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

Page 1 of 1 . ''\ Final Groundwater Monitoring SAP and Responses to Comments _ ;~-} ~:ul... View Document


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

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

07111 3.. 0

OL.t 01


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

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

To: Dan Gravatt/R7/USEPA/[email protected]

Cc: “Victoria Warren” , “Paul Rosasco”

, “Randal Bodnar” , “Shawn

Muenks” , “Dave Vasbinder”

, “Jessica Merrigan”

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

Thanks, Diana
From: Diana Howarth [mailto:dhowarth(g)herstassociates.coml Sent: Monday, January 09, 2012 11:30 AM To: Dan Gravatt ([email protected]) Cc: Victoria Warren ([email protected]hrtc.net); Paul.Rosasco ([email protected]); Randal Bodnar
([email protected]); Shawn Muenks ([email protected]); Dave Vasbinder
([email protected]); Jessica Merrigan ([email protected])
Subject: Bridgeton December 2011 Monthly Progress Report:
Norfolk Monthly Report Final email distribution . Eric Ballenger. i lli il l

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

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

Thank you,
Diana Howarth
Herst & Associates, Inc.

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

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


2012-07-06 – MDNR requests special consideration given to fugitive dust control

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

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

Dan and Shawn,

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

Also enclosed are responses to the EPA and MDNR comments.

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


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

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

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


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

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

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

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

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

Thanks, Paul

From: Muenks, Shawn I”mailto:[email protected]
Sent: Tuesday, July 17, 2012 11:43 AM
To: Rosasco, Paul [email protected]’)
Subject: West Lake Landfill groundwater sampling prep


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

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

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

P.O. Box 176, Jefferson City, MO 65102-0176


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 West Jefferson Avenue, Suite 406
Lakewood, Colorado 80235
Dear Mr. Rosasco:
The U.S. Environmental Protection Agency (EPA) is providing comments for the reviewed
document submittal titled “Bridgeton Landfill Thermal Isolation Barrier Investigation Phase 1 Report,
Bridgeton, St. Louis County, Missouri” prepared by Feezor Engineering, Inc. and P. J. Carey &
Associates, in conjunction with Engineering Management Support, Inc. and Auxier and Associates, Inc.
The cover letter on the document was dated December 19, 2014 and submitted to EPA in accordance
with the Administrative Order on Consent, EPA Docket No. VII-93-F-0005, paragraph 51 to complete
characterization of radiologically impacted material (RIM) at OU 1, Area 1.
Majority of the general comments enclosed were previously discussed at our joint technical
meeting held on January 23, 2015 and agreed upon by the responsible parties in their response letter to
the EPA, dated January 27,2015. Other additional comments are also provided, which are either general
in context or document specific per the EPA’s complete review of the December draft report. All
comments should be directly addressed through written correspondence to the EPA and can be discussed
by teleconference or email if needed to expedite response. Once approved, the Agency will request a
revised work plan submittal for review and approval. If the comments submitted by the EPA today
cannot be timely addressed before the next iteration of the draft work plan is submitted for Agency
review (i.e., they cross paths), it is understood that they will be addressed, and where applicable,
incorporated prior to submission of a revised final work plan. The EPA also reserves the right to submit
further comments on the pending iteration of draft work plan submittal.
Based on our February 18 and March 2, 2015 follow up teleconferences and as discussed above,
comments that are relevant to the next phase of soil characterization and fieldwork activities should be
incorporated into the revised work plan. Once the EPA approves the revised document, the responsible
parties will proceed in accordance with the work plan schedule to complete this additional work. At the
completion of fieldwork activities this summer, any enclosed EPA comments related to reporting data
results should be incorporated within a comprehensive report that contains data from every phase of
RIM characterization fieldwork performed to date and following the conclusion of the final phase this
If you have any questions regarding this document, EPA’s comments or would like to discuss
other issues, please email or contact me at (913) 551-7611.
WLLFOIA4312- 001 – 0050546
cc: Shawn Muenks, MDNR
Robyn Kiefer, USACE
Brad Vann
Remedial Project Manager
Missouri/Kansas Remedial Branch
Superfund Division
WLLFOIA4312- 001 – 0050547
General Comments:
I. All field notes and photos should be attached to the comprehensive report or added as
2. The Data Quality Objectives in the pending revised work plan must differentiate the
radiological contaminants from a radioactively impacted material (RIM) source versus a
non-RIM/naturally occurring or other sources. Please revise the DQOs accordingly.
3. The upcoming investigation is dependent on the historical photographs to determine
sampling locations. It is EPA understanding from our last teleconference that an aerial
survey of the landfill was taken in I973 and available, and was verbally requested during
our last telephone conference. Therefore, please provide copies of this photograph and/or
stereographic pairs, along with any other relevant or referenced historical information to
EPA for supporting the rationale behind sample locations and or historical placement of
RIM. This may be provided with the revised work plan or as a separate submittal to EPA.
4. The comprehensive final report must include a conclusion and recommendations section.
In addition, document figures warrant revision that accurately depict and incorporate
relevant site information both historical and based on recent sampling results around
OUI, Area I, as some of the historical RI boundaries are now obsolete.
5. Supplemental sampling needs to identify a clear process in the work plan, or reference an
existing one, for decision making while in the field and further investigation if
concentrations of RIM are found in the pending expanded investigation locations without
requiring another mobilization.
6. All work related documents (e.g., work plans, reports, deliverables, etc.) from this point
forward must include a schedule of primary tasks/activities/milestones with along
projected dates for their start/completion and where applicable identification of any
critical path items.
7. It is EPA’s intention to collect split samples during the next round of fieldwork for
submission of TCLP standard and/or pyrolysis analysis. Soils identified as containing
RIM associated with the radionuclides historically dispose of at OUI Area I, need to be
made available to EPA personnel or their field representatives. This would include and is
not limited to existing RIM soils samples collected during the prior round of
characterization that are currently maintained onsite.
8. Per the technical conference with EPA personnel on January 23, 20I5 and consistent with
the January I5, 20I5 letter sent by EPA, RPs need to perform additional bounding
sampling near elevated locations to determine whether or not contamination extends
outside these areas. This includes establishing a no RIM boundary and performing
additional sampling southward towards the North Quarry area and west of the original
boundary of Area I to determine the extent of RIM in this area. Ideally samples could be
placed per that discussion to ensure best coverage, support the existing data, and in
WLLFOIA4312- 001 – 0050548
accordance with risk-based statistic, given the heterogeneity of how RIM was placed in
the landfill. As previously discussed, there’s a lot of value in using historic imagery to try
to identify areas of potential concern. Where historic imagery is utilized it must be cited
to help support sampling locations, and where available copies provided in reports to
justify sampling locations (see General Comment 3).
9. For reporting purposes and work after the investigation, EPA recommends the RPs revisit
some assumptions of the Baseline Risk Assessment using this new data and any future
collected data as part of the RIM characterization to ensure site conditions are still similar
to what has been previously assessed. It’s possible to calculate the total amount of
Thorium-230 disposed of in 8,700 tons of waste material, this value is ~1.5E15 pCi.
Using the UCL95 values provided in the BLRA you arrive at a total accounted for
activity of 1.3E15, or about 90% of the material is accounted for, which is probably a
pretty good estimate.
Conversely, if the average value is used, you arrive at an accounted for activity of only
7.5E14, which is roughly 50% of the material…
With this new data the material present appears to be in a larger area, at least at Area 1,
and present in thicker layers, and/or is present at higher activities than what was assumed
in the BLRA. Therefore, this information will need to be reevaluated in the revised BRA
prior to amending the Supplemental Feasibility Study.
Specific Comments:
1. Section 1, pg. 7, Paragraph: Report states, “Although these criteria identify levels that
would allow for unrestricted use of the site, these criteria have no relationship to riskbased
criteria for a solid waste landfill or levels that would be protective if an SSE were
to occur in these materials.” The final report needs to state that risk-based criteria for this
site has not been determined, therefore, comparison to unrestricted use criteria is being
2. Section, Page 8, Paragraph 4: Report states that monthly groundwater levels
measured in 2000 and 2005 indicated that groundwater generally occurs only in the
underlying alluvium at or below the base of the landfill material. As such, recent
groundwater levels need to be reviewed and also cited in the final report to indicate
whether current data shows the groundwater level is still at or below the depth of waste;
or could reference section 7.2 to indicate that 2013 investigation results confirm that
current conditions still indicate fluid levels at or below the base of the landfill material,
which is consistent with the 2000 and 2005 groundwater levels.
3. Section 1.1.3, Page 9: This paragraph references the proposed thermal isolation barrier
location. Two alignment alternatives have been proposed. The final report will need to
include a figure or figures to indicate which IB location is being referred.
WLLFOIA4312- 001 – 0050549
4. Section, Page 9, Paragraph 2: Report states laboratory analysis of surface soil
samples (the upper 6 inches) detected radionuclides at levels above 5 pCi/g above
background at boring locations WL-106 and WL-114. Figure 2 only shows WL-106B. In
the final report, please clarify if this is the same well as WL-1 06 or not and correct if
5. Section 3.2.5, Page 17, Paragraph 2: In this paragraph, and at several other locations in
the document, it is stated that a screening value of 200-250 cps was used to identify
potentially elevated gamma readings. Be sure to include an explanation on how that
screening level was determined in the final report.
6. Section 4.2.1, Page 24, Paragraph 2: Last sentence states, “Samples were then
geologically logged, photographed, scanned for radiation, and samples for radiological
analyses were selected.” Expand this section in the final report to indicate how the
samples for radiological analyses were selected and how the number of samples selected
were determined or reference section 4.4 where further discussion is provided.
7. Section 4.2.2, Page 25: Section identifies sonic borehole locations selected if GCPT data
indicated the potential for RIM (1-2, 2-2, 5-3, 1C-6). Also states 8-1 and WL-119 were
selected to further understand slightly elevated GCPT sounding results. Clarify whether
the “if” needs to be changed to “because”, as “if” implies the borings were pre-selected,
then amend the text in the final report accordingly. Also, there is no mention of why
sonic boreholes 12-5, 13-3, 13-6, 14-2, 14-4, 14-5, 14-7, 15-2 (& 2A), 16-3, and 16-6
were drilled, which warrants addressing in the final report.
8. Section 4.4, Page 27, Paragraph 1: States “Intervals with elevated gamma readings were
selected for offsite laboratory analysis.” Additional text is needed in the final report to
clarify what constitutes an “elevated gamma reading”. Also, clarify if the samples taken
from the interval were from locations that exhibited the highest 2 gamma reading in each
interval. Additional text also needs to discuss if samples taken where there were no
elevated gamma readings, and if an attempt was made to collect samples above and
below the elevated readings to identify if the vertical extent of RIM had been identified at
those locations.
9. Section 5.3.5, Page 32: This section does not provide narrative summary of results of four
gas monitoring as the other sections do. A results summary statement needs to be
included in this section within the final report, and backup data provided and referenced
in an appendix.
10. Section, Page 33: A statement must be included in the final report how alpha
readings above 20 dpm/1 00cm2 and beta-gamma readings above 1000 dpm/1 00 cm2
were determined to be contaminated. This comment also applies to sections and, which use this same reference level.
11. Section 6, Page 34, Paragraph 1: States ” … based upon review of historic images, it was
determined during the investigation that a deeper quarry existed in the southeast portion
of OU 1 Area 1 that could be problematic to the barrier design.” The final report must
WLLFOIA4312- 001 – 0050550
clarify where you are referring to Bridgeton Sanitary LF North Quarry, and if so, should
also state that it doesn’t appear to be some newly identified feature.
12. Appendix C3 & Figure 6: Sonic downhole borehole log and core scan shows columns for
samples collected and shipped. Figure 6, sonic boring 1-2 shows a sample was collected
at depths of 8-9′, 18-19′, 20-21′, 22-23′, 24-25′, 28-29′, 33-34′, 38-39′, 39-40′, and 40-41′
and results were provided. However, the sample shipped box on the log was only
checked for samples 28-29′ and 39-40′. This discrepancy warrants documenting in the
final report and demonstrates the absolute need for boring logs to be rechecked,
especially in the field, for accuracy to ensure they are complete and correctly reported.
13. Figures General Comment 1: The final report needs to include another set of figures that
contain all results, including past sample results and recent sample for each radionuclide
to facilitate a better understanding of RIM distribution in Area 1. Historically
interpolated boundaries also merit updating from these additional figures as they have
been disproven.
14. Figures General Comment 2: If the data is available, it needs to plot the results of
samples below the depth of contamination, or the CPT gamma results plotted for the
interval below the highest results. For example, it’s helpful at location Sonic 1-2 to see
that the interval immediately below the high sample was non-detect, whereas at Sonic 1 C-
6 it’s not immediately clear if a “clean” sample was ever identified. It would also help to
color code or otherwise identify borings where elevated material is found. While the
posting plots are useful, it’s hard to get a good visual summary of the data as presented,
and needs to be revised accordingly in the final report.
15. Figure 2: Figure references “elevated” and “non-elevated” historical boundaries. All
figures in the final report need to be changed to quantify the “elevated” levels, and areas
of surface RIM be clearly identified.
16. Figure 14: The profile shows GCPT-12 hit alluvium at elevation 442. However, on the
1971 aerial it appears the elevation at this location is ~432 along the edge of what
appears to be a lagoon and is where the 1C-12 is located. In a 1973 aerial it appears the
lagoon is essentially filled in, which means it is possible that what is being classified as
alluvium is actually spoils from the quarrying operation or some other type of fill.
Review this information accordingly, clarify and if necessary revise in the final report.
17. Cross Sections: Revision showing the lab results for sonic borings in each cross section at
each depth a sample was collected would significantly improve clarity and avoid possible
reviewer error. Cross referencing between logs, downhole scans, and lab reports is
confusing and time-consuming and can lead to error; thus, having as much of the
pertinent data at one glance would aid in understanding the contaminant distribution.
Please revise accordingly, in the final report.
WLLFOIA4312- 001 – 0050551


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

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


2016-05-23 – EPA – West Lake – SED Further sediment sampling and storm water flow information

From: Mahler, Tom
To: [email protected]
Cc: Vann, Bradley; Barker, Justin; Gieseke, Andrew; Juett, Lynn; Stoy, Alyse
Subject: Further sediment sampling and storm water flow information
Date: Monday, May 23, 2016 1:55:00 PM
Attachments: QAPP for West Lake Landfill – Sediment Sampling_Revision 02.pdf
As you are aware, three sediment samples were collected on January 6th, 2016 as part of
the Additional Characterization work for Area 1 and Area 2. For each of these three
samples, EPA collected splits. After reviewing the validated data from you and your clients
in addition to the EPA split samples data (see attached), EPA has determined that SED4
and EPA’s split for this sample (SED 4-EPA DUP) contain radionuclides which meet the
definition of RIM for OU-1 of the West Lake Landfill site. Specifically the Combined
Thorium concentrations for SED4 and SED 4-EPA DUP are 16.16 pCi/g and 20.63 pCi/g
respectively which exceeds the established limit of 7.9 pCi/g.
Additionally, EPA provided a QAPP for the collection of additional sediment samples which
has since been updated. I have attached an updated version of this QAPP which includes
an updated figure that depicts the previously collected sediment samples as well as new
proposed sample locations. Specifically the QAPP requires the collection of additional
sediment samples located between SED4 and the north corner of the West Lake Landfill
property along the drainage pathway for storm water situated between the OU-1, Area 2
fence line and St. Charles Rock Road.
EPA Region 7 requires further characterization of this portion of the landfill property as
soon as access is attainable and recent storm water recedes. We are requesting that the
PRPs perform a gamma walkover survey to determine if there are any elevated areas of
gamma radiation for which biased sediment samples could be collected. In addition, EPA
Region 7 will require 5 additional sediment samples be collected approximately every 100
feet between SED 4 and the north corner of the landfill property (see attached updated
figure from the QAAP). One of these sample locations will require the collection of a
duplicate sample for data quality purposes. Finally, because of the recent storm events
which have inundated this area with storm water, the collection of an additional sample
from the SED4 location will also be required. EPA will collect these samples or will collect
100% split samples. This work is to be performed during the week of May 23, 2016. If a
gamma survey cannot be performed the week of May 23, 2016, because of residual storm
water or excessive vegetation, it may be delayed until conditions change. Please move
forward with collection of the sediment samples regardless.
Finally, EPA is also requiring the PRPs to provide definitive information on the locations of
storm water drainage that runs along the east side of the West Lake complex located
between the norther portion of the Bridgeton landfill, OU-1 Area 1, and St. Charles Rock
Road. Please ensure to include information associated with the four drop boxes and/or
inlets located immediately North and South of the landfill entrance road, as well as whether
there is a connection between the stormwater collection pond(s) in the northeast portion of
the West Lake complex, and immediately north of the complex and the sediment pond to
the north of the complex and east of St Charles Rock Road. Please provide this
information by Wednesday, May 25, 2016
Please let me know if you have any questions about these proposed sampling plan. Also,
please coordinate with me on the timing for collection of the sediment samples.
Tom Mahler
On-Scene Coordinator
US EPA Region 7


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

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

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