain excavation
activities in the North and South Quan”ies ofthe Bridgetol;l Sanitary Landfill, 256 gulls,
geese, doves, and raptors were observed within:~ 20-day period. According to the Federal
Aviation Administration (Dol beer et al, 2014 ), these bird species were among the species
most frequently struck.byair:planes betwee~ 1990 and 2~ 13. It is expected that geese and
doves would not he attractecf:~to the excavation and waste handling operations to be
undertaken as they typically do not consume decomposed waste. However, gulls and raptors
are expected to be attr~ted to thesite operations as they will seek out easy food sources
including decemposed waste. With/gulls, miti:g~tion efforts such as sudden loud noises from
bird scaring devices (canons, warning horns) are .effective only for a period of a few days as
gulls can rapidly adaptto these sounds (AirpdrtOperators Association and General Aviation
Awareness Council, 2066). Add1tionally, since gulls tend to feed at operating landfills as the
trucks hauli:l:lg in trash are”tipped”, it is expected that gulls will likewise feed as excavation
is being conducted and trucks are being loaded to move the excavated waste to the staging
areas and to load trucks for off-site waste transport. Therefore, minimizing the amount of
excavation exposed and reducing the duration of construction will be one of the best bird
hazard mitigation strategies for the site.
Storm water management will also require mitigation efforts as birds are attracted to standing
water sources. For work previously performed at the Bridgeton Sanitary Landfill, the RPs
have ensured that detention basins drain within 24 hours, thereby not providing a continued
standing water source to attract birds. It is expected that a similar mitigation method for
storm water management would be implemented for each of the IB alignments.
Alignment 1 would be located where there will be no newer waste located on the north side
of the IB and will be placed in an area with a maximum waste depth of approximately 40
feet. The extent of waste decomposition and the pressure and insulating conditions in a
WLLFOIA4312- 001 – 0055693
landfill (often determined by the depth or thickness of the waste) are two of several factors
that can contribute to the generation of a future SSE. Older waste and shallower waste
located north of the Alignment 1 IB are considered an advantage as these conditions are less
likely to support the generation of a future SSE than the newer and deeper waste of
Alignments 2 and 3.
Another advantage of Alignment 1 is that the design time would likely be shorter than the
design time for Alignment 3 primarily because some of the data required for design of the IB
has already been collected. Some geotechnical data would still be required to be collected
before design could begin, but these pre-design investigations would likely be shorter in
duration than those that would be required for the other alignments, therefore allowing design
efforts to be completed in a shorter duration than the other alignments.
Alignment 1 also has an advantage of not having to remove existing North Quarry
infrastructure (monitoring wells, landfill gas collection wells, andassociated piping) for the
installation of Alignment 1. The North Quarry infrastructure was installed as part of the
May 2013 First Agreed Order of Preliminary Injunction for the RPs to install infrastructure to
monitor for the SSE and control landfill gas. Therefore, the least impact to the existing
infrastructure will minimize the design and construction duration as the RPs will not have to
remove, redesign, and reinstall the North Quarry infrastrUcture.
4.5 Structural IB Alignment 1 Disadvantages Discussion
While Alignment l has comparatively more advantages than Alignments 2 and 3, the
disadvantages of Alignment 1 carry some amount of risk that must be considered. While it
may be possible to manage the risk associated with these disadvantages, these risks must be
considered. when selecting an align;ment.
The first disadvantage .of Alignment 1 is that although the vast majority of RIM will be
isolated north of the IB, some RIM will remain on the south side of the IB. Since the
purpose ofinstalling the IBis to prel(ent the SSE in the Bridgeton Sanitary Landfill, from
coming into contact with RIM in the West Lake Landfill, leaving some RIM on the south
side of the IB would not completely fulfill that purpose. To mitigate this significant
disadvantage, the Alignment 1 design would need to include a means for mitigating the RIM
remaining on the southside of the IB. Field and laboratory results from the recent sampling
performed by the RPs must be evaluated to determine what information is required to
evaluate technologies fotaddressing the remaining RIM, if the risk is shown to be such that
remediation is required. Section 5 includes a list of potential options that the RPs could
consider to address remaining RIM.
The second disadvantage of Alignment 1 is that the IB would be installed through RIM.
Handling RIM during excavating, staging, screening, transporting, and disposal of the RIM
are activities that must be appropriately planned during design and carefully managed during
construction due to the potential impact to the safety of on -site workers and the potential for
RIM release during off-site transportation to disposal facilities.
WLLFOIA4312- 001 – 0055694
The on-site worker safety risks can be mitigated through the preparation and thorough
execution of Health and Safety Plans; however, preparing and following these procedures
does add time to the construction process. Similarly, off-site disposal of RIM will require
some over the road transportation. This will result in increased truck traffic in the vicinity of
the site and could lead to increased risk for traffic accidents, which could result in spilling
RIM along the transportation route.
Excavation through RIM can also lead to off-site exposure risks associated with airborne
dust, which could contain RIM. Qualitative assessment of the relative off-site risk due to
airborne RIM exposure would be dependent upon the depth of the RIM and the RPs’ material
handling processes. Mitigation is planned through use Gf afi air monitoring network to
monitor for RIM and through proper dust control dur:ing ex~a~ation activities. Proper
planning and response plans to include these mitigation actions will be required to reduce the
risk but the preparation and implementation of t}tese mitigation efforts will increase the
design and construction durations.
Off-site waste transportation itself is a risk fornotonly s~fety reasons, but.due to how it can
impact the duration of construction. The time it takes to stage, screen, segreg~te, sample,
load, and transport the RIM can ~dd ~~nificant time !O the construction duration. The exact
impacts to the design and construction efforts cannot be quantified at this time and will need
to be addressed by the RPs as they determine how the RIM will be managed. The amount of
RIM, the saturation of the waste, how the waste will be transported, and the location,
permitting, and samplingtequirements of the disposal facility will contribute to the schedule
risk associated with handling RIM.
There are no know~ past applications using a concrete wall as a heat barrier in a landfill.
There have h~en. studies showing. thed~gradation of strength properties of concrete when
exposed to high heat. It maybe possibleto,overcome these issues during design, but more
study would be necessary to determine if speci~l mix designs could overcome this issue.
4.6 Structural IB Alignment 2 Advantages Discussion
The primary advantage of Alignment 2 is that this alignment should separate all identified
RIM from the existing SSKin:the Bridgeton Sanitary Landfill. This is a significant
advantage as that is the primary reason for the installation of the IB.
Another advantage is that from an off-site safety standpoint, because no RIM is anticipated to
be encountered, the risk for on-site and off-site exposure to RIM is low.
4.7 Structural Alignment 2 Disadvantages Discussion
The primary disadvantage of Alignment 2 is the significant volume of waste that would need
to be excavated. Because the depth of the IB would be approximately 180 feet and the
WLLFOIA4312- 001 – 0055695
potential for differential settling of the waste on the opposite sides of the IB, the IB design
would have to be significantly wider than the IB for Alignment 1 to be capable of
withstanding these differential stresses. This effort will significantly increase the design
duration as additional time will be required to ensure the design is stmcturally sound and that
the proper cooling system is incorporated. Additional geotechnical data will also need to be
collected and getting that data from a deeper depth will take longer. One potential way to
mitigate the width of the Alignment 2 IB would be to implement an on-going operation and
maintenance plan that restores the surface of the settled waste to prevent the overturning
stresses caused by differential settlement of the wastes adjacent to the barrier. The RPs will
need to make a determination on which means is most effective for addressing this issue,
should this alignment alternative be selected.
Due to the large depth and width of the excavation, thelength of time the excavation would
remain open would be significantly increased and the odor potential and duration of the odor
would, in tum, be significantly increased. The negative impact of the odor and the duration
of the odor to the quality of life for the nearby community may not be acceptable.
The significant volume of waste and the length of time to excavate will al~osignificantly
increase the bird hazard potentiaL As discussed itt Section 4.4, gulls and raptors are expected
to be attracted to the site operations as they will seeK: out easy food sources. Due to their
ability to rapidly adapt to loud and active surroundings, mitigation techniques would have to
be aggressive and vary frequently due to the significant dutation required to constmct this
alternative. Additionally, since gullswould be expected tofeed as excavation is being
conducted and tmcks are ~eing loadedlo move the exc~vated waste to the staging areas and
to load tmcks for off-site waste transport, bird nlifigation for this alignment alternative is
expected to be challenging over the extendedcmistmction duration expected for this
alignment alternative.
Alignment 2 would be located. within the Bridgeton Sanitary Landfill, therefore, a large
amount of the newer waste in this landfill will be located on the north side of the IB. The
maximum depth on the north side of the IB would be approximately 180′. The greatest depth
of this ‘hewer waste wouHfb’e located between the IB and the Quarry wall, which could
potentially i11crease the pressure and insulating factors, which, if other conditions are right,
could contribute to a future SSE on the north side of the IB.
Alignment 2 would be locate(! in the North Quarry of the Bridgeton Sanitary Landfill and
should not encounterRJM.because there has been no evidence that RIM was placed in this
area and because a review of historical records indicated that in 1973, while the RIM was
being placed in the West Lake Landfill, the North Quarry was still be excavated. This site
conceptual model does not support the presence of RIM from the Latty A venue site in the
North Quarry. Because of this, the risk to the safety of on-site workers due to RIM is
determined to be the lowest compared to the other alternatives. However, because of the
significant volume and depth to be excavated, the constmction techniques, and the length of
constmction required to install the IB, the general constmction safety risk to workers is
considered significantly higher than Alignments 1 and 3.
WLLFOIA4312- 001 – 0055696
With regards to off-site safety, due to the large volume of waste and limited space on site for
staging, off-site disposal will be required. The increased tmck traffic in the vicinity of the
site will increase the risk for traffic accidents. Additionally, the increased tmck traffic
waiting to enter and exit the site will impact the existing Transfer Station operations. This
could dismpt some of the Transfer Station’s operations including customer’s trash collection
Another disadvantage of Alignment 2 is that monitoring wells, gas collection lines, and gas
extraction wells located in the North Quarry would have to be removed prior to installation
of the IB and then reinstalled after constmction is completed. Due to the long constmction
duration, that North Quarry infrastmcture would not be in place for a long duration. The
North Quarry infrastmcture was installed as part of an Qrder for Preliminary Injunction for
the RPs to monitor temperature fluctuations, carbon monoxide emissions, and control landfill
gas. This infrastmcture is important for detecting potential movement of the SSE and
controlling landfill gas.
The volume of waste to be excavated with Alignment 2 would result in daily conditions that
are considered similar to those of an operating landfill. Th~. number and the significance of
the disadvantages of Alignment 2 far outweigh the Aligmnent 2 advantages. Therefore, all
parties were in agreement of not suppoJ;ting selection ofAlignment 2.
4.8 Structural IB Alignment 3 Advantage~ Discuss ion
The primary advantages of A~gnment 3 are that 1t is tecllnically feasible and requires
significantly less volume of waste to be excavated compared to Alignment 2 while
minimizing and potentially eliminating RIMremaining south of the IB and potentially
exposed ~o the SSE when comparet:l to Alignment 1.
Anotlfler advantage ofAlignmeat 3 is that the on-site safety risk to workers due to RIM
exposure will be lowerthan Alignment 1 and the on-site safety risk to workers due to general
constmction efforts would be less than Alignment 2 because of the shorter constmction
duration and less challenging installation.
4.9 Structure/} Alignment 3 Disadvantages Discussion
Although Alignment 3 has significantly less volume of waste to be excavated than Alignment
2, the volume of waste to be excavated for Alignment 3 is considered a disadvantage when
compared with the volume of waste to be excavated for Alignment 1. Alignment 3 could
have as much as double the volume of waste as Alignment 1. As previously stated, the
volume of waste drives the disadvantages with each alignment, so more than doubling the
volume of waste will increase the risk associated with those disadvantages.
Alignment 3 will have less potential for odor than Alignment 2, but will have a greater
potential for odor than Alignment 1 due to the increased volume of waste to be excavated. In
WLLFOIA4312- 001 – 0055697
addition to the longer excavation duration, multiple staging areas will also be required for
Alignment 3 in order to stage the larger amount of excavated waste so it can be screened
prior to disposal. Having multiple staging areas will also contribute to the longer overall
construction duration and odor potential. As odor is a quality of life issue for the community,
this could be considered a significant disadvantage to the community.
Alignment 3 will also have a significantly less potential for bird hazard compared to
Alignment 2 due to the lower volume of excavated waste; however, when compared to
Alignment 1, the bird hazard potential increases and therefore, is considered a disadvantage.
As discussed in Section 4.4, gulls and raptors are expected to be attracted to the waste and
some mitigation efforts are not expected to be effective for more than a few days.
Additionally, since gulls tend to feed as the excavated material is loaded onto trucks for
transport, netting or other means of mitigation will likely be required to minimize bird
A disadvantage of Alignment 3 is that it would need to move 50-feet closer to the high
quarry wall than the alignment evaluated as Gption 3 Alignment in the R.Ps October 2014
report entitled “Isolation Barrier Alternatives Analysis, West Lake Superfund Site.” This
will require additional design effort and potentially a thick;er wall in the w’esteJ;U third of the
wall to account for potentially higher differential settlement forces from North Quarry waste
settlement. Despite this, the overall level of effort as compared to the Option 3 Alignment in
the 2014 report is unlikely to be substantially. higher.
With Alignment 3, S(JMepfthe newer Waste in the North Quarry will be located on the north
side of the Alignment 3 IB. Tfiis overlay area; when combined with the West Lake Landfill
Area 1 waste below it, has a maximum depth ()f waste of approximately 90-feet. The
additional depth ofwasJe from the North Quarry overlay and the newer waste located on the
north side of the Alignment 3 IB are two factors that can contribute to the generation of a
future SSE on the north side of the IB. Because these conditions would exist if this
alignment were installed, they are considered·~ disadvantage. The on-site safety risk for
Alignment 3 would be lower wlien compared to Alignment 1 if little or no RIM is excavated
to ins tail this IB. The relative risk for Alignment 3 RIM exposure would be equal or slightly
higher compared to Alignmtnt 2 as noRIM is expected to be encountered during excavation
of Alignment 2. From a general construction standpoint (not considering RIM), the on-site
safety risk for Alignment 3 is higher than Alignment 1 due to the length of the construction
duration and higher revel of Qifficultly associated with a deeper wall. The general on-site
safety risk for Alignnfent3is considered significantly less than Alignment 2 due to the depth
of excavation and the amount of material handling required for Alignment 2.
Alignment 3 ‘s off-site risk for exposure to airborne dust containing RIM is considered lower
than Alignment 1 ‘s risk because Alignment 3 will be placed in an area that is expected to
encounter limited RIM, if any, based upon recent sampling results. As indicated in the
Alignment 1 discussion, mitigation measures, including air monitoring and dust control, can
be employed to control risks during excavation and waste handling.
WLLFOIA4312- 001 – 0055698
The duration of design for Alignment 3 will be longer than Alignment 1 due to the need to
for a more robust design to address differential settlement. The depth of the waste will
increase the amount of time required to collect the data necessary for design. Additionally,
because the IB will be deeper in the western portion of the alignment, additional design time
will be required due to more complex loadings and structural requirements of the wall. The
construction duration for Alignment 3 will also be longer than Alignment 1 due to the
increased depth of the western portion of the IB.
Another disadvantage of this IB alignment is the impact to existing infrastructure. The
monitoring wells, gas collection lines, and gas extraction wells located in the North Quarry
would have to be removed prior to installation of the IB and then reinstalled after
construction is completed.
There are no known past applications using a concrete wall asaheat barrier in a landfill.
There have been studies showing the degradation of strength properties of concrete when
exposed to high heat. It may be possible to oxercome these issues during design, but more
study would be necessary to determine if special mix designs could overcome this issue.
4.10 Heat Extraction Barrier Advantages
The most significant advantage oftheheat e~traction IBis that the volume of waste to be
removed will be negligible compared to any other option. The waste to be removed results
from drilling coolant wells. This amount of waste <;an easily be handled on site. As a result of the mfuimized waste, the odots. and bird hazards for this alternative is significantly less than the other alternatives. On-site safety risk is also the least of all alternatives due to limited, if any, :exwsure to R1;M or other chemicals. Additionally, offsite exposure to RIM :Fisk would l:>e the least ofall the other alternatives as well due to the limited
amount of waste handlfug. A€lditionally, thilalternative would have limited truck traffic
when compared to the other alternatives, significantly reducing the off-site traffic accident
One of the oth’er more significant advantages of the heat extraction barrier alternative is that
the design time is shorter than the other alternatives and it can be installed within a shorter
duration than the strUcturaliB+alternatives. Given that there are varying views of the
movement of the SSE, shorter design and installation durations are a strong advantage.
Because of the shorter design and installation time, the system can be expanded quickly in
the event actual monitoring data shows that additional cooling is necessary to contain the
heat front.
Data from the RP’s pilot study provides a proof of concept for the heat extraction barrier
alternative. The proposed heat extraction system combined with the heat sink properties of
the surrounding limestone makes the neck area between the North and South Quarries the
optimal location to install a cooling system.
WLLFOIA4312- 001 – 0055699
4.11 Heat Extraction Barrier Disadvantages
The primary disadvantage of the heat extraction barrier is the wells will be subject to high
heat, a corrosive environment, and waste settlement. This can be mitigated by planning for
well replacement if heat and corrosion or waste settlement impacts the cooling wells. In
addition, application of heat extraction wells for this purpose has had limited testing (the
RP’s pilot study).
Another disadvantage is that the proposed placement of the heat extraction barrier in the neck
is that if a future SSE were to occur in the North Quarry, the heat extraction barrier would
not be positioned to prevent the SSE from moving into the West Lake Landfill and coming in
contact with the RIM. However, the flexibility of the lieat: extraction barrier alternative is
such that additional wells and coolant capacity could he quickly installed at a location
between a new SSE and the RIM.
5. Design Considerations
Options to address some of the technical challenges anticipated during design and construction
were identified. Following are some of those design considerations.
For Alignment 1 and potentially for Afignment 3, the possibility of encountering RIM during
excavation exists. During discussions, the RPs i:ttdicated they Were considering utilizing a panel
wall construction method to install the IB, Utilizing a panel wall construction method would
reduce the amount of e~cavated materials arid drilling fluids/slurry tfrat would come into contact
with RIM when compared to a cont~uous trench excavation; kowever, there could still be a
significant volume ofwa~te and flui~s resulting from the in panel wall construction that would
require handling and disposal as RIM. Because ilie safe handling and disposing of additional
material as RIM. will increase the Qyerall duration and cost of the project, alternative construction
methods.thatcouldfurther minimize the potential amount of radiologically impacted slurry or
drilling fluids should be investigated.
One potential construction method that could be considered to minimize the use of fluids or
slurry is the use of a secant pile.wall for that portion of the IB that extends through RIM. A
secant pile wall w~:Uld not require ;use of a slurry, so it would minimize the potential spread of
RIM and eliminate handling of :RIM contaminated slurry. It is also suitable for installation in
difficult subsurface c6n~iti~ns, It also can be used in combination with panel wall installation
(panel wall installation on ilie east portion of the IB and a secant pile wall installation on the west
portion of the IB). The primary disadvantage of a secant pile wall installation is that there is less
certainty in the continuity of the wall; however, there are installation and down-hole verification
techniques to minimize this uncertainty. The RPs would also need to determine how to
incorporate an internal cooling system with both the secant pile wall and the panel wall
construction methods.
Depending upon the alternative selected, there may be some RIM remaining on the south side of
the IB wall that needs to be addressed as part of the IB design. Table 2 summarizes some
potential mitigation measures to consider.
WLLFOIA4312- 001 – 0055700
Table 2 – Options to Address Remaining RIM
Option Description Advantages Disadvantages
RIM handling, screening, transport,
Open excavation and increase in odor
Open excavation and increase in bird
hazard to air traffic
Ensuring IB stability while RIM
Excavate identified excavation is conducted adjacent to the
Excavate RIM remaining on Minimizes risk of RIM contact lB. This is a significant disadvantage
RIM south side ofiB with SSE and will increase the size of the IB, the
\l’olume of waste to be excavated, and
6tlfer associated risks. It is possible that
.excavation after IB installation may not
be technically feasible depending upon
the t?cation of the remaining RIM with
respectto the IB structure.
Off-site hauling for disposal may
increases risk of traffic accidents and
RIM release.
Reduces the amount of waste Effects of SSE in C:ontact with stabilized
Utilize deep soil to be handled, transported, and R.lM are unknown. Will likely require
mixing techniques di&posed .. • bench scale testing to verify
to auger down to
··················• May be difficult to implement in the
RIM, inject cement landfill due to potential loss of grout (in
In-Situ grout, and mix Reduces tlfe amoimt of situ deep soil mixing has been
Stabilization grout with the exposed waste and therefore successful in nonnal soil conditions).
waste to reduces the amount of od.or Some components of waste may hinder
immobil.izethe hydration of waste so bench scale
RIM and adjacent testing would be required to determine
waste intoa the appropriate stabilization agents.
hardened block less Reducesthe amount of Requires thorough identification of RIM
sl)St:;eptible to tlte exposed waste and therefore to know area requiring stabilization
SSE reduces the bird llit?:ard
Eftective for smaller areas of Requires ability to identify location of
Inject liquid N2 or RIM SSE. Difficult to detect SSE movement
1 ;n~~=~~c~h:s the
Wastefiandling/disposal Reliable supply ofliquid N2 and C02 is
would be limited to waste not currently available.
LiquidN2 or SSEapproaches to generated for injection well
C02 Injection cool tlfe. subsurface installation
and extinguish the Limited odors- no open
SSE excavation Increased worker safety issues when
Limited bird hazard-no open handling liquid N2
Heat Install closed- Flexible and can be Wells may settle as waste settles and
Extraction system cooling implemented quickly. Can be could impact effectiveness of system,
Barrier loop and wells to expanded easily if additional causing need for new wells. Well
cool the heat front cooling is required. material could be impacted by high heat
between the RIM and corrosion.
and the SSE to
prevent the SSE
from coming into
contact with the
WLLFOIA4312- 001 – 0055701
Option Description Advantages Disadvantages
Allows for capture of landfill
Install synthetic gas. Landfill gas collected may require
Synthetic cover over top of Eliminates excavation, reduces treatment prior to discharge.
Landfill landfill south ofiB need to handle, transport, or
Cover& Gas where remaining dispose of waste
Collection RIM is located. Eliminates excavation, Any cover could potentially be
System Install gas minimizes bird hazard. susceptible to damage from SSE or
collection system RPs already planning to install natural events.
synthetic cover at North
If any of these options were to be incorporated, the RPs wou:ld’:need to evaluate each one and, if
necessary, conduct the appropriate studies required for design and construction. As part of the
design to address any RIM remaining south of the I]3, the RPs should evaluate the possible risks
to receptors should the SSE come into contact with the remaining RIM.
6. Design Schedule Considerations
It is not known that the SSE will reach the RIM; however, due to the unpredictable nature and
movement of the SSE, the length ofti:nte for the SSE to reach the RIM in QUI, Area 1 is
currently unknown. Therefore, length df time required to design and install the IB was a
consideration during this assessment.
The standard industry practice is to complete the d~s1gn in stages with reviews conducted at each
stage. Typical design stages are the 3 0%, 60%, 90% and 1 00% i:fesign stages. The 3 0% design
stage is conceptual and many of the specific details of the design are not complete and are still
being evaluated, T~e 60% and 90% d~sign stages ate more complete with almost all of the
details defined, The Final Design represents the completed design product. It is USACE ‘s
understanding that a similar design process will be followed for the IB effort and that the
documents produced at each stage of the design will be subject to government review and
This staged approa¢h to the designallows for good quality control and helps ensure that all
design objectives are met. However, at each stage in the process, a set of documents is produced
that requires sufficient time to prepare, review, and then respond to any technical review
comments so that those revisiotis may be carried forward into the next stage. There may be ways
to shorten the time required t6complete each design stage. Typical methods to speed up the
design process are: increase the number of designers; conduct “over the shoulder” or “in
progress” reviews while the design team continues working instead of requiring the designers to
stop and respond to review comments in between each stage; and reduce the time allowed for the
reviewers to perform their review. Each of these methods introduces some chance of error.
Rushing the design and quality control reviews in order to start construction earlier may result in
problems or delays during construction because those problems w


2015-01-04 – EPA – West Lake Landfill – OU1 Removal Action (Isolation Barrier)- EPA Region VII Monthly Report

West Lake Landfill SF Site OUl Removal Action (Isolation Barrier)- EPA Region VII Monthly Report
Bill No.: I 27076647 I lAG No.: DW96958582 I P2# : 444809 I lAG Exp. Date: I 30-Dec-2016
Reporting Period: I From:
1 Dec2015
I To:
4Jan 2015
Robyn Kiefer
Work Performed
Key Milestones
Projected Work
Key Milestones
Project Management: Completed monthly status report and budget tracking. lA
processing/funding acceptance. PDT Coordination.
Coordination for Kansas City District Engineer’s involvement in EPA IB Announcement Press
Event including preparation of potential Q&A
Partici nal discussions lB.
12/1/15 -Kiefer, Specking participate in call with EPA to discuss IB options
12/2/15 -Sexton call with EPA R7 RA (Hague) RE: West Lake IB announcement
12/8/15 -Kiefer, Speckin, Leibbert participate in pre-decisional discussion call with
12/9/15 -Young, Leibbert participate in EPA R7 RA briefing prep call
12/10/15 -Young, Leibbert participate in EPA R7 RA briefing meeting
12/18/15- Sexton, Ostrander, Young, Leibbert, Kiefer- NWK District Engineer briefing on
West Lake announcement
12/31/15 -EPA makes announcement on IB decision
Review RP’s Comprehensive Phase 1 Report
Review and coordinate response with St. Louis District & EPA on Pb210 article
Assist EPA with core testing effort as requested
Assist in aration for Feb 8 CAG
Attend February 8 CAG meeting.
Complete review of IB installation work plans and designs when they are submitted
Perform preconstruction observation effort.
Risk: Delay of decision on IB path forward due to need for additional characterization
reduces alternatives and increases risk of rushed design and construction effort, should a
heating event be identified in North Quarry.
Challenge: Advanced notice of dates when work plans/designs are expected to be submitted
by RP is necessary to ensure appropriate PDT resources are available to perform document
reviews in a timely manner. Advance notice of what USACE support (meetings, briefs,
reports) is required is key to ensuring quality of and ability to support.
Challenge: $80K in additional funding received from EPA. Execution of activities not
included in original budget continues. With additional $80K, projected shortfall (depending
future Technical Assistance tasks roximatel $50K.
1 OF 2
WLLFOIA4312- 001 – 0058924
West Lake Landfill SF Site OUl Removal Action (Isolation Barrier)- EPA Region VII Monthly Report
Bill No.: I 27076647 I lAG No.: DW96958582 I P2# : 444809 I lAG Exp. Date: I 30-Dec-2016
Reporting Period: I From:
1 Dec2015
I To:
4Jan 2015
Robyn Kiefer
lAG Summary
USACE Contract Total Amend Total lAG Date
Reimbursable Direct Fund Cite
320,000 – 320,000 320,000 15-Apr-2014
80,000 – 80,000 400,000 8-Dec-2015
Funded Current Bill Previous Remaining EAC Notes
Billed Funding
400,000 9,543.40 185,061.08 205,395.52 320,000 See Page 1 -Funding Challenge
Note: This is an in-house action, therefore no contractor expenditures
Scope of Work Summary
Project Development Team
Robyn Kiefer
Paul Speckin
Jough Donakowski
Pat Conroy
Mary Delaet
Margie Benningfield
Dave Mueller
Bradley Vann
Electronic Deliverable
Robyn Kiefer
Project Manager
Org Phone
CENWK-PM-M 816-389-3615
CENWK-ED-EG 816-389-3592
CENWK-ED-ES 816-389-3993
CEMVS-EC-GT 314-331-8430
CENWK-ED-DM 816-389-3226
CEMVS-EC-CA 314-331-8040
CEMVS-EC-CF 314-331-8040
EPAR7RPM 913-551-7611
8 January 2016
20F 2
WLLFOIA4312- 001 – 0058925


2014-10-14 – EPA – West Lake Landfill – Fiscal Year 2014 Accomplishments

Sumpter, Richard[Sumpter.Richard@epa.gov]
Weber, Rebecca
Tue 10/14/2014 6:35:10 PM
RE: West Lake FY14 accomplishments
From: Sumpter, Richard
Sent: Tuesday, October 14,2014 1:31PM
To: Weber, Rebecca
Cc: Lubbe, Wendy
Subject: RE: West Lake FY14 accomplishments
From: Weber, Rebecca
Sent: Tuesday, October 14, 2014 11:21 AM
To: Sumpter, Richard
Subject: RE: West Lake FY14 accomplishments
From: Sumpter, Richard
Sent: Tuesday, October 14,2014 11:19 AM
WLLFOIA4312- 001 – 0058210
To: Weber, Rebecca
Subject: RE: West Lake FY14 accomplishments
From: Weber, Rebecca
Sent: Tuesday, October 14,2014 11:15 AM
To: Sumpter, Richard
Subject: RE: West Lake FY14 accomplishments
From: Sumpter, Richard
Sent: Tuesday, October 14, 2014 11:07 AM
To: Jackson, Robert W.
Cc: Weber, Rebecca
Subject: RE: West Lake FY14 accomplishments
From: Jackson, Robert W.
Sent: Tuesday, October 14, 2014 10:55 AM
To: Sumpter, Richard
Subject: FW: West Lake FY14 accomplishments
WLLFOIA4312- 001 – 0058211
From: Gravatt, Dan
Sent: Tuesday, October I4, 20I4 I0:42 AM
To: Jackson, Robert W.; Field, Jeff; Ferguson, Jaci
Subject: West Lake FYI4 accomplishments
Provided at Bob’s request this morning:
FY20 I4 Milestones for West Lake Landfill
EPA entered into two separate Interagency Agreements with the US Army Corps of Engineers:
one to obtain their assistance with design and construction oversight for the subsurface barrier
intended to separate the subsurface oxidation event in OU2 from the radiologically impacted
material in OU I; and the other to provide independent technical reviews of the deliverables the
PRPs will generate under the Supplemental SFS. USACE provided EPA its evaluation of the
engineering considerations with the three potential barrier alignments that have been considered
to date. EPA continued to coordinate with the US Geological Survey under another IA as they
prepared a comprehensive evaluation of groundwater hydrology and background concentrations
and sources of radionuclides at the site. EPA issued a Pre-Construction Order to the PRPs that
directed them to begin preparing the site for the eventual construction of the subsurface barrier
and provide other technical documents on bird mitigation and air monitoring that will support
this construction. EPA installed a network of five off-site air monitor stations in the surrounding
community to begin collecting a background baseline data set to help evaluate air sampling data
to be collected during the eventual construction of the subsurface barrier. EPA’s Office of
Research and Development evaluated the PRP’s report on the possible effects the OU2
subsurface oxidation event might have on the RIM in OUI should the SSE migrate into OUI in
the future. ORD has also been tracking the monthly reports on the SSE extent and gas and
temperature data provided by the PRPs to the Missouri DNR to provide an independent
assessment of SSE behavior. EPA responded to community concerns about possible radiological
contamination at the Bridgeton Municipal Athletic Complex and conducted a thorough
investigation of the area which determined that there was no radiological contamination there.
EPA has coordinated extensively with the community through attendance of the monthly
Community Advisory Group meetings and issuance of weekly “West Lake Update” newsletters.
WLLFOIA4312- 001 – 0058212
Daniel R. Gravatt, PG
11201 Renner Boulevard, Lenexa, KS 66219
Phone (913) 551-7324
Principles and integrity are expensive, but they are among the very few things worth having.
WLLFOIA4312- 001 – 0058213


2015-10-09 – EPA – West Lake Landfill – Heat Extraction Barrier Pilot Study Data Needs

Heat Extraction Barrier Pilot Study Data Needs –Update
Subject: Heat Extraction Pilot Study Updated Data Needs to Adequately Evaluate Potential
Effectiveness of Heat Extraction Barrier, West Lake Landfill
Date: October 9, 2105
One of the alternatives evaluated in the October 2014 Isolation Barrier Alternatives Analysis
report submitted by Bridgeton Landfill LLC is a heat extraction barrier. However, the
Alternatives Analysis report lacked detailed information necessary for USACE to make an
independent technical evaluation of the potential effectiveness of such a system. Since the
October report was submitted, Bridgeton Landfill LLC proposed to expand on the current test
well (GIW-4) and perform a pilot study to obtain information to demonstrate the effectiveness of
this proposed alternative and to obtain data necessary for design of the system. It is USACE’s
understanding that this expansion pilot study was approved by the Missouri Department of
Natural Resources (MDNR) and implemented.
In December 2014, USACE submitted to EPA the information listed below. This list is
information USACE will need regarding the heat extraction study at GIW -4 and the pilot study
expansion system that consisted of retrofitting 6 additional GIW wells with recirculation coolant
tubes, to assess whether adequate information is being collected to design an effective heat
extraction system.
It is USACE’ s understanding that the pilot study data that was submitted to the Missouri
Department of Natural Resources (MDNR) was posted on their website. USACE reviewed the
information posted on the MDNR web site and supplemented the list below with what
information was identified from that web page. The supplemental information is included below
in brackets with text bolded. If there is no bracketed/balded information, we could not locate the
• Schematic of the modified GIW -4 used in the preliminary heat extraction study including
depth and construction of the well and all pipe sizes where fluid is flowing [MDNR website
has a submittal from Republic that shows a schematic of the cooling loop proposed for
the expanded pilot. As-built information was not provided]
• Details of the cooling equipment and/or coolant being used in the pilot study.
• The preliminary data collected from the heat extraction study at GIW -4 including inflow and
outflow water temperatures, flow rate, and the temperature within the casing measured at
multiple depths.
• Calculations to determine the 25kW extraction rate.
WLLFOIA4312- 001 – 0059515
• Location of the 6 additional GIW wells to be retrofitted with recirculation coolant tubes
including depth and construction of the wells and all pipe sizes where fluid will flow.
[MDNR website has a Republic submittal requesting expansion of the pilot study and
includes a plan view of proposed GIW wells and locations of proposed new temperature
• An explanation ofhow the modified GIW wells are representative of the proposed driven
heat extraction wells and whether or not a pilot study of driven wells of the material proposed
for the full scale system will be tested prior to design and installation of the system.
• Plans of the proposed closed loop header system used to convey cooling water to the
mechanical cooler.
• Location of current Temperature Monitoring Probes and depths and proposed locations and
depths of temperature measurements when the pilot study is expanded.
• Proposed study procedures including assumptions used.
• Proposed calculations to determine thermal conductivity and heat storage properties of the
landfill waste. In addition, how is obtaining thermal conductivity and heat storage properties
of the South/North Bridgeton landfill waste representative of these properties in the proposed
location of the heat extraction system in the West Lake Landfill waste?
• Results of the assessment ofheat front progress to the north and the rate of energy flux to the
• Calculations used to predict the amount of heat that could be extracted under steady state
conditions and the results of those calculations.
• A plan view of the proposed Temperature Monitoring Points as well as a cross section
showing depth intervals of temperature readings. Attachment C indicates it is envisioned as
one array per 120 feet would be sufficient. Is this 120 ft spacing parallel with the proposed
barrier? [[MDNR website has a Republic submittal requesting expansion of the pilot
study and includes a plan view of proposed GIW wells and locations of proposed new
temperature probes.]
• It appears the settling front associated with the SSE would render the heat exchange system
non-functional if the system fell within the influence of settlement (similar to the need to set
back Option 3 IB wall). Therefore, it appears the heat exchange system would need to halt
the SSE and settling front some distance south of the barrier to prevent this failure from
occurring. What distance is this and what temperature needs to be attained some distance
from the barrier to prevent this from happening?
On October 8, EPA notified US ACE that Republic Services had provided them with more details
of the cooling system. Once that information is provided, US ACE will review that information
and provide further updates, as required, on what additional information is necessary to evaluate
the cooling loop pilot with the potential of utilizing it as a thermal barrier option for the isolation
WLLFOIA4312- 001 – 0059516
If you have any questions, please contact me at 816-389-3615.
Robyn Kiefer
Project Manager
ou=DoD, ou=A


2014-04-07 – EPA – Report on West Lake-Bridgeton Landfill Fire – Cover Transmittal Letter and Report

To: Brecht Mulvihill[brecht.mulvihill@mail.house.gov]; Brendan
Fahey[brendan_fahey@mccaskill.senate.gov]; Downey Palmer[downey_palmer@blunt.senate.gov];
Edwilla Massey[edwilla.massey@mail.house.gov]; Erik Rust[erik.rust@mail.house.gov]; Joeana
MiddletonUoeana_middleton@mccaskill.senate.gov]; John ScatesUohn_scates@blunt.senate.gov]; Kerry
DeGregorio[kerry_degregorio@blunt.senate.gov]; Lou Aboussie[lou.aboussie@mail.house.gov]; Mark
Fowler[mark_fowler@mccaskill.senate.gov]; Mary Beth Wolf[marybeth_wolf@blunt.senate.gov]; Mattie
Moore[mattie_moore@mccaskill.senate.gov]; Miriam Stonebraker[miriam.stonebraker@mail.house.gov];
Nichole Distefano[distefano.nichole@epa.gov]; Patrick Bond[patrick_bond@mccaskill.senate.gov];
Pauline Jamry[pau line .ja mry@mai I. house .gov]; Steven Engelhardt[ steven. engel hardt@mail. house .gov];
Tod Martin[tod_martin@mccaskill.senate.gov]
From: Sanders, LaTonya
Sent: Mon 4/7/2014 2:41:47 PM
Subject: FW: Report on West Lake-Bridgeton Landfill Fire – Cover Transmittal Letter and Report
From: Tapia, Cecilia
Sent: Friday, April 04, 2014 8:36AM
To: anderson@recycleworlds.net
Subject: FW: Report on West Lake-Bridgeton Landfill Fire – Cover Transmittal Letter and Report
Importance: High
WLLFOIA4312- 001 – 0058480
From: Peter Anderson
Sent: Monday, March 24,2014 5:02:50 PM
To: Stanislaus, Mathy
Subject: FW: Report on West Lake-Bridgeton Landfill Fire- Cover Transmittal Letter and
WLLFOIA4312- 001 – 0058481
WLLFOIA4312- 001 – 0058482
From: Peter Anderson L’-‘-“==~~~===’-‘~=~”-=J
Sent: Friday, March 21, 2014 6:52 PM
To: ‘chris.koster@ago.mo.gov’
Cc: ‘mogov@mail.mo.gov’; ‘brooks.karl@epa.gov’; ‘christopher.hall@usace.army.mil’
Subject: Report on West Lake-Bridgeton Landfill Fire – Cover Transmittal Letter and Report
WLLFOIA4312- 001 – 0058483
WLLFOIA4312- 001 – 0058484


2016-02-09 – West Lake Landfill – AG Koster letter to Congressman Clay and Congresswoman Wagner supporting request to transfer WLL to FUSRAP

Washington, DC 20515
Congresswoman Ann Wagner
435 Cannon
Washington, DC 20515
Dear Congressman Congresswoman Wagner,
from the Environmental ,_,.,.,.,.,,””,.. .. -,
Action Program” (or “FUSRAP”) …, …… uuuu~…,,
Because the EPA has proven itself an
West Lake I I encourage
outlined 4100 and S. 2306 and prioritize
House of Representatives.
past three years, my
aggressively to a solution to
Landfill-a problem vAll~vv.1.
Bridgeton Landfill. For example, office
West Lake site to
contamination, anticipation of construction of an
call for testing and expedited construction
March, and August 14, and 2015.
In response our repeated calls to
promises failed to deliver results. For
stated it was with
construction was expected to
passed with no discernable movement toward a
letters, sent
(573) 751-3321
WLLFOIA4312 – 001 – 0001696
Similarly, in February 2015, the EPA reported taking steps
characterizing radiological at also
testing, which would provide valuable information regarding the potential consequences
of letting fire at the Bridgeton reach the radiological at West Lake.
A year passed, yet EPA still has not announced the results its site
characterization, nor does it appear that the pyrolysis testing has been completed.
All the while, the continues to Experts by my office have raised
questions regarding whether and how long the safeguards installed
Bridgeton landfill can continue to progress toward West Lake.
Additionally, a troubling report released by Missouri Department of Natural
Resources last month corroborated concerns originally identified by my experts
radiological contamination may be present outside the perimeter of fenced-in landfill.
burning radioactive waste dump requires government act with urgency, but
seems unable to move forward with a meaningful solution. The Corps of Engineers,
through FUSRAP, has experience dealing with contaminated sites. I hope that experience
will enable the Corps, if given primary jurisdiction over this site and the necessary
funding, to quickly design and implement a remedial solution to improve the health and
quality of life of the Missourians who live, work, and go to school near West
Lake and Bridgeton Landfills.
cc: Senator Roy
Senator Claire McCaskill
Congressman Blaine Luetkemeyer
Congresswoman Vicky Hartzler
Congressman Emanuel Cleaver
Congressman Graves
Congressman Billy Long
Congressman Jason Smith
Attorney General
WLLFOIA4312 – 001 – 0001697
Karl Brooks
Environmental Protection Agency
Regional Administrator, Region 7
11201 Renner Blvd.
Lenexa, Kansas 66219
Dear Regional Administrator Brooks,
November 27, 2013
P.O. Box see
(573) 751-3321
The State of Missouri has received a Phase I Status Report detailing the preliminary
results of the Gamma Cone Penetrometer Testing that EPA has required in preparation for the
installation of an isolation barrier at the Westlake site in Bridgeton, Missouri. After reviewing
the report, the State is concerned about some of the raw data summaries, which suggest the
presence of higher-than-background-level radioactivity at depth outside the area where previous
maps represented the radioactive material was located.
In light of this new preliminary data, it is critically imp01tant that EPA direct the
completion of a comprehensive survey of the Westlake site to determi11e with certainty the
boundary lines encompassing the radioactive material. The implementation of.engineering
controls, including the isolation barrier intended to separate the radioactive material in Westlake
from the smoldering event in the Bridgeton landfill, depends on an accurate picture of the
radiological profile of the site. The State calls upon EPA to commence this comprehensive
smvey without delay.
In addition, due to the importance of this data and the high level of public interest in the
site, the State strongly encomages EPA to make the information publicly available as soon as
EPA validates the data for accuracy.
We look forward to hearing from you and continuing to work with you in addressing the
difficult challenges ahead.
Attorney General.
WLLFOIA4312 – 001 – 0001698
· .
. .
. ·._·.• …
Karl Brooks
Environmental Protection Agency
Regional Administrator, Region 7
11201 Renner Blvd.
Lenexa, Kansas 66219
January 8, 2014
Dear Regional Administrator Brooks,
(573) 751-3321
For more than nine months now, our office has worked with the Missouri
Department of Natural Resources (DNR) and EPA in addressing a matter of great
public concern-the underground fire at the Bridgeton landfill and its proximity to
the radioactive material at the adjacent West Lake site. While the landfill is
supervised by the State and West Lake is within federal jurisdiction, it is important
that regulators at all levels continue to communicate openly and effectively with
each other and with the public. We have demanded that Republic Services take
substantial steps toward mitigating the landfill fire, and significant work has
already been done. I write today to encourage a similarly aggressive approach to the
West Lake side of the problem and to better understand EPA’s timetable and its
contingency plan should the situation worsen.
Since our office became involved in this matter last spring, we have moved
rapidly to compel Republic Services to get control over the fire in the Bridgeton
landfill. We filed suit against Republic less than a week after receiving a referral on
this matter from DNR, seeking injunctive relief and monetary penalties. By
Memorial Day, we had negotiated a preliminary injunctive agreement that required
the company to install protective measures, including an ethylene vinyl alcohol
(EVOH) cap and gas interceptor wells, in an effort to slow the spread of the fire.
Before the summer ended, the wells were in place and the southern portion of the
landfill had been covered. Republic subsequently agreed to cap the remainder of the
landfill (the north quarry), and work on that project is expected to be completed by
May 30, 2014.
While much has been accomplished to better manage the fire at the
Bridgeton landfill, progress toward securing the radioactive material at the
federally supervised West Lake site has, to this point, been less visible. Republic
www.ago.mo .gov
WLLFOIA4312 – 001 – 0001699
Karl Brooks
January 8, 2014
Page 2
agreed in September to construct an isolation barrier between the West Lake and
Bridgeton landfill sites, yet it appears that the company is still conducting a survey
of the area in advance of any construction. We appreciate that EPA has urged
Republic to expedite this process, but the seriousness of the West Lake issue
requires that regulators set an aggressive timetable for Republic to complete the
barrier installation and demand that its deadlines be met. With that in mind, we
ask that EPA identify when it expects the comprehensive radiological survey will be
completed and, further, when it expects Republic to complete the construction of the
isolation barrier.
No matter how ambitious the construction schedule is, of course, we must
recognize that circumstances may change. We cannot be certain that the spread of
the fire in the Bridgeton landfill will not accelerate or that a new fire will not
spontaneously develop in the north quarry near the West Lake boundary line. As
the regulatory agency with supervisory authority over the West Lake site, EPA
must be prepared to react quickly should it become apparent that the isolation
barrier cannot be constructed in time to prevent the fire from reaching the
radioactive waste. We ask that the EPA make public its contingency plan in the
event that the construction of the isolation barrier becomes infeasible.
The people who live, work, and travel in the Bridgeton area deserve swift
action from the State and from EPA as we address the complex challenges posed by
the landfill and West Lake site. We are grateful for your team’s efforts thus far, and
we look forward to further cooperation between our respective agencies as our work
Attorney General
WLLFOIA4312 – 001 – 0001700
Karl Brooks
Regional Administrator
Environmental Protection Agency
11201 Renner Blvd.
Lenexa, KS 66219
Dear Administrator Brooks,
March 18, 2014
(573) 751·3321
One year ago, my Office filed a lawsuit against Republic Services alleging a series of
environmental-law violations relating to events at the West Lake landfill complex. The suit
seeks to accomplish two primary objectives. First, the suit aims to hold Republic responsible for
the alleged violations of applicable environmental laws. Second, and more importantly, the suit
aims to compel Republic to move swiftly in preventing the subsurface fire in the south quarry of
the Bridgeton landfill from migrating northward and reaching the radioactive material deposited
in Operable Unit 1 (OU-1). Over the past year, Republic has taken steps to slow the spread of
the fire, but recent developments suggest that these measures do not address the entire problem.
It now appears that radioactive material from OU-1 may be spread more widely than originally
thought and may be present in the north quarry of the Bridgeton landfill. Republic and EPA
must act aggressively to address this apparent relocation.
Last fall, after initial reports indicated that radioactive material was found in sections of
OU-1 that were previously thought to be unaffected by radiological deposits, EPA agreed to
order a comprehensive survey of the area to determine the true boundary of radioactive
contamination. We understand preliminary tests have found radioactive material not only
outside the originally identified “radioactive perimeter,” but beyond the southern edge of OU-1
itself, into the north quarry of the Bridgetonland:fill.
Expedited radiological testing: The possible relocation of radioactive material from
OU-1 into the Bridgeton landfill highlights the need for EPA and Republic to accelerate their
surveying and engineering efforts to ensure the fire in the south and radioactive material in the
north never meet. In particular, the need for a comprehensive remapping of the West Lake site
to definitively identify the extent of OU-1 ‘s radioactive contamination has never been clearer.
We ask that EPA and Republic expedite their work to complete this project as quickly as
WLLFOIA4312 – 001 – 0001701
Karl Brooks
March 18, 2014
Page 2
Federal authority over OU-l’s radiological deposits: The entire West Lake I
Bridgeton landfill complex was long-ago designated a Superfund site under federal control. To
date, EPA has limited its exercise of regulatory jurisdiction to the defined Operable Units at
West Lake, and it deferred its oversight of the remainder of the Bridgeton landfill to the
Missouri Department of Natural Resources. But the developing information indicating the
spread of OU-1 ‘s radioactive material suggests this division of legal authority may require a
change. EPA expressly deferred its legal authority regarding solid-waste facility closure and
post-closure of the Bridgeton landfill to the State only because that portion was thought to be
untainted by OU-1 ‘s radioactive waste. It is the federal government-whether EPA exclusively
or EPA working in conjunction with the Army Corps of Engineers-that is vested with the legal
authority and the resources to direct remediation of sites containing 0 U-1 ‘s radioactive waste. If
radioactive material from OU-1 is confirmed to be located in the Bridgeton landfill, legal
authority oyer the contaminated site must shift back from the State to the federal government.
Rapid construction of isolation barrier: Last September, Republic announced its
intention to build an isolation barrier to separate the radiological material in OU-1 from the
smoldering :fire in the southern part of the Bridgeton landfill. Over six months have passed, yet
construction of the barrier still has not begun. Although we acknowledge that essential
surveying is still underway, the ongoing site testing need not prevent construction from
commencing, at least in part. As EPA completes its radiological profile of the site, we ask that it
also finish its review of Republic’s proposed plan to construct the isolation barrier and, upon
identifying a sound design, direct that construction begin without delay.
The State’s highest priority is to protect the health and safety of its residents. Even if
circumstances require that EPA reassert its legal authority over the entire West Lake site, the
State will continue its work in validating data, offering comments to remedial plans, and
providing whatever other support may be needed. We look forward to working with EPA and
Republic in taking the steps necessary to isolate the radioactive waste from the landfill fire and .
thereby give the people in Bridgeton and its surrounding communities the security and peace of
mind they deserve.
Attorney General
cc: Bill Beck, General Counsel, Republic Services
WLLFOIA4312 – 001 – 0001702
Karl Brooks
Regional Administrator
US EPA Region 7
11201 Reimer Blvd_
Lenexa, KS 66219
August 11, 2014
Dear Administrator Brooks:
P.O. Box: 899
(573) 751-3321
In the First Agreed Order that my Office reached with Republic Services (“Republic”)
over a year ago, the St Louis County Circuit Court ordered Republic to implement a number of
protective measures to control the spread of the subsurface smoldering event (“SSE”), reduce
odors caused by the smoldering refuse, and separate the burning trash from the radiologically
impacted material deposited at the north end of the West Lake site. While significant work has
been done and is ongoing in an effort to control the fire and mitigate odors, little visible
progress has been made toward constructing.the isolation barrier aimed to keep the SSE from
reaching radiological waste. As the construction of the isolation barrier depends on the detection
and handling of radioactive material, any work on the project necessarily requires EPA
oversight and approval.
We recognize that the design and construction of the isolation barrier is an enormously
complicated task, and we appreciate the involvement of the Army Corps of Engineers, who
bring special expertise to engineering projects of this complexity. We also understand that the
implementation of any isolation-barrier design depends on the review and approval of LarnbertSt
Louis International Airport (“Airport”), which is responsible for ensuring that any planned
excavation or construction will not draw large numbers of birds and put air traffic at risk.
We understand that the Corps has analyzed a number of alternatives for placement of the
isolation barrier. In the interest of moving this project forward in a timely fashion, we ask that
EPA adopt the following schedule:
• Within 30 days, EPA, in conjunction with the Corps, presents its formal analysis
of the isolation-barrier alignment alternatives to Republic and to the Airport.
• Within 45 days following Republic’s receipt of the analysis, Republic submits its
alignment selection to EPA and to the Airport, which must include sufficient
design specifications to allow EPA, the Corps, and the Airport to evaluate the
• Within 45 days following the Airport’s receipt of Republic’s proposal, the
Airport announces whether it will consent to the proposal in light of its concerns
WLLFOIA4312 – 001 – 0001703
regarding the risks excavation and construction at the landfill may pose to flights
due to increased bird activity.
• If the Airport approves the proposal, EPA announces within 30 days of approval
whether it approves the proposal.
• If the proposal is not approved, Republic submits a modified proposal to EPA,
the Corps, and the Airport within 30 days, taking into account the comments and
concerns raised.
As always, the health and safety of the public, including those who live and work around
the landfill and those who rely on the Airport to provide safe flights, is our highest priority. We
remain frustrated with the slow pace of progress thus far. It is critically important that all
participants in this project move with greater dispatch to ensure that all members of the public
are protected.
Attorney General

WLLFOIA4312 – 001 – 0001704
Karl Brooks
Environmental Protection Agency
Regional Administrator, Region 7
11201 Renner Blvd.
Lenexa, Kansas 66219
February 18, 2015
Dear Regional Administrator Brooks,
(573) 751-3321
Thank you for your letter of February 9, 2015, updating our office on the EPA’s
recent directive regarding the Bridgeton Landfill / Westlake site. As you ’11 recall,
completing a comprehensive radiological characterization of the site was one of the three
action items discussed at our last meeting, and we appreciate the progress update and
your assurance that the work will proceed on an enforceable schedule.
We note also that, consistent with the second action item, EPA has secured
Bridgeton Landfill’s agreement to maintain soil corings and make them available for
EPA’s intended pyrolysis testing. Our recollection was that EPA expected that testing to
require five to six months to complete. Please keep us up to date on the progress of that
Finally, our colleagues from the Army Corps of Engineers suggested at our
meeting that an EVOH cover and gas extraction system could be explored as a potential
method to capture radon emissions that might occur as a consequence of the subsurface
fire at the landfill. As a third action item, we asked that EPA, in conjunction with the
ACOE, analyze the feasibility and probable effectiveness of installing such a system at
the Bridgeton Landfill/ Westlake site. Please let us know where things stand on that
We understand that scientific testing takes time to properly conduct. Yet, as we
have indicated before, the people of Missouri, particularly those who live, work, and go
to school near the landfill, are troubled by uncertainty surrounding the site and are eager
WLLFOIA4312 – 001 – 0001705
Karl Brooks
February 18, 2015
Page 2
for answers. We look forward to receiving the results of the above-mentioned tests and
analyses as soon as they are available.
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WLLFOIA4312 – 001 – 0001706
2/812016 Army Corps of Engineers to work on burning Bridgeton Landfill : News
– –
Army Corps of Engineers to work on burning Bridgeton
The Anny Corps of Engineers will help build an isolation barrier between an underground
fire at the Bridgeton landfill and radioactive materials in the adjacent West Lake Landfill,
according to the Environmental Protection Agency.
“The EPA intends soon to conclude an agreement with the United States Anny Corps of
Engineers to enlist Corps construction expertise for the isolation barrier to separate West
Lake from the (subsurface smoldering event),” EPA region seven administrator Karl Brooks
wrote in a letter Friday to Missouri Attorney General Chris Koster.
Construction on the barrier is expected to start within 90 days, Brooks said.
Koster urged the EPA this week to move quickly on the barrier. That move came one year
after Koster sued the landfills’ owner Republic Services, alleging violations of environmental
laws. Republic’s efforts to keep the fire from spreading “do not address the entire problem”
because additional radioactive material has been discovered closer to the fire, Koster said.
The Cold War-era nuclear waste was dumped illegally about 40 years ago and was
previously thought to be contained in West Lake. Early results from an EPA study show the
materials were found beyond the original perimeter and in the north section of the
Bridgeton landfill. The underground fire is in the south section.
Environmental groups and nearby residents have long called for the Army Corps of
Engineers to take over the cleanup of the Superfund site. The Corps has worked on other
nuclear waste cleanup projects around Lambert-St. Louis International Airport and
Coldwater Creek. Recently, several organizations, including St. Louis County, the cities of
Bridgeton and Maryland Heights and the Pattonville School District have supported such a
move. Missouri’s congressional delegation also called on the EPA to work with the Corps on
West Lake.
“I understand there’s a strong desire for action and that action is moving forward very
quickly,” Brooks said, adding that the EPA will retain authority over the site through its
Superfund program. “This is not a transfer to the Corps. This is an assist to EPA”
A spokesman for Republic Services said the company is committed to the construction of the
barrier when the regulatory authorities approve such a plan.
“The safety of both sites has always been our highest priority,” said Richard Callow.
http://www.stltoday.com/nev.1si1ocal/m etralarmy-corps-of-engi neers-to-work-on-burni ng-bri dgeton-landfi 11/articl e _ c914db0e-Oee4-50ca-a7 a2-53c565df2286.ht. . . 1 /1
WLLFOIA4312 – 001 – 0001707
FEB 13 20t5
The Honorable Chris Koster
Attorney General of Missouri
P.O. Box 899
Jefferson City, MO 65102
Dear Mr. Koster:
LENEXA, KS 66219
FEB 0 9 2015 OFFICE OF
I am pleased to report that the U. S. Environmental Protection Agency Region 7 has obtained agreement
from the West Lake Landfill Superfund site potentially responsible parties to gather additional data to
support identifying the nature and extent of Radiologically Impacted Materials contamination south and
west of the previously-defined boundaries of Operable Unit 1, Area 1. This Agency expects to receive
the work plan from the parties detailing this effort by the end of February, and the EPA will ensure this
work proceeds on an enforceable schedule. Bridgeton Landfill also provided written confirmation that
soil corings from the previous Phase 1 investigatory work have been maintained and can be made
available for the EPA’s proposed pyrolysis testing.
The EPA will continue to coordinate our efforts with the state of Missouri to ensure our respective data
collection activities at the Bridgeton Landfill and West Lake Landfill Superfund site support the mutual
goal of RIM identification and monitoring of the subsurface smoldering event.
Thank you for your and your staff’s excellent efforts to inform this agency about developments
connected with your office’s work on the Bridgeton Landfill. I have appreciated your timeliness and
Karl Brooks
WLLFOIA4312 – 001 – 0001708


2016-02-09 – EPA – Desk Statement and Update on West Lake Landfill Superfund Site Actions

Darryl Fears, Staff Writer Washington Post
1. Follow-ups with reporter
2. Desk Statement and Update provided to reporter
1. Follow-ups with reporter:
2. 02-09-2016 Desk Statement & Update on West Lake Landfill Superfund Site Actions
EPA is committed to working with the State of Missouri, as well as our federal partners with the U.S.
Army Corps of Engineers and the U.S. Geological Survey to implement a final remedy and other actions
to protect public health at the West Lake Landfill Superfund Site in Bridgeton, Mo.
Staff from EPA headquarters and Region 7 have met with the Just Moms STL members in person and
by phone, most recently this past Friday. We are in frequent contact to both listen to concerns and share
updates on progress at the site. We remain focused on numerous immediate and long-term actions
required to protect the community from the radioactive wastes contained at the West Lake Landfill in
Bridgeton, MO.
Our current priorities include:
Final Proposed Remedy
• EPA negotiated and finalized a modified Administrative Order on Consent Scope of Work
modification with the Potentially Responsible Parties (PRPs) in December 2015.
• PRPs will deliver a Remedial Investigation Addendum and subsequent Final Feasibility Study
for EPA’s review and approval this fall.
• Once the FFS is approved, EPA will finalize our evaluation of the 2008 remedy decision and
WLLFOIA4312 – 001 – 0001739
issue a draft final remedy for public review and comment.
Isolation Barrier Determination
• At the end of 2015, EPA announced its decision to require the installation of an isolation barrier,
along with other engineering measures, to ensure radiologically impacted material remains
separated from the subsurface smoldering event currently occurring in the adjacent Bridgeton
• EPA Region 7 made this decision with technical support from our Office of Research and
Development, the U.S. Army Corps of Engineers and in consultation with the Missouri
Department of Natural Resources and the Missouri Department of Health and Senior Services
throughout the fall and winter of 2015.
• Next Actions: EPA is negotiating the technical and legal details with the PRPs to perform this
work pursuant to an enforceable schedule. The state of Missouri continues its actions with the
owner of the Bridgeton Landfill to control the subsurface smoldering event and emissions.
Groundwater Investigations (new Operable Unit)
• EPA intends to investigate and address groundwater under a new Operable Unit (OU3). In late
2015 and January 2016, EPA had multiple discussions with the State of Missouri about future
groundwater work. Next Actions: EPA, with technical support from the U.S. Geological Survey,
is developing the scope of additional groundwater investigations to fully characterize the nature
and extent of contamination related to the site.
Surface Fire Unilateral Administrative Order for Removal Acton
• EPA issued a Unilateral Administrative Order (UAO) on December 9, 2015, for a time-critical
removal action to mitigate surface fire risks.
• The UAO requires the PRPs to:
o implement engineering measures to mitigate the risk of a surface fire within the boundary
of the West Lake Landfill site coming in contact with radiologically impacted material
(RIM) at or near the surface, and
o develop an incident management plan that will be used to coordinate with local
emergency responders.
• Next Actions: Work at the site begins the week of Feb. 8-12 and is expected to be completed
later in the spring of 2016. The PRPs provided EPA with a draft work plan and supporting
documents for constrnction of a non-combustible cover and an incident management plan. EPA
is currently reviewing these documents. A final report will be made available to the public.
Dialogue Framework
• EPA desires a more inclusive, transparent and fact-based dialogue with the community so we
have contracted with neutral facilitators Cindy Cook and Dain Maddox of Adamant Accord.
They have spoken with community members during this past week and continue to meet with
them in-person in St. Louis this week. These facilitators have substantial experience in
facilitating respectful and substantive dialogue regarding complex environmental issues. After
meeting with community members, they will report their findings at a meeting in St. Louis at the
end of Febrnary and then develop a framework for continued dialogue with this diverse group of
community members and leaders and EPA Region 7 staff.
WLLFOIA4312 – 001 – 0001740
WLLFOIA4312 – 001 – 0001741


2016-04-01 – EPA – West Lake – 2016-05 Monthly Report

West Lake Landfill SF Site OU1 Removal Action (Isolation Barrier) – EPA Region VII Monthly Report
Bill No.: 27078485 IAG No.: DW96958582 P2# : 444809 IAG Exp. Date: 30-Dec-2016
Reporting Period: From:
1 Apr 2016
2 May 2016
Brad Vann
Robyn Kiefer
1 OF 2
Work Performed
Narrative • Project Management: Completed monthly status report. Coordination with EPA and PDT.
• Began gathering data for Hixson FOIA request.
• Incorporated review comments into USACE QAP and finalized.
• Completed review and comment on Draft Particulate Emission and Final Radon Flux reports
from RPs. Provided comments to EPA.
• Provided list of potential questions for public availability session.
• Participated in discussions with EPA and the RPs regarding IB Design Guidelines and sand IB.
Meetings • 4/4/16 – Call with EPA/RPs regarding IB pre-design criteria
• 4/5/16 – Call with EPA regarding IB pre-design criteria
• 4/18/16 – Attend Public Availability Session & Public Dialogue meeting
Key Milestones

Projected Work
Narrative • Continue to support EPA on RP’s Risk Calculations
• Complete FOIA documentation gathering and review

Meetings • Attend CAG meeting in St. Louis
Key Milestones
• Complete review of IB installation work plans and designs when they are submitted
• Perform preconstruction observation effort.
• Risk: Delay of decision on IB location/risk and published date for completion of IB design
and beginning of construction increases risk of rushed design.
• Challenge: Advanced notice of dates when work plans/designs are expected to be submitted
by RP is necessary to ensure appropriate PDT resources are available to perform document
reviews in a timely manner. Advance notice of what USACE support (meetings, briefs,
reports) is required is key to ensuring quality of and ability to support.
• Challenge: $80K in additional funding received from EPA. Execution of activities not
included in original budget continues. With additional $80K in funding provided, projected
shortfall (considering original budgeted tasks and depending upon future Technical
Assistance tasks requested by EPA) is now estimated to be approximately $104.5K.
IAG Summary
USACE Contract Total Amend Total IAG Date
Reimbursable Direct Fund Cite
320,000 – 320,000 320,000 15-Apr-2014
80,000 – 80,000 400,000 8-Dec-2015
West Lake Landfill SF Site OU1 Removal Action (Isolation Barrier) – EPA Region VII Monthly Report
Bill No.: 27078485 IAG No.: DW96958582 P2# : 444809 IAG Exp. Date: 30-Dec-2016
Reporting Period: From:
1 Apr 2016
2 May 2016
Brad Vann
Robyn Kiefer
2 OF 2
Funded Current Bill Previous
EAC Notes
400,000 7,561.48 241,236.21 151,202.31 400,000
Note: This is an in-house action, therefore no contractor expenditures
Scope of Work Summary
Project Development Team
Name Org Phone
Robyn Kiefer CENWK-PM-M 816-389-3615
Paul Speckin CENWK-ED-EG 816-389-3592
Jough Donakowski CENWK-ED-ES 816-389-3993
Pat Conroy CEMVS-EC-GT 314-331-8430
Mary Delaet CENWK-ED-DM 816-389-3226
Dave Mueller CEMVS-EC-CF 314-331-8040
Bradley Vann EPA R7 RPM 913-551-7611
Electronic Deliverable 17 May 2016
Robyn Kiefer
Project Manager


2015-12-21 – USACE – Suggestion on WSJ response

From: Vann, Bradley
To: Mahler, Tom; Juett, Lynn
Cc: Hooper, Charles A.; Peterson, Mary
Subject: RE: Suggestion on WSJ response
Date: Monday, December 21, 2015 4:21:12 PM
Tom, I agree on sharing but certainly we would craft our own response. We’ve been sharing media
items related to West Lake or with the occasional overlap from FUSRAP with the Corps since their
IAs began (IB and remedy). It’s always for their awareness and ours to ensure consistency in
information. Especially since Robyn or Paul are often in the public, such as at CAG meetings
answering questions in sidebar discussions. Wouldn’t see this as an issue here any differently. If the
information needs to go to St. Louis, Robyn can also forward it on to Susan Adams in St. Louis.
Bradley Vann – Remedial Project Manager
U.S. Environmental Protection Agency
Superfund Division
Missouri/Kansas Remedial Branch
11201 Renner Blvd.
Lenexa, KS 66219
Phone: 913-551-7611
Fax: 913-551-9611
Cell: 816-714-0331
From: Mahler, Tom
Sent: Monday, December 21, 2015 3:44 PM
To: Juett, Lynn
Cc: Vann, Bradley ; Hooper, Charles A. ;
Peterson, Mary
Subject: Suggestion on WSJ response
I just wanted to let you all know that I talked to Jough Donakowski with the Kansas City USACE and
he confirmed to me that there is no clean up level established for lead 210 for the FUSRAP sites. He
even pulled up one of the St. Louis RODs to confirm.
I suggest that we forward the latest set of questions to Robyn and Jough just for their awareness. Do
we have a contact with the St. Louis USACE group. We might want to forward to that person as well.
I’m not saying that we ask them to response but I think they should know what this reporter is
Any thoughts?


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

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
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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
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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.
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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.
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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.
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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.
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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.
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USACE is available to participate in a comment resolution meeting upon request.
Robyn V. Kiefer
Project Manager
CC: Scott Young-CENWK-PM-E
Jason Leibbert-CENWK-ED-E


1981-10-05 – NRC – RMC Report – Site Visit – West Lake Landfill, St. Louis County, Missouri

liOoAr REPORT ON SITE VISIT – WEST LAKE LANDFILL ST. LOUIS COUNTY, MISSOURI (j 4°249268 Radiation Management Corporation Midwest Division 3356 Commercial Avenue Northbrook, IL 60062 (312)291-1030 TABLE OF CONTENTS Page LIST OF FIGURES i LIST OF TABLES ii INTRODUCTION 1 SITE CHARACTERISTICS 2 RADIOLOGICAL SURVEY 5 SUMMARY 9 APPENDIX A – Draft Site Survey Plan. Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 LIST OF FIGURES West Lake Landfill Aerial Survey External Radiation Survey, Landfill External Radiation Levels at 1 Meter Above Surface, Area 1. External Radiation Levels at 1 Meter Above Surface, Area 2 Location of Air, Water and Soil Samples I- •’) LIST OF TABLES Table I Radon Daughter Air Sample Results Table II Water Sample Results Table III Soil Sample Results INTRODUCTION Iii fI III I1I I. INTRODUCTION In September and November, 1980, Radiation Management Corporation (RMC) visited the West Lake Landfill in St. Louis County, Missouri. The purpose of these visits was to obtain sufficient data to allow RMC to prepare a detailed site radiological survey plan. This survey has been scheduled for spring 1981, and is designed to clearly define the radiological conditions at West Lake Landfill. All work has been performed under Letter Contract: NRC-02-20-034 (Radiological Evaluation of Burial Grounds) between RMC and the U.S. Nuclear Regulatory Commission (NRC). Two visits have been made to this site, the first of which occurred on Sep tember 24th. During this visit RMC met site personnel, discussed past, present and future site activities, performed a visual inspection of the site, and arranged for a second, more detailed site visit. This second visit took place November 12-14, 1980. The visit had been delayed over one month due to ongoing landfill operations in an area of interest to RMC. During the second visit, a series of preliminary radiological measurements were made. These measurements included external dose rates, grab air sample evaluations and water and surface soil analyses. The purpose of these measurements was to better define the location of buried material, and to demonstrate that no significant radiological hazards to site personnel exist at this time due to the buried material. As a result of these visits, two extensive areas of contamination have been defined on the landfill site. These areas are not normally occurpied, with one exception as noted in the report. Based on preliminary measurements, RMC concludes that radiation exposures to site workers are minimal. ri rt II. SITE CHARACTERISTICS Although extensive studies of the West Lake Landfill site characteristics have not yet been completed by RMC, the preliminary visits have yielded the basic site information provided below. The radiological history of the site has been traced through discussions with site personnel and review of documents obtained from the NRC, State of Missouri and St. Louis area firms and agencies. (A) Site Profile The West Lake Landfill is located on St. Charles Rock Road just west of the Tausig Road intersection in Bridgeton, MO. The site is about one (1) mile northwest of Route 270 and approximately 1*5 miles east of the Missouri River. It is located in a combined rural-industrial area, and is bounded on three sides by farm land and on the fourth by St. Charles Rock Road, beyond which are located several commercial and industrial establishments. The nearest residential area is a trailer park located about 3/4 of a mile southeast of the landfill. The site is approximately 200 acres and consists of a quarry, stone and limestone processing and storage areas, and several active and inactive landfills. The sanitary landfills are open to the public anytime during normal working hours. West Lake Landfill keeps track of entries for the purpose of assessing fees for disposal, however access is not controlled for any other purpose. J n Preliminary discussions with the Missouri Department of Natural Resources n confirm that at least a portion of the site is within the Missouri River I floodplain. In addition, alluvial ground water level appears to be very near the surface in this area. These considerations prompted the Missouri Geological I. Survey, in 1973, to propose to classify the site as hazardous under the then 1 1 current operating procedures. In addition, samples from perimeter monitoring wells taken in 1977 and 1978 indicated some movement of leachate into those i wells, based on chemical (not radiological) analyses. However, recent studies by the Department of Natural Resources indicate little or no surface or sub- I surface movement of leachate from the site. Leachate from the active sanitary _ landfill is collected in an observation well, pumped to trucks and transported • to a sewage treatment plant in St. Louis. At this time, there is no evidence | of significant ground water contamination, although geological reports indicate a potential for such problems. 1 p (B) Site Radiological Hisotry I In June 1976, the St. Louis Post-Dispatch printed a story alleging that radio3 active material had been erroneously dumped in the West Lake Landfill in 1973. The source of this material was identified as the Cotter Corporation, Hazelwood J . Missouri, Latty Avenue Site. I I An NRC investigation conducted by Region III in 1977 concluded that about q 7 tons of UsOe, contained in 8700 tons of barium sulfate leachate, had been mixed with about 39,000 tons of soil at Latty Avenue and the entire volume disposed of at the West Lake Landfill. The earlier study by the Post-Dispatch (1976) claimed only 9000 tons (presumably the barium sulfate leachate) had been buried, and that the remaining material had not been disposed of at West Lake. The Post-Dispatch alleged that the contractor hauling the dirt had admitted falsifying invoices for about 40,000 tons of soil. Discussions with the site superintendent, Mr. Vernon Fehr, have indicated that he recalls the specific shipments and could accurately locate the material. No records were kept of the disposals, but Mr. Fehr recalled that a large quantity of material was dumped, although he doubted it totaled 40,000 tons. A fly-over radiological survey (ARMS flight) performed in 1978 showed external radiation levels as high as 100 uR/hr in the area indicated by Mr. Fehr as containing the Latty Avenue material. In addition, this survey revealed another possibly contaminated area in a fill previously believed to be “clean”. Mr. Fehr is certain Latty Avenue material was not dumped in this second “hot” area. Apparently the second area is at least 10 years old, and no one had any idea what radioactive material might be present there. Figure 1 shows the results of the 1978 aerial survey. The area in the southeast fill is believed to contain Latty Avenue material, while that on the northeast boundary was previously unidentified. RADIOLOGICAL SURVEY ;r if r i I r i r r c r J III. RADIOLOGICAL SURVEY AND EVALUATION (A) Methods and Measurements 8 A series of measurements and samples were taken on and near the site over a three day period in November 1980. These measurements were designed to estimate I the extent of on site contamination, to evaluate possible existing radiological hazards to site personnel, and to make a preliminary assessment of the possible movement of material off site. Based on these measurements and known site characteristics, a detailed site survey plan has been developed to precisely define the site radiological conditions. External gamma dose rates were used as an indication of the extent of buried material. Measurements were made with a 2″ by 2″ Nal detector and an end window GM tube, at a height of one meter above ground. Nal count rates were converted to yR/hr exposure rates using a previously established factor for radium and daughters in soil. The GM tube was used only in areas where levels exceeded the range of the Nal detector. A series of particulate grab air samples were taken on site, in the areas of highest external radiation levels, and inside one building. These samples were counted for gross activity within one hour and again several days later. The short lived activity was attributed to radon daughters, and working levels were calculated from these activities. Water samples were collected from the leachate observation well, from two freshly dug monitoring wells at the site perimeter, and from a pond located just north of the site. These were analyzed for gross alpha and radium activity. Several surface soil samples were also collected. These came from the berm along the northwest boundary and were taken where the external radiation survey indicated possible surface or near surface activity. These have been analyzed for gamma activity in an effort to identify the contaminants in this previously unknown burial. (B) Results Figure 2 shows the West Lake Landfill and the two areas of buried material. As can be seen, the on-site ground measurements reveal that the initial fly over survey mislocated the actual contamination slightly. Both contaminated areas are located north and east of the aerial survey locations. The burial identified as Area 1 is located along the southern edge of the site access road, extending from the eastern boundary of the fill to the recently constructed parking lot. The total area of readings above background is about 112,00 ft2(2.6 acres). Two areas where levels exceeded 100 uR/hr were identified, each about 7500 ft2(0.2 acre each). The highest levels measured in Area 1 were about 200 uR/hr. A detail of this area is shown in Figure 3. The second burial, Area 2, is shown in Figure 4. This area extends along the Northwest boundary of the site, starting at the boundary berm and extending into the site as far as 300 feet in some directions. The total area of readings above background in this case is about 360,000 ft2(8.3 acres). This estimate assumes that contamination extends under existing stone and gravel piles, where readings could not be made. The highest levels recorded were 5 mR/hr, along the berm in a normally unoccupied area. The fill containing Area 1 is. known to extend to a depth of 30 to 40 feet. The radioactive material is presently covered with an estimated 6 feet of fill, and the operator is planning to cap and seed it shortly. This fill is known to be essentially a sanitary fill, containing no industrial waste or construction or demolition materials. The fill is located over a quarry, and the fill leachate is collected from the quarry floor via a sump well located in the northeast corner of the landfill. Approximately 50,000 gallons of leachate are collected each day and sent to the Metropolitan St. Louis Sewer District Bissell Point Plant. The landfill containing Area 2 is older and less is known about it. However, it is certain that large objects such as building rubble are buried there, along with quantities of rocks from the quarry. In addition, it appears possible that some toxic chemicals (PCB’s, dioxane, etc.) may be buried here. This fill extends to 30-40 feet and is placed on top iof existing land.. Ground water monitoring wells are located near this fill, at the property boundary. Grab air samples were taken in five locations during the site survey. Gross activities were counted 35 minutes after sampling and working levels calculated using a modified Kuznetz method. Samples were taken at the location of highest external radiation levels in an effort to represent the worst case conditions. Measured levels ranged from 0.014 WL to 0.038 WL. Results are shown in Table I. A total of four water samples were collected. Two were taken from monitoring wells dug by the Missouri Department of Natural Resources in October, 1980, one from the on-;site leachate observation well and the final from a pond near the site. These sampling locations are shown in Figure 5, and the analytical J results shown in Table II. Monitoring Wells 3 and 4 were sampled since they are in the general direction of movement of ground water from the landfill. In general, all off-site levels are within EPA drinking water standards (al though these standards do not apply here) and there is no evidence of conta minant movement through water off site for these preliminary measurements. Soil samples were taken at three locations in and around Area 2, in an effort to identify the contaminants in this area. These were surface samples, taken at sites where external radiation measurements indicated the possibility of surface activity. One sample was taken at a hot spot on the berm, a second from loose dirt where a road has been dug through the berm, and a third from the field adjacent to the site berm. Results are listed in Table III and show that elevated concentrations of uranium and daughters exist in soil on the landfill (Area 2) site. No unusual levels were detected in the off-site field soil, and no isotopes other than naturally occuring radionuclides were detected in any of the samples. Activities in the “hot spot” sample were so high that quantitative determinations using the initial analytical techniques were not possible, and further analyses will be required. SUMMARY IV. CONCLUSIONS Two areas of apparently buried contamination have been identified. The first (Area 1) is located immediately south of the landfill access road and comprises about two (2) acres. The second (Area 2) is along the northeast boundary and totals about eight (8) acres. Material in Area 1 is believed to have come from the Latty Avenue site, and would therefore contain uranium ore (UsOe) in barium sulfate leachate. Material in Area 2 is also known to contain uranium and daughters, and is therefore similar to Latty Avenue residues, although the origin of this material cannot be substantiated. Several normally unoccupied areas of the landfill have external radiation levels in excess of 20uR/hr, the target criteria for remedial action. Working levels in these areas may approach MFC for unrestricted areas, based on very limited sampling data. There is no initial indication of movement of material via ground water off site. One occupied facility has been located on an area where material has apparently been buried. This is the Shuman Equipment Service Building on the north section of the landfill. External exposure rates inside the building range from 15 to 50yR/hr, while radon daughter activities are estimated to be near MFC for unrestricted areas under some circumstances. Results of this preliminary site visit have been used in the development of the Draft Site Survey Plan which appears in Appendix A. i’:-r FIGURES AND TABLES •’ t I I 1 I tdttMBB 0 4OO 800 1200 1600 2000 FEET 0 100 200 300 400 500 600 METERS I-HTIMATHD LANDFILL OUTLINE wnnr LAKE LANOFIU AERIAL SURVEY ISOPLETHS onoss COUNT CONVERSION SCALE OAMMA EXPOSURE RATE* LETTER 1 m LEVEL LABEL JliR/tnl A -• C 8-10 o 10- 13 C 13-17 r 17-24 o 24*33 M 33-49 1 4S-82 J •2-84 K 84-11* ritio.or-viiw AT «o m ALIITUDI AND IXTRAPOLATCO TO THC 1 m LEVEL. INCLUDES J.7 fiH/kr COSMIC RADIATION. FIGURE 2 DOERNAL RADIATION SURVEY, LANDFILL A FIGURE 3 1 1 EXTERNAL rtADIATION LB/ELS AT 1 HFTER ARWF qiRFAPf. All readings are in pR/hr. Bkgd. 10 pR/hr. pR/hrv AREA 1 25 ft. x 25 ft. grid pattern L] J 1 • 1 Ali readings are viR/hr. BXgd. = 10iiR/hr. RADIATION LfVELS AT 1 rtlER ABWE SURFACEN AREA 2 5 >! >lOO(jR/hr. ^ ^ >SOOyR/hr. 30 ft. x 30 ft. grid pattern * j FIGURE 5 <*> LOCATION OF AIR, WATER AND SOIL SAMPLES ca Table I Radon Daughters Air Samples Results Sample1 Location Area 1 near road Date S Time Nov.13,8:45am ConditionsDry, wind S-lOmph60*F Working Level 0.017WL Area 1 over highest external level Nov.13,10:30am Dry, wind S-lOmph62 °F 0.014WL Area 2 over highest external level Nov,13,2:45pm Dry, wind S-lOmph70°F 0.019WL Area 2 over suspected Nov.13,3:07pm Dry, wind S-5mph 0.038WL surface material 70°F Inside Shuman Equipment Nov.14,7:35am Bid sealed overnight 0.031WL Service Bid no ventillation Table II Water Samples Collected in October and November 1980 – Results Sample # Location Leachate Observation Well Sample Well #3 Sample Well #4 Settling Pond (1) RMC (2) ANL (3) Missouri DNR Activity Gross a < 7.3 Gross 6 80121 Ra-226 1.0910.29 (2) Gross a 15.612.6 pCi/1 (2) Gross 6 41.314.3 pCi/1 Ra-226 0.610.1 pCi/l(3) Gross a 2.910.7 pCi/l(2) Gross B 7.612.0 pCi/l(2) Ra-226 0.510.1 Ci/1^ Gross a < 2.9 Gross B < 26.3 Table III Soil Sample Results Sample Location Activity pCi/g(dry) Area 2 over suspected Pb-214 PresentM surface material Bi-214 Ac-228 Pb-212 U-235 U-238 Th-227 Ra-226 Th-228 Roadway from berm to Pb-214 4.5EI ± 4, 5EO offsite field Bi-214 3.3EI ± 3, 3EO Ac-228 1.2E1 ± 6.3E-1 Pb-212 3.5E1 ± 3.8EO U-235 1.6E1 ± 1.6EO Th-237 2.3E1 ± 3.0EO K-40 1.3E1 ± 2.3EO Ra-226 3.3E1 ± 3.3EO U-238 Present(2) Off-site field Bi-214 4.1EO ± 4.1E-1 Ac-228 9.6E-1 ± 4.3E-1 U-235 1.5 EO±3.8E-1 U-238 Present(2) K-40 2.2E-1 ± 8.3E-2 Ra-226 4.1E1 ± 4.1E-1 Th-228 1.4E1 ± 5.2E-1 Pb-214 5.3E1 ± 5.3E-1 (1) Activity too high for quantitative determination using initial counting method. Levels are greater than 100 pCi/g for Bi-214 and Pb-214. (2) No quantitative determination of U-238 was made. 'r j: _ f f -.. DRAFT SURVEY PLAN FOR THE WEST LAKE LANDFILL Draft Survey Plan for the West Lake Landfill I. INTRODUCTION Based on preliminary site visits and predetermined survey criteria, a comprehensive radiological survey plan for the West Lake Landfill site has been prepared in draft form for review. The objective of this survey is to define the present radiological status of this site. Based upon the survey results, the Nuclear Regulatory Commission will perform engineering evaluations to determine if remedial actions are required. To this end, survey measurements are designed to determine the identity, concentration and extent of contaminants on site, and whether these contaminants are moving off site. Several types of measurements are required for this survey. These proposed measurements are listed below and described in the following paragraphs. Survey Methods A) Measurement of External Gamma Exposure Rates and Beta-Gamma Dose Rates B) Measurement of Surface Radioactivity C) Measurement of Subsurface Radioactivity D) Measurement of Water Radioactivity E) Measurement of Airborne Radioactivity Al II. SURVEY METHODS (A) Measurement of External Radiation Levels The two areas of contamination which have been previously identified will be gridded and surveyed for both gamma radiation levels at one meter above the surface and beta gamma levels at the ground surface. The basic pattern at each contaminated area will be survey blocks defined by a 10 meter grid system. External gamma levels at one meter will be recorded at each grid point (i.e. at each intersection of two grid lines). Initially, precise gamma measurements at a few specially selected grid points will be made with sensitive Tissue Equivalent lonization Chamber System. At the same time, Nal scintillation detector measurements will be made and a conversion factor for the Nal count rate versus yR/hr established. Once this factor is confirmed, the scintillation detector will be used for all grid measurements at relatively low exposure rates. For higher rates, an ion chamber type portable survey instrument will be used. At each grid point, an end window G-M tube will be used for surface measurements. An open and closed window reading will be made at 1 cm, and the ratio of the two used to indicate surface contamination. A more closely spaced grid (i.e. 5 meter) will be employed to define known hot spots or where evidence of non-representativeness is presented. A2 (B) Measurement of Surface Radioactivity Based on the external surface measurements, surface soil samples will be collected for analysis. This sampling is not considered likely in Area 1, since it is known that buried radioactive material has been recently covered with sanitary fill and capped with "clean" dirt. Therefore, surface deposits are highly unlikely in this area, and were not detected during the preliminary site visit. However, preliminary measurements in the older fill area (Area 2) indicated the possibility of surface deposits, and these will be investigated. Samples to a depth of a few inches would be collected and analyzed. Surface drainage ways will be evaluated wherever the possibility exists that radioactive materials have been carried or washed away from original storage or burial locations. Again, the most probable area of concern is Area 2, where the probability of surface deposits exists and where the dike enclosing the landfill on the north and west is failing. Here, water may be seeping through these faults. Surface drainage is not apparent in the vicinity of Area 1, with the possible exception of some drainage along the landfill access road. Vegetation on site consists only of grass and common weeds. Off site, crops are grown on farm land immediately north and west of the site, adjacent to Area 2. Since the possibility of contamination exists here, crop samples will be collected where indicated by surface measurements. A3 (C) Measurement of Subsurface Radioactivity Since it is known that most, or all, of the radioactive material at the West Lake Landfill has been buried, extensive subsurface monitoring and sampling will be requried. This activity will consist of drilling and lining holes in and around the known contaminated areas. The purpose of this activity is to determine the depth and lateral extent of subsurface deposits. The principle measurement method will be in situ gamma spectroscopy. Each hole will be "logged" using an intrinsic germanium (IG) detector coupled to a computer based multichannel analyzer. Field analyses can then be made, both qualitatively and quantitatively, thereby eliminating time consuming laboratory analyses and expensive core sampling of each hole. Measurement intervals may range from 6" to 24", depending upon factors such as hole depth, activity, etc. An occasional core sample will be taken to verify the in situ measurements and to confirm the presence or absence of non-gamma emitting nuclides such as Th-230. The exact number and depth of holes cannot be determined at this time, since these will depend to some degree upon the extent of subsurface contamination and the characteristics of the fill. Initial estimates would be based on external measurements made during the preliminary site visit. These measurements indicate that Area 1 is about 2 acres and Area 2 about 8 acres. It is known that material in Area 1 is covered with about 6 feet of sanitary fill and clean dirt. Little is known about the material in Area 2, except that this is an industrial fill with large, solid objects such as rocks, boulders and building rubble. A4 Based on this information, it is believed that drilling and sampling will be relatively simple in Area 1. It is possible that as few as 10 bore holes would define this contamination. It is likely that more will be required for Area 2. (D) Measurement of Radioactivity in Water Wherever possible, water samples will be taken from the bore holes. Additional leachate samples will be collected, along with off site pond water. Samples will also be collected from existing site monitoring wells and those which the Missouri Department of Natural Resources might dig. Run off water will be collected is possible. There are no flowing streams which border the site. (E) Measurement of Airborne Radioactivity Measurements will be made to determine whether the material buried on site is a source of airborne radioactivity. The isotopes of concern are Ra-226, Ra-224 and/or Ra-223, which decay to Rn-222, Rn-220 and Rn-219. This may result in the emanation of radon from the soil, and movement of radon and daughters off site. These measurements will be designed to determine Rn flux emanation as a source term for off-site dose calculations. Additional on site Rn daughter measurements will be made to verify preliminary working devel (wl) determinations. Radon flux measurements which are to be related to off-site dose calculations are of no value for Rn-219, due to its very short (4 sec) half-life. Therefore, only the long-lived daughters are of concern for off-site exposures. In addition, if the parent (Ra-223) is not within a few millimeters of the surface, it is not likely to emanate into the atmosphere. AS Due to these considerations, only Rn-222 and Rn-220 fluxes will be measured. The principle measurement technique will be to collect a filtered gas sample from an accumulator and count it in a radon gas analyzer (scintillation cell). Sequential alpha counting, starting immediately after sampling, will allow separation of Rn-222 from Ra-220 (if present). Numerous samples will be taken from various locations during the survey period, in an effort to reduce the effect of fluctuations between individual measurements due to varying meteorological and soil conditions. If Rn-219 proves to be of concern, its daughter can be determined by collection of a particulate filter paper and subsequent gamma counting. This sample „ can be collected from the accumulator simply by circulating the accumulator * air through a filter and back into the accumulator. The sensitivity will be | limited by the relatively short half-life of the daughters and small volume of the samples. Alternatively, the presence of Rn daughters can be determined I by a or v spectroscopy of high volume particulate samples. 1 However, Rn daughter measurements in the presence of all three Rn parents are difficult or complex to measure in the field, even with spectrometry. The proposed method is for total working levels to be measured directly, from the integral of all short-lived radon particulate-attached alpha emitting daughers. Since the purpose here is to determine exposure, a series of measurements at several locations will be made during the 2 month field project to determine average concentrations. This will be done using simple manual techniques and external counting. A6 III. SURVEY INSTRUMENTATION AND EQUIPMENT The specific instrumentation employed may vary slightly with survey require ments, nevertheless certain items are known to be required and have been dedicated to this survey. These are described below. External gamma exposure rates can be measured precisely to 1 or 2 uR/hr with the Tissue Equivalent lonization Chamber system, which consists of 16 liter Shonka chambers and Keithley vibrating capacitor electrometers. Portable survey instruments include Eberline and Johnson rate meters, sealers, GM tubes, alpha scintillators and Nai detectors and Victoreen ion chambers. Sample gamma analysis will be performed with a 20cc intrinsic germanium (IG) detector and Tennecomp TP-50 computer based MCA system. Bore hole logging will be accomplished with a second IG detector, with a specially adapted cryostat and dewar assembly, and a Tracer-Northern 1750 MCA system. Radon gas will be counted in an EDA Radon Gas Analyzer. If alpha spectro scopy is required, a system such as the Tennelec TC 256 will be used, together with one of the MCA's. This instrumentation, along with various laboratory items such as ovens, drying lamps, sample containers, balance, etc.'will be placed in two mobile vehicles for movement on site. Since one goal of this survey is to determine if remedial action is required, it will be necessary to be able to measure levels established by the NRC as target criteria for remedial action. The lower limits of detection (LLD) have been defined as 20% of target criteria and are shown below. A7 Soil Contaminants Nuclide Target Criteria LLD Ra-226 5pCi/g IpCi/g Total U 15pCi/g 3pCi/g U-238 30pCi/g 6pCi/g U-235 30pCi/g 6pCi/g Th-232 5pCi/g IpCi/g Th-230 15pCi/g 3pCi/g (Criteria for Th-232 assume equilibrium with daughters) Water and Airborne Contaminants Nuclide Target Criteria LLD All MFC Unrestricted 20% MFC External Radiation Nuclide Target Criteria LLD All 20 uR/hr 4yR/hr This survey plan has been designed to provide rapid field evaluations of the radiological status of the West Lake Landfill, and to provide the data needed to determine if remedial actions are necessary. Initiation of this survey is scheduled for early spring, 1981. A8

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