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

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2015-11-20 – USACE – EPA – West Lake Landfill – ISOLATION BARRIER ALIGNMENT ALTERNATIVES ASSESSMENT Amendment 1

U.S. Army Corps of
Engineers
ISOLATION BARRIER
ALIGNMENT ALTERNATIVES
ASSESSMENT
Amendment 1
WEST LAKE LANDFILL
BRIDGETON, MISSOURI
FOR
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
1.
2.
3.
4.
5.
6.
7.
3.1
3.2
3.3
4.1
4.2
4.3
4.4
4.5
4.6
4.7
4.8
4.9
4.10
4.fl
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
Tables
Table 1 Relative Comparison of Alignment Alternatives …………………… ll
Table 2 Options to Address Remaining RIM ………………………………… 21
References ………………………………………………………………………… 25
1
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.
10
WLLFOIA4312- 001 – 0055690
Factor
Excavation
Volume
Odor Potential
Bird Hazard
Potential
RIM
Remaining
South of
Barrier

Potential for
Future SSE
North of
Barrier
On-Site Safety
Table 1: Relative Comparison of Alignment Alternatives
Alignment 1
Least volume than
other
aligmnents~50,000
CY±
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
Alignment2
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.
11
Alignment3
Approximately twice as
much as Aligmnent 1
~95,000 CY ±.,.
significantly less than
Aligmnent2
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
encountered.
ThermaliB
Least amount of
excavated volume of all
alternatives. System
requires wells and near
surface coolant loop
system.
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
exposure.
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
accidents/spills).
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
capacity
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
12
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
13
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.
14
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
15
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.
16
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
services.
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
17
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
hazards.
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.
18
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
risk.
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.
19
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.
20
WLLFOIA4312- 001 – 0055700
Table 2 – Options to Address Remaining RIM
Option Description Advantages Disadvantages
RIM handling, screening, transport,
disposal
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
excavation
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
RIM.
21
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
Quarry
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
comment.’
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

Post

2015-05-27 – EPA – West Lake Landfill – Question on status of RIM characterization

To:
From:
Sent:
Subject:
Vann, Bradley[Vann. Bradley@epa .gov]
Kiefer, Robyn V NWK
Wed 5/27/2015 1 :00:59 PM
Question on status of RIM characterization (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
Brad:
Have the RPs mobilized for the additional RIM characterization?
Per their Work Plan, they indicated they’d have GCPT data within 9 weeks. Is that still what is
anticipated?
Thanks,
Robyn
Robyn Kiefer
Project Manager
US Army Corps of Engineers
Kansas City District
Classification: UNCLASSIFIED
Caveats: NONE
WLLFOIA4312- 001 – 0059043

Post

2016-07-20 – West Lake Landfill – Evaluation of the Selected Remedy for Operable Unit-1 at the West Lake Landfill

EVALUATION OF THE EPA SELECTED REMEDY FOR OPERABLE UNIT-1 (OU-1)
AT THE WEST LAKE LANDFILL
BRIDGETON, MISSOURI
DATED: 20 July 2016
PREPARED BY:
Robert Alvarez
Senior Scholar
Institute for Policy Studies
Lucas W. Hixson
Director, Field Operations
Environmental Services
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BACKGROUND
In 1973, uranium ore processing residues from the production of nuclear weapons, mixed with contaminated soil from the Latty Avenue Site in Hazelwood, Missouri were transported and illegally dumped in the West Lake Landfill in Bridgeton, Missouri. Currently there are known concentrations of radiologically impacted material (RIM) in areas of the landfill designated by the US Environmental Protection Agency (EPA) as Operable Unit 1 Area 1 and Area 2. The full extent of the contamination relative to the potential impact of an adjacent underground fire* has not yet been determined. However, EPA experts indicate that sufficient data exists to support removal of these materials.
SUMMARY
In 2008, the Environmental Protection Agency (EPA) proposed a Record of Decision (ROD) related to the Operable Unit-1 (OU-1) at the West Lake Landfill (EPA 2008)3. The EPA remedy proposes “in-place” disposal with the installation of a cap/cover over portions of the landfill and long-term monitoring of groundwater at the site.
Internal communications from EPA’s expert reviewers reveal that the proposed remedy is unlikely to protect thousands of urban residents from concentrated radioactive wastes in the floodplain of the Missouri River.
EPA internal analyses find that:
1. The EPA cannot ensure the protectiveness of the cap/cover for toxic uranium processing wastes, in an unlined landfill, that become increasingly radioactive for thousands of years.
2. Radioactive materials attributable to the waste materials at the West Lake Landfill have already been detected in the air, groundwater, surface soils, sediments, and vegetation around the site — at or above regulated standards.
3. An underground fire burning in the wastes in the adjacent Bridgeton Sanitary Landfill compromises the cap/cover remedy by increasing radiological emissions and offsite exposures.
4. The radioactive materials in the landfill can be removed and transported to a licensed radioactive waste landfill without unacceptable risk to the public. However, delays in removal will increase costs and long-term exposures to the public.
*U.S. Fire Administration, Topical Fire Research Series, Landfill Fires, Volume 1, Issue 18 March 2001 (Rev. December 2001)”Spontaneous heating is attributed to 5% of landfill fires. This occurs when underground, decomposing waste rising in temperature combusts as it comes in contact with a methane gas pocket. This is known as a “hotspot…” http://nfa.usfa.dhs.gov/downloads/pdf/statistics/v1i18-508.pdf.
Evaluation of the EPA Selected Remedy for Operable Unit-1 (OU-1) at the West Lake Landfill
This report provides a summary of observations based on internal communications and recommendations provided by Environmental Protection Agency (EPA) experts in documents published by Agency, including technical experts from the EPA Office of Research and Development, Engineering Technical Support Center (ETSC)1 in 2014 and from the EPA National Remedy Review Board (NRRB)2 in 2013- which was withheld from the public until mid-2016.
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 2 | P a g e
FINDINGS
1. The EPA cannot ensure the protectiveness of the cap/cover of toxic uranium processing wastes, in an unlined landfill, that become increasingly radioactive for thousands of years.
a. The EPA’s own experts pointed out the known shortcomings with the proposed remedy design and recommended that Region 7 look into alternative remedies;4
In March 2013, EPA experts from the National Remedy Review Board (NRRB) stated that: “[the proposed remedy] lacked sufficient information on the long-term protectiveness of this alternative.” Furthermore, the NRRB stated: “both of the landfill designs (RCRA Subtitle D and UMTRCA) proposed in the 2008 ROD and 2011 SFS have known shortcomings for handling radioactive waste by itself, let alone handling radioactive waste in a humid region as it would be at the West Lake Landfill.”
The proposed remedy set an unprecedented limit for radiological contamination that was 18 times greater than previously allowed for such wastes located in an urban area.5
The NRRB recommended that instead of enclosing the wastes that Region 7 should excavate the radiological waste and transport it to facilities designed to provide long-term management for such materials.6
The NRRB also determined that the proposed long-term monitoring of the groundwater by itself is not a CERCLA remedy and so could not be a component of the ROD selected remedy.
b. The radiologically-impacted material in the West Lake Landfill is highly toxic and will increase in radioactivity and toxicity over time leading to increased risk to the public;7
The known radiologically-impacted material (RIM) disposed of in the West Lake Landfill is out of secular equilibrium and as daughter products grow back into normal concentrations, the waste materials will increase in radioactivity, toxicity, and risk to the public over time for the at least 10,000 years.
The EPA National Remedy Review Board (NRRB) detailed the dangerous nature of the materials noting, “Based on the package provided to the Board, it appears that there are potentially significant amounts of RIM that are highly toxic (e.g., based on NRC estimates in the 1982 and 1988 reports, radium of up to 22,000 pCi/g, bismuth-214 up to 19,000 pCi/g, and average thorium-230 concentrations of 9,000 pCi/g.” and; “Given the presence of highly radioactive material at this site, and the fact that its hazardous nature will continue to increase over time, the Board believes excavating and/or treatment of any amount of the RIM should lead to important risk reduction.”
The EPA’s cap/cover remedy proposed in the 2008 ROD and 2011 Supplemental Feasibility Study (SFS) does not address the in-growth of radioactivity over time that will occur in the landfill.
3 | P a g e 07/20/2016
c) The EPA’s proposed cap/cover would not protect the groundwater within and beyond around the landfill from becoming contaminated;
The EPA has not demonstrated that the groundwater can be protected from contamination if the cap/cover remedy as proposed in the 2008 ROD and 2011 SFS is approved. Samples of groundwater at the landfill have found levels of contamination that greatly exceed federal permissible maximum contaminant levels (MCLs) and indicate both the off-site migration of groundwater as well as the potential impact on offsite vegetation.8 9 Exceeding an MCL in groundwater would require a response action according to CERCLA protocol.10,11
The West Lake Landfill is an unlined landfill with no engineering barriers12 in the alluvial floodplain waters that flow into the Missouri River, upstream of the confluence with the Mississippi River. Groundwater levels can highly fluctuate according to rainfall event, and river levels can interact directly with surface water and groundwater runoff near the landfill. Because of the lack of engineered protection at the landfill, groundwater at the site can come into contact with RIM material and spread contamination in the highly permeable alluvial aquifer, and into the deeper bedrock aquifer.
It is extremely difficult to clean up contaminated groundwater. Every available corrective action to prevent groundwater contamination by RIM material in the West Lake Landfill should be considered. As long as the radioactive material remains in the landfill, the groundwater will continue to be contaminated.
d) EPA experts have raised serious concerns with the analysis and characterization of the RIM at West Lake;
In 2013, the NRRB raised a number of serious concerns with “…the way the nature and extent of the RIM at the site was characterized….” The Board pointed out that most of the RIM is located at or near the surface of the landfill (within 10 feet of the surface) as opposed to characterizations made in the ROD and SFS that the materials would be difficult to excavate. The lack of cover materials increases risk to members of the public, because there few if any barriers preventing the migration of radioactive materials and gases from the landfill into the air, groundwater and local environment around the facility.13
The EPA Office of Research and Development (ORD) pointed out that the lack of accurate accounting of the radioactive wastes at West Lake increases the uncertainties related to the potential impacts of the underground fire, at the adjacent Bridgeton Landfill.14
e) Alternative remedies could provide a more permanent remedy protective of the public;
The EPA National Remedy Review Board (NRRB) pointed out that the latest technologies could be employed to sort RIM from Non-RIM materials. The radioactive wastes could be then be sent to a dedicated and regulated radioactive disposal facility,
“Given the presence of highly radioactive material at this site, and the fact that its hazardous nature will continue to increase over time, the Board believes excavating and/or treating any amount of the RIM should lead to important risk reduction. Where it appears that much if not all of the RIM is located near the surface, cleanup at this site appears less complicated than other sites….Radiological material is also easily sorted out in the field with portable instruments that provide instantaneous measurements to ensure that only contaminated material is retrieved which, in turn, minimizes disposal costs.”
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 4 | P a g e
2. Radioactive wastes from the West Lake Landfill have already been detected in the air, groundwater, surface soils trees and other vegetation around the site, at levels above federal permissible Maximum Contamination Levels (MCLs).
Uranium, thorium and their related decay products have been detected in off-site vegetation on private properties around the landfill.15
RIM material has migrated beyond the landfill by surface water transport during strong rainfall events.16
Samples of groundwater at and around the landfill have found levels of contamination that exceed standards.17
Measurements of radon in air conducted for the 2011 SFS found concentrations of radon that nearly exceeded UMTRCA standards.
Levels of unsupported lead have been detected in the local environment around the landfill out of equilibrium with background levels of radon and radium.18
3. An underground fire, burning in the adjacent Bridgeton Sanitary Landfill, could seriously compromise the cap/cover remedy by increasing radiological emissions and offsite exposures.
In December 2010, operators of the Bridgeton Sanitary Landfill detected elevated temperatures and carbon monoxide levels indicating an underground fire was burning in an area adjacent to and connected with known contaminated areas of the West Lake Landfill. The movement of the underground fire in the South Quarry has been unpredictable and there are no estimates of the length of time it would take for the underground fire to reach the RIM in Area 1.
The threat of an underground fire reaching the nuclear waste was of such concern that the Potential Responsible Parties (PRPs) contracted a company called Engineering Management Support, Inc. (EMSI) to prepare a report the potential risks that would be generated if the fire were to interact with the RIM materials. The EMSI report was released to the public in January 2014.
On March 28, 2014, at the request of the EPA, a technical review of the EMSI report on the potential impacts of fire was conducted by the Office of Research and Development – who predicted that an underground fire in OU-1 would:
• Create long-term risks to people and the environment;19
• Limit the effectiveness of the proposed remedy in the 2008 ROD and 2011 SFS, even with a proper cap/cover design, inspection and maintenance;2021
• Increase the temperature and pressure conditions within the landfill, generating large amounts of steam and forcing out a larger volume of gases (including radon) and fine particulates into the local environment;22
• Increase production of contaminated leachate and dissolved gases that can migrate into the groundwater;23
5 | P a g e 07/20/2016
• Increase potential for releases of radon at levels of concern;
i. Measurements of radon around the landfill for the 2011 SFS recorded concentrations close to Uranium Mill Tailings Radiation Control Act (UMTRCA) standards.24
ii. An underground fire in OU-1 would be expected to further reduce the ability of the waste materials to retain radon gas. By reducing the amount of moisture in the buried wastes, thereby increasing the space between soil particles, more radon will escape;25
• A cap/cover installed over impacted areas at the West Lake Landfill could also hinder efforts to monitor and respond to future underground fire events.26
4. The radioactive materials in the landfill can be removed and transported safely to licensed radioactive waste landfill. However, delays in removal will increase costs and long-term exposures to the public.
Downhole gamma logging and laboratory analyses conducted at the West Lake Landfill reveal that the radiologically impacted materials are generally found at depths ranging between the surface and top 6 feet of topsoil. There are also hot spots of contamination could be targeted for excavation and removal.
In February 2012 the EPA’s National Remedy Review Board (NRRB) conducted its review of the EPA’s Region 7 proposal for remedial action of Operable Unit 1 at the West Lake Landfill. In March 2013, the Board finalized its draft discussions, which concluded
“…based on the fact that the Agency has safely cleaned up numerous hazardous waste sites with radiological contamination across the country, including many in residential areas, the cleanup work can be done safely without unacceptable risk…”
The NRRB recommended that EPA Region 7 should:
“…develop an alternative that reflects an approach which surgically removes the RIM, which appears to be a discrete, reachable source term that will continue to increase in toxicity over hundreds and thousands of years…”
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 6 | P a g e
CONCLUSIONS
The EPA has yet to propose a plan for the excavation of highly radioactive materials from the West Lake Landfill, despite their own scientific evidence and recommendations from their own staff experts.
The Federal Government has been removing radiological contaminants from residential and commercial properties for the past seventy years in order to reduce hazards stemming from exposure to members of the public. The removal of radiologically-impacted source material is protective and should be an important objective of any proposed cleanup. These cleanup activities can be safely and efficiently completed with appropriate engineering controls and in accordance with approved health and safety plans.
In the near term, efforts should be made to:
1. Evaluate and implement immediate responses to prevent an underground fire from coming into contact with RIM material;
2. Identify current technologies which could be employed to sort RIM materials;
3. Determine the vertical and linear characterization of groundwater contamination and potential groundwater plume as opposed to isolated groundwater hot-spots;
4. Detect and characterize additional hot spots in the landfill outside of the known contaminated areas;
5. Facilitate the excavation of RIM material from the West Lake Landfill and its shipment and ultimate disposal at a dedicated and licensed disposal facility;
Finally, in accordance with expert evaluations, the proposed remedy in the 2008 ROD should be replaced with a more permanent and protective removal remedy that will reduce hazards to the public. Such a remedy should be developed with feedback from the community.
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ACRONYMS
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
EMSI
Engineering Management Support, Inc.
EPA
Environmental Protection Agency
ETSC
EPA ORD Engineering Technical Support Center
MCL
Maximum Contaminant Level
NRRB
National Remedy Review Board
ORD
EPA Office of Research and Development
OU-1
Operable Unit-1
PRP
Potentially Responsible Party
RCA
Recycled Concrete Aggregate
RIM
Radiologically-Impacted Material
ROD
Record of Decision
SFS
Supplemental Feasibility Study
UMTRCA
Uranium Mill Tailings Radiation Control Act
Evaluation of the EPA Selected Remedy for Operable Unit-1 at the West Lake Landfill 8 | P a g e
ENDNOTES
1 U.S. Environmental Protection Agency, Memorandum, From: John McKernan, ScD, CIH Director, ORD Engineering Technical Support Center (ETSC), To: Dan Gravatt, RPM U.S. EPA Region 7, Subject: Observations on the EMSI report: Evaluation of Possible Impacts of a Potential Subsurface Smoldering Event on the Record of Decision – Selected Remedy for Operable Unit-1 at the West Lake Landfill, Dated January 14, 2014, March 28, 2014. https://semspub.epa.gov/work/07/30284983.pdf
2 U.S. Environmental Protection Agency, National Remedy Review Board Discussions Regarding the Remedy at the West Lake Landfill Superfund Site, February 28, 2013. http://moenvironment.org/files/WestLakeNRRB_MCEnotes.pdf (The National Remedy Review Board (NRRB) is a peer review group created to ensure that proposed Superfund cleanup decisions are consistent with Superfund law, regulations and guidance. NRRB members are EPA managers and senior technical and policy experts with significant experience in Superfund remedy selection issues.)
3 U.S. Environmental Protection Agency, Record of Decision, West Lake Landfill Site, Bridgeton, Missouri, Operable Unit 1, May 2008. http://westlakelandfill.com/Portals/0/Documents/West%20Lake%20ROD%20OU1%20signed%2005-29-08.pdf
4 Comments from NRRB Reviewer John Frisco on PRP Scope of Work: Alternative Cover Designs and Fate and Transport Modelling, “Not sure why an ET [evapotranspiration] Cover is even being considered at this site since its deficiencies have already been identified (Albright and Benson).”
5 Inside EPA, EPA Orders Rare Review of Radioactive Cleanup Plan at Precedential Site, June 28, 2010
6 Internal E-Mail from NRRB Reviewer John Frisco dated February 15th, 2012 stated “Radiological contamination remains active for a very long time and would require long-term management wherever it ends up. For this reason, where possible, we try to send such material to facilities designed specifically for this purpose (e.g., Idaho, Utah). If one could safely and efficiently extract the radiological waste that might be an option worth consideration.”
7 Comments from NRRB Reviewer Charles Openchowski on PRP Scope of Work for groundwater, “The NRC reports also discuss how the toxicity of this RIM will continue to increase over time…this increase in Ra-226 must be considered in evaluating the long-term hazard posed by this radioactive material.” The SFS also acknowledges this fact.”
8 State of Missouri Attorney General’s Office, “Westlake Landfill Tree Core Analysis Report,” Dr. Joel G. Burken, Dr. Shoaib Usman, September 2, 2015 – Scientific data published by the State of Missouri Attorney General’s Office, demonstrated the potential for RIM to transfer offsite. Tree coring analysis conducted around the West Lake Landfill observed elevated radiologic counts of U-238 and U-235 in many of the analyzed samples. These elevated levels indicate offsite migration of RIM into the local environment.
9 Missouri Department of Natural Resources,” Bridgeton Sanitary Landfill Groundwater Investigation Report,” St. Louis County, Missouri, prepared for the Attorney General of Missouri – Analysis of potentiometric contours published by the State of Missouri Attorney General’s Office indicate that groundwater flows in a westerly direction, angling away from the landfill toward the Missouri River.
10 OSWER Directive 9355.0-30, Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions, April 22nd, 1991
11 OSWER Directive 9283.1-33, Summary of Key Existing EPA CERCLA Policies for Groundwater Restoration
12 Robert E Criss, Risk and Character of Radioactive Waste at the West Lake Landfill, Bridgeton, Missouri, March 14, 2013 – “Specifically, it has no basal clay liner, no plastic sheeting, no internal cells, no leachate collection system, nor any type of protective cap, all of which are standard requirements for modern landfills. Instead the West Lake Landfill is a chaotic pile of debris covered by unmanaged “natural” vegetation, surrounded by a fence with radioactive hazard signs. This landfill is an unsuitable host for any type of radwaste, industrial waste, chemical waste, or even ordinary domestic waste.” http://moenvironment.org/images/West_Lake_Rept03142013.pdf
13 Environmental Protection Agency, West Lake Update – EPA to Conduct Additional Sediment Sampling at the West Lake Landfill, May 26th, 2016 – EPA analysis has determined that RIM materials are being transported off-site with surface water after significant rain events and collecting in sediment around the landfill.
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14 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary Bullet Point #2, “Since we do not have a full accounting of the material in OU-1, we cannot make a definitive assessment regarding the potential for chemical reactions between the RIM and non-RIM materials if an SSE (Sub-Surface Smoldering Event) were to occur. If these reactions were to occur, they could cause a rapid buildup of heat or gas, and subsequent reactions or reactive conditions in the landfill.”
15 State of Missouri Attorney General’s Office, Westlake Landfill Tree Core Analysis Report, Dr. Joel G. Burken, Dr. Shoaib Usman, September 2nd, 2015
16 Environmental Protection Agency, West Lake Update — EPA to Conduct Additional Sediment Sampling at the West Lake Landfill, May 26th, 2016.
17 Internal Comments by Charles O. on PRP Groundwater Scope of Work, “Based on information presented to the [National Remedy Review] Board, it appears that there have been some samples of groundwater at this site that exceed standards considered as ARARs…Generally, under existing Agency guidance, exceeding a maximum contaminant level in groundwater normally would warrant a response action.”
18 M. Kaltofen, R. Alvarez, L. Hixson, Tracking legacy radionuclides in St. Louis, Missouri, via unsupported 210Pb, Journal of Environmental Radioactivity, December 2015. http://www.coldwatercreekfacts.com/media/reports/Alvarez-Journal-2015.pdf
19 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #4, “We do not support the conclusion that no additional long term risks would be created in the event of a SSE at OU-1. There are at least two risk pathways that could exist from an SSE [subsurface smoldering event]. The first is through increased air exposures to contaminants such as radon. As airborne concentrations of radon increase, so would the risk to people. The second pathway is increased leachate production that could move contaminants and dissolved radon gas from OU-1 into the groundwater.”
20 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #2, “…using the higher temperatures observed in the Bridgeton Landfill as a worse-case scenario, these temperatures may cause the structural integrity of the cap called for in the 2008 ROD to be adversely affected. This could potentially include surface cracks and fissures in the cap extending down into the waste material, and potentially cause permeation of the cover used.”
21 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #2, “…if a SSE occurs, short-term risks may be present even with proper cap design, inspection and maintenance.”
22 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary Bullet Point #3, “A SSE in OU-1 would be expected to create increased pressure conditions within the landfill and force out entrained gases, including radon.”
23 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #5, “Short-term effects of an SSE could also include greater amounts of leachate production, which has been observed at the Bridgeton Landfill from condensation of large amounts of steam. An SSE may result in increased emissions of radon and other contaminants in the air and groundwater, even with annual inspections and proper maintenance of designs discussed in the 2008 ROD and 2011 SFS.”
24 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #3, “Given that measurements of radon in air during the SFS were close to a Uranium Mill Tailings Radiation Control Act (UMTRCA) standard, there is potential for radon releases at levels of concern if a SSE occurs in OU-1. This observation does not consider other environmental conditions that could cause radon and other landfill gas concentrations to increase at ground level, such as atmospheric inversions.”
25 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #4, “We do not support the conclusion that no additional long term risks would be created in the event of a SSE at OU-1. There are at least two risk pathways that could exist from a SSE. The first is through increased air exposures to contaminants such as radon. As airborne concentrations of radon increase, so would the risk to people.”
26 Internal Comments from EPA ORD ETSC experts on EMSI Executive Summary, Bullet Point #3, “…a SSE may be present in OU-1 for a long period of time before it is detected, because the only apparent means to detect a SSE after closure is through annual visual inspections.”

Post

2015-01-22 – EPA – West Lake Landfill – Risk is the Driver for Decision-Making

To: Field, Jeff[Field.Jeff@epa.gov]; Jefferson, MatthewUefferson.matthew@epa.gov]; Stoy,
Alyse[Stoy.Aiyse@epa.gov]; Slugantz, Lynn[Siugantz.Lynn@epa.gov]; Kiefer, Robyn V
NWK[Robyn .V. Kiefer@usace.army. mil]; McKernan, John[McKernan .John@epa .gov]; Kappelman,
David[Kappelman. David@epa .gov]
From: Vann, Bradley
Sent: Thur 1/22/2015 5:07:38 PM
Subject: West Lake Landfill – Tomorrows Meeting with RPs (revised agenda)
All,
Here is the revised agenda for tomorrow’s discussion with the RP technical team. Please review
this morning (or what is left of it) and let me know if additional changes are needed. Note items
in red font are internal considerations/discussion points and will not be sent out with final
version this afternoon.
Thanks,
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
Agenda
e Meeting purpose to be responsive to EPA letter dated 1/15/15 and discuss technical path
forward on RIM characterization
WLLFOIA4312- 001 – 0058779
e Overview on how characterization work fits with existing work
-Completion of the Soils Remedy
-Address Technical Concerns
-Risk is the Driver for Decision-Making
e Investigation of interface between OU -1 Area 1 and North Quarry
-Area of Interest
-Overview of Statistical Approach
e Cores and Composition of Area 1
-Purpose
-Review of existing cores
WLLFOIA4312- 001 – 0058780
e Projected Timeline
– Work Plan revision/review and approval
-Field Work
-Reporting
e Jan 30 meeting Primer/Meeting Wrap Up
WLLFOIA4312- 001 – 0058781

Post

2015-04-02 – EPA – West Lake Landfill – Bridgeton Missouri CERCLA History

West Lake Landfill site, Bridgeton Missouri
CERCLA History
April2, 2015
• National Priority Listing (NPL) for West Lake
o West Lake Landfill was listed on the NPL in 1990 (See 55 FR 35502-25512, Aug.
30, 1990).
o The NPL listing package was primarily based on radioactive contamination;
however, the narrative summary mentions that there are other chemical
contaminants in the landfill.
o NPL listings are based on data of a sufficient nature to list the site but are not
inclusive of all contaminants that may present an unacceptable risk and do not
define the areal of extent of contamination.
• As noted in a 2012 HRS listing: The HRS does not require scoring all
pathways if scoring those pathways does not change the listing decision. The
HRS is a screening model that uses limited resources to determine whether a site
should be placed on the NPLfor evaluation and possible Superfund response. A
subsequent stage of the Superfund process, the remedial investigation (RI),
characterizes conditions and hazards at the site more comprehensively.
• For the West Lake site, Operable Unit (OU) 1 deals with landfills that contain RIM (and
other chemicals) and OU2 deals with the other non-RIM landfills at the NPL site.
• OUI had a Record of Decision (ROD) signed in 2008. Subsequent to the signature of the
ROD, concerns were raised by the Missouri Coalition for the Environment and others
regarding EPA’s decision to cap the Site and leave RIM in place. As a result, the Agency
chose to more thoroughly explore other potential alternate remedies, including full and
partial excavation. That has been the primary focus of work over the last few years,
including the NRRB consultation and ongoing work supported by OSRTI, ORD, and
others.
• OU2 (non-RIM landfills) had a separate ROD signed in 2008 for the non-radiation
portion of the site.
o The ROD for OU2 (non-RIM landfills) states: “For areas operated under state
permit, i.e., the Former Active Sanitary Landfill and the Closed Demolition
Landfill, the terms of their respective permits dictate the appropriate closure and
post-closure care requirements. Successful completion of these requirements
would eliminate the need for further CERCLA action at these units. Consistent
with EPA’s policy on coordination between the Resource Conservation and
Recovery Act and CERCLA actions, these regulated units are deferred to the state
regulatory program.”
o The OU2 ROD indicates that the Former Active Sanitary Landfill, also known as
the Bridgeton Landfill, is part of the OU2 area The OU2 ROD requirements
include:
• Installation of landfill cover meeting state sanitary landfill requirements
WLLFOIA4312- 001 – 0057929
• Groundwater monitoring consistent with requirements for sanitary
landfills
• Surface water runoff control
• Gas monitoring and control consistent with sanitary landfill requirements
• Institutional Controls
• Surveillance and maintenance of the remedy
o Because of the deferral, all of the activities and issues related to the Bridgeton
Landfill have been lead and managed by the State. This includes management of
the off-gassing, which has been an issue of significant community interest.
• The following maps are attached (please note the “North” arrows as the orientation can
vary from one map to the next):
o West Lake Landfill OU-2 map
• Shows the the overall boundaries and state permit coverages
o West Lake Site Layout for OU-1, which shows Radiological Areas 1 and 2
o West Lake Site vicinity map
• There also has been some recent discussion regarding a recent flyover.
o Based on discussions with the Region, in February 2015, a local fire department
official conducted a flyover using an infrared camera that supposedly indicated
that the North Quarry of the Bridgeton Landfill may have elevated temperatures.
Immediately north of the North Quarry is where RIM was found during 2014
sampling associated with locating an isolation barrier between the RIM and the
SSE. This could have led to the conclusion that the subsurface smoldering event
may have migrated to the radiation contamination areas.
o However, it appears that the State and the Region have determined that the data
from that flyover are not credible, due to concerns with the overall process,
equipment, etc.
o Thus, the Region and the State are no longer addressing the flyover. The Region
continues coordination with the state on review of the data from the temperature
probes and gas extraction wells to evaluate the possible movement of the SSE.
WLLFOIA4312- 001 – 0057930

Post

2014-08-01 – EPA – USACE – Independent Technical Review for Operable Unit 1 at the West Lake Landfill Site

STATEMENT OF WORK
Independent Technical Review for Operable Unit 1 at the West Lake Landfill Site
1. BACKGROUND INFORMATION
The West Lake Landfill Site is on a parcel of approximately 200 acres located in
the northwestern portion of the St. Louis metropolitan area. It is situated approximately
one mile north of the intersection of Interstate 70 and Interstate 270 within the limits of
the city of Bridgeton in northwestern St. Louis County. The Missouri River lies about 1.5
miles to the north and west of the Site.
The Site consists of two radiologically contaminated landfill cells comprising
Operable Unit 1 (OU-1) and the Bridgeton Sanitary Landfill (Former Active Sanitary
Landfill) and several inactive areas with sanitary and demolition fill that have been
closed comprising OU-2. Land use at the site and the surrounding areas in Earth City is
industrial.
Other facilities which are not subject to this response action are located on the
200-acre parcel including concrete and asphalt batch plants, a solid waste transfer station,
and an automobile repair shop.
The Site was used agriculturally until a limestone quarrying and crushing
operation began in 1939. The quarrying operation continued until 1988 and resulted in
two quarry pits. Beginning in the early 1950s, portions of the quarried areas and adjacent
areas were used for landfilling municipal solid waste (MSW), industrial solid wastes, and
construction/demolition debris. These operations were not subject to state permitting
because they occurred prior to the formation of the Missouri Department of Natural
Resources (MDNR) in 1974. Two landfill areas were radiologically contaminated in
1973 when they received soil mixed with leached barium sulfate residues.
The barium sulfate residues, containing traces of uranium, thorium, and their longlived
daughter products, were some of the uranium ore processing residues initially
stored by the Atomic Energy Commission (AEC) on a 21.7 acre tract ofland in a then
undeveloped area of north St. Louis County, now known as the St. Louis Airport Site
(SLAPS), which is part of the St. Louis Formerly Utilized Sites Remedial Action
Program managed by the U.S. Army Corps of Engineers (USACE)
In 1966, residues associated with the production and refining of uranium
materials were purchased by Continental Mining and Milling Company of Chicago,
removed from the SLAPS, and placed in storage at the Hazelwood Interim Storage Site
(HISS) on Latty Avenue under an AEC license. In 1967, Commercial Discount
Corporation, which obtained possession of the HISS property and residuals, began drying
residue and shipping them to Cotter Corporation in Canon City, Colorado (DOE 1987).
WLLFOIA4312- 001 – 0058946
In 1969, residues remaining at the HISS were sold to Cotter Corporation in Canon City.
In 1970, Cotter Corporation dried and shipped some of the remaining residues from the
HISS to Canon City (DOE 1994). In December 1970, an estimated 10,000 ton of
Colorado raffinate and 8,700 tons ofleached barium sulfate remained at the Latty
Avenue HISS.
Reportedly, 8,700 tons of leached barium sulfate residues were mixed with
approximately 39,000 tons of soil and then transported to the West Lake site in 1973.
According to the landfill operator, the soil was used as cover for municipal refuse in
routine landfill operations.
The geology of the landfill area consists of Paleozoic-age sedimentary rocks
overlying Pre-Cambrian-age igneous and metamorphic rocks. The Paleozoic bedrock is
overlain by unconsolidated alluvial and loess deposits of recent (Holocene) age. Alluvial
deposits of varying thickness are present beneath Areas 1 and 2. The landfill debris varies
in thickness from 5 to 56 feet in Areas 1 and 2, with an average thickness of
approximately 30 feet in Area 2. The underlying alluvium increases in thickness from
east to west beneath Area 1. The alluvial thickness beneath the southeastern portion of
Area 1 is less than 5 feet (bottom elevation of 420 ft/amsl) while the thickness along the
northwestern edge of Area 1 is approximately 80 feet (bottom elevation of 370 ft/amsl).
The thickness of the alluvial deposits beneath Area 2 is fairly uniform at approximately
100 feet (bottom elevations of 335 ft/amsl).
A subsurface oxidation event (SSE) is ongoing in the South Quarry Landfill
portion of the Bridgeton Sanitary Landfill. The South Quarry cell is connected to the
North Quarry cell which is adjacent to Operable Unit 1, Area 1, one of the locations on
site that received the radiologically contaminated soils in 1973. Pursuant to an order
from the Missouri Attorney General, the site owner is required to install a subsurface
barrier between the North Quarry cell and OU-1 Area 1 to prevent the SSE from
migrating into the radiologically contaminated materials.
As a follow-up to EPA R7 consultation with EPA’s National Remedy Review
Board (NRRB) in February 2012, the following evaluations are being conducted to assess
the Remedial Alternatives for OU-1: 1) partial excavation evaluation; 2) alternative
landfill cap designs; 3) evaluation on the use of waste treatment technologies, including
apatite; 4) recalculation of RIM volumes for a full excavation scenario; 5) groundwater
fate and transport modeling; and 6) recalculation of discount rate. These evaluations will
be contained in a forthcoming Supplemental Feasibility Study (SSFS) Amendment or
equivalent document.
WLLFOIA4312- 001 – 0058947
II. OBJECTIVE AND SCOPE
This will be an interagency agreement. The EPA is requesting assistance from
the US Army Corps of Engineers (US ACE) to conduct an Independent Technical Review
(ITR) of specific documents associated with Operable Unit-1 at the West Lake Landfill
and being developed in response to National Remedy Review Board (NRRB) comments.
The technical support may consist of performance of specific tasks which USEP A
contractors have neither the expertise or cannot provide at reasonable cost to EPA.
III. WORK ASSIGNMENT TASKS
USACE shall furnish personnel and services required to conduct an ITR of
reports prepared by the Responsible Parties in response to the recommended NRRB
evaluation.
Tasks included in this scope are:
1. Project Planning and Support
2. Independent Technical Reviews
3. Community Relations Support
4. Close-Out
TASKl PROJECT PLANNING AND SUPPORT
This task includes work efforts related to project initiation, management, and
support. Activities required under this task include the following, as applicable:
1.1 US ACE shall participate in a scoping meeting with EPA to discuss the work
assignment.
1.2 USACE shall provide proposed level of effort and costs for the support activities
to be performed. Based on EPA’s review of the scope, level of effort and cost
estimate, USACE may be called upon to participate in negotiations with EPA on
the proposed level of effort and to revise the level of effort as a result of these
negotiations.
1.3 The USACE shall perform site-specific project management including:
1.3 .1 Establishment and maintenance of necessary work assignment files,
schedules, and project documentation
1.3.2 Provide monthly reporting and invoices. These documents shall contain
WLLFOIA4312- 001 – 0058948
narrative of specific task and subtask activities sufficient enough for the
EPA Remedial Project Manager (RPM) to evaluate the work assignment
progress.
1.3.3 Monitor costs and performance
1.3.4 Coordinate staffing and other support activities to perform the work
assignment tasks in accordance with the Statement of Work (SOW)
including USACE subcontractors, if utilized.
1.3.5 Attend necessary work assignment meetings
1.3 The USACE shall accommodate any external audit or review mechanism that
EPA may require. Level of effort for this work will be determined at a later date
and this IA will be amended to include this task and associated cost.
TASK2 INDEPENDENT TECHNICAL REVIEWS
This task includes the work required to conduct the ITR and documents the
required deliverables.
2.1 US ACE shall coordinate and prepare a review plan and assist EPA in preparing
the reviewer’s charge statement.
2.2 US ACE shall perform an ITR of reports prepared by the Responsible Parties
(RPs) in response to the NRRB consultation with EPA on the Supplemental
Feasibility Study dated December 28, 2011. The purpose of the ITR is to
provide an independent assessment of the RP’ s work products to ensure the
scientific and technical components have been applied in a sound manner to meet
established regulatory requirements. The ITR will be conducted by qualified
individuals who are independent of those who performed the work, and who are
collectively equivalent in technical expertise (i.e., peers) to those who prepared
the reports.
The reports prepared in response to the NRBB recommendations will include:
2.2.1 Up to four ITR reports to address the following:
• The RP’ s evaluation of a partial excavation alternative;
• The RP’s recalculation of RIM volumes to address alternate excavation
scenano;
• The RP’ s evaluation of up to three alternative landfill cap designs;
• The RP’ s evaluation on the use of up to five waste treatment technologies,
including apatite and soil sorting;
• The RP’s results of groundwater fate and transport modeling; and
• The RP’ s recalculation of all alternatives using a 7% discount rate.
2.2.2. A Supplemental Feasibility Study Addendum or equivalent document.
WLLFOIA4312- 001 – 0058949
2.2.3 A Revised Proposed Plan, if required. If a Revised Proposed Plan is
required, the level of effort for the ITR will be determined at a later date and this
IA will be amended to include this task and associated cost.
2.2.4 An Amended ROD, if required. If a Revised ROD is required, the level of
effort for the ITR will be determined at a later date and this IA will be amended
to include this task and associated cost.
2.3 USACE ITR team will review historical documents for familiarity and
understanding of the site. Historical documents will not be the subject of the
ITR. Historical documents to be reviewed include, but may not be limited to the
following:
• OUI Site Characterization Summary Report
• OUI Remedial Investigation Report
• OUI Baseline Risk Assessment
• QUI Feasibility Study
• OUI Supplemental Feasibility Study
• OUI Record of Decision
• EPA Radiological and Infrared Survey Report (ASPECT) (May 20I3)
• MDNR Radiological Survey Report (May 20 I3)
• Radiation Management Corporation Radiological Survey (I982)
• NRC Radioactive Material in West Lake Landfill (I988)
2.4 US ACE shall prepare an ITR report for each of the documents reviewed. The
letter report will contain USACE’s technical evaluation and, to the extent
practicable, shall be written in terms understood by the general public. The letter
report will be submitted to EPA as a “final” product. The number of days
allotted for completion of the ITR will be jointly determined and agreed upon by
EPA and USACE based upon the size and nature of the document to be
reviewed, but shall be no less than 45 calendar days for any review.
2.5 The USACE ITR will focus exclusively on the scientific and technical aspects of
the documents and whether the scientific and technical components have been
applied in a sound manner to meet established regulatory requirements. It will
not address grammatical, editorial, or formatting aspects of the document.
2.6 The US ACE ITR team shall participate in one technical meeting with EPA and
the RPs for each of the documents reviewed. The purpose of these meetings will
be to provide clarification on any comments. These meetings will be conducted
in the St. Louis area. If not able to be accomplished via an in-person meeting,
the meeting shall be accomplished by phone and internet (Web Meeting).
2. 7 EPA shall furnish US ACE with the following:
WLLFOIA4312- 001 – 0058950
2.7.1 Background documents, data, and other information necessary to ensure
the ITR’ s completeness;
2.7.2 Notification, at least 30 days in advance, of submittal of a document for
review
2.7.3 A tentative schedule identifying anticipated document submittal dates,
review times, and meetings.
TASK 3 COMMUNITY RELATIONS SUPPORT
This task includes efforts related to community relations support to EPA.
Activities required under this task include the following:
3.1 Upon issuance of this IA, USACE shall attend two community meetings to inform
the public ofUSACE’s support to EPA under this IA and answer questions. For
the initial public meeting after IA release, USACE will prepare a Power Point
presentation or other visual aids, as required to communicate the ITR process to
the public. For the second public meeting after the IA release, USACE shall
attend to answer any remaining public questions regarding the IA scope.
3.2 Upon completion of the review of each document, US ACE staff shall attend a
community meeting and present a description of the work accomplished by
US ACE and the findings of the ITR. The presentation will be provided via Power
Point, or via other means, if required. An electronic file of the Power Point
presentation shall be furnished to EPA at the meeting. USACE shall furnish 50
paper copies of the PowerPoint presentation for distribution to the public.
3.3 USACE staff shall be available to participate in pre- and post-meeting public
availability sessions for the meetings at which the USACE reviews are presented.
USACE shall provide necessary public availability session displays and
information packets (up to 50 handouts of Power Point presentation).
3.4 EPA, as lead agency, shall be the central point of contact for all project
stakeholders. If requested by EPA, US ACE shall provide written responses to
written questions received by EPA from the community regarding USACE’s
scope of work for the ITR effort.
TASK4 WORK ASSIGNMENT CLOSE-OUT
This task includes efforts related to work assignment close-out. Activities
required under this task include the following:
4.1 Upon notification by EPA, the USACE shall begin all internal procedures
necessary to close out the work assignment including any file duplication,
distribution, storage, or archiving per the contract requirements.
WLLFOIA4312- 001 – 0058951
4.2 The USACE shall return documents identified to EPA or other document
repositories as directed.
IV. WORK ASSIGNMENT PERIOD OF PERFORMANCE
August 1, 2014 to December 30, 2016
V. STATUTORY AUTHORITY
The statutory authority for entering into this IA is Section 105(a)(4) of the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) of 1980 (42 U.S.C. 9601 et seq., Public Law 96-510, December 11,
1980), as amended by the Superfund Amendments and Reauthorization Act
(SARA) of 1986 (Public Law 99-499, October 17, 1986), and Executive Order
12580.
VI. SCHEDULE OF DELIVERABLES/MILESTONES
TASK DELIVERABLE
1.3.2 Monthly Reports/Invoices
2.2 ITR Reports
VII. EPA CONTACTS
N
Project Manager Dan Gravatt
Project Officer Ina Square
SUBMITTAL SCHEDULE
Throughout period
Per agreed upon schedule
913-551-7324
913-551-7357
WLLFOIA4312- 001 – 0058952

Post

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

CHRIS KOSTER
ATTORNEY GENERAL
Washington, DC 20515
Congresswoman Ann Wagner
435 Cannon
Washington, DC 20515
65102
Dear Congressman Congresswoman Wagner,
your
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
www.ago.mo.gov
2016
letters, sent
P.O.Box899
(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.
Enclosures
cc: Senator Roy
Senator Claire McCaskill
Congressman Blaine Luetkemeyer
Congresswoman Vicky Hartzler
Congressman Emanuel Cleaver
Congressman Graves
Congressman Billy Long
Congressman Jason Smith
Respectfully,
CHRIS
Attorney General
WLLFOIA4312 – 001 – 0001697
ATTORNEY GENERAL OF MISSOURI
JEFFERSON CITY
ORRIS ROSTER
A-TTO:RNEY GENERAL
Karl Brooks
Environmental Protection Agency
Regional Administrator, Region 7
11201 Renner Blvd.
Lenexa, Kansas 66219
Dear Regional Administrator Brooks,
65102
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.
CHRIS KOSTER
Attorney General.
www.ago.mo.gov
WLLFOIA4312 – 001 – 0001698
· .
. .
. ·._·.• …
ATTORNEY GENERAL OF :Mrssoum
CHRIS KOSTER
ATTORNEY GENER.AL
JEFFERSON GITY
65102
Karl Brooks
Environmental Protection Agency
Regional Administrator, Region 7
11201 Renner Blvd.
Lenexa, Kansas 66219
January 8, 2014
Dear Regional Administrator Brooks,
P.O.Box899
(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
continues.
CZ~L
CHRIS KOSTER
Attorney General
WLLFOIA4312 – 001 – 0001700
ATTORNEY GENER.AL OF MissoURI
CHRIS KOSTER
ATTORNEY G-ENERAL
Karl Brooks
Regional Administrator
Environmental Protection Agency
11201 Renner Blvd.
Lenexa, KS 66219
Dear Administrator Brooks,
JEFFERSON CITY
65102
March 18, 2014
P.0.Box899
(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
possible.
www.ago.mo.gov
WLLFOIA4312 – 001 – 0001701
·_,’I’
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.
CRRIS KOSTER
Attorney General
cc: Bill Beck, General Counsel, Republic Services
WLLFOIA4312 – 001 – 0001702
CHRIS KOSTER
ATTORNEY GE-‘TERAL
Karl Brooks
Regional Administrator
US EPA Region 7
11201 Reimer Blvd_
Lenexa, KS 66219
ATTORNEY GENERAL OF MISSOURI
JEFFERSON CITY
65102
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
proposal.
• 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
www.ago.mo.gov
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.
CHRIS KOSTER
Attorney General

WLLFOIA4312 – 001 – 0001704
ATTORNEY GENERAL OF MISSOURI
CHRIS KOSTER
ATTORNTIY GENERAL
Karl Brooks
Environmental Protection Agency
Regional Administrator, Region 7
11201 Renner Blvd.
Lenexa, Kansas 66219
JEFFERSON CITY
65102
February 18, 2015
Dear Regional Administrator Brooks,
P.0.Box:899
(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
testing.
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
analysis.
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
www.ago.mo.gov
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.
Respect~//
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WLLFOIA4312 – 001 – 0001706
2/812016 Army Corps of Engineers to work on burning Bridgeton Landfill : News
8ll ST. LOUlS POST-DISPATCH
– –
Army Corps of Engineers to work on burning Bridgeton
Landfill
MARCH 22, 201412:00AM • BYBLYTIIE BERNHARD
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
C MISSOURI UNITED STATES ENVIRONMENTAL PROTECTION AGEN Y ATTORNEY GENERAL
The Honorable Chris Koster
Attorney General of Missouri
P.O. Box 899
Jefferson City, MO 65102
Dear Mr. Koster:
REGION 7
11201 RENNER BOULEVARD
LENEXA, KS 66219
FEB 0 9 2015 OFFICE OF
THE REGIONAL ADMINISTRATOR
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
transparency.
((Ul!
Karl Brooks
WLLFOIA4312 – 001 – 0001708

Post

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
Landfill.
• 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

Post

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

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

Post

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

Work Plan for Installation of a
Non-Combustible Cover over
Radiologically-Impacted Material
At or Near the Ground Surface in
Radiological Areas 1 and 2
West Lake Landfill Operable Unit-1
Prepared for
The United States Environmental Protection Agency Region VII
Prepared on behalf of
The West Lake Landfill OU-1 Respondents
Prepared by
Engineering Management Support, Inc.
7220 West Jefferson Avenue, Suite 406
Lakewood, Colorado 80235
In association with
Feezor Engineering, Inc.
406 E. Walnut Street
Chatham, Illinois 62629
and
Auxier & Associates, Inc.
9821 Cogdill Road, Suite 1
Knoxville, Tennessee 37932
January 4, 2016 Revised February 12, 2016
WLLFOIA4312- 001 – 0015856
Table of Contents
1 Executive Summary ………………………………………………………………………………………. 1
2 Work to be Performed ……………………………………………………………………………………. 3
2.1 Extent of Surface RIM …………………………………………………………………………….. 4
2.1.1 Surface RIM Extent ………………………………………………………………………….. 4
2.1.2 Vegetation Cover ……………………………………………………………………………… 4
2.1.3 Other Cover Material ………………………………………………………………………… 5
2.2 Buffer Zone and Crossroads Lot 2A2 Vegetative Areas Investigation ……………. 5
2.3 Placement of a Non-Combustible Cover.. …………………………………………………… 8
2.4 Vegetation Clearing ……………………………………………………………………………….. 10
2.5 Performance Testing ……………………………………………………………………………… 11
2. 5 .1 Initial Testing Prior to the Start of Construction …………………………………. 11
2.5.2 Additional Testing During Vegetation Clearing ………………………………….. 12
2.5.3 Confirmation Testing ………………………………………………………………………. 12
2.6 Demonstration of No Risk of Release from Remaining Vegetation ……………… 13
2.7 Perimeter Air Monitoring ……………………………………………………………………….. 13
2.8 Occupational Monitoring ……………………………………………………………………….. 14
2.9 NCC Inspections and Maintenance ………………………………………………………….. 15
3 Anticipated Schedule For NCC Completion ……………………………………………………. 15
4 Project Team ………………………………………………………………………………………………. 15
5 References ………………………………………………………………………………………………….. 16
Table
1 Area 1 and Area 2 Non-Combustible Cover Installation Schedule- West Lake
Landfill OU-1
Figures
1 Extent of Surface RIM as Defined in the RI – Area 1
2 Extent of Surface RIM as Defined in the RI – Area 2
3 Extent of Surface RIM and Overland Gamma Results from the RI – Area 1
4 Extent of Surface RIM and Overland Gamma Results from the RI – Area 2
5 Extent of Surface RIM and Areas of Existing Cover – Area 1
6 Extent of Surface RIM and Areas of Existing Cover – Area 2
7 Preliminary Extent of Non-Combustible Cover- Area 1
8 Preliminary Extent of Non-Combustible Cover- Area 2
9 Air Quality Monitoring Stations
10 Project Team
Attachments
1 Area 2 Sloped Rock Fill- Plan and Profile View
2 Inspection and Maintenance Plan
ii
WLLFOIA4312- 001 – 0015857
List of Acronyms
Auxier
EMSI
EPA
FEI
FS
GERT
GPS
MARSSIM
MDNR
MMP
Nai
NCC
ou
oz/sy
PPE
QA
QC
RI
RIM
SAP
TAT
TLD
UAO
VOCs
Auxier & Associates, Inc.
Engineering Management Support, Inc.
United States Environmental Protection Agency
Feezor Engineering, Inc.
Feasibility Study
General Employee Radiation Training
GeoPositioning System
Multi-Agency Radiation Survey and Site Investigation Manual
Missouri Department ofNatural Resources
Materials Management Plan
Sodium Iodide
Non-combustible Cover
Operable Unit
ounces per square yard
personal protective equipment
Quality Assurance
Quality Control
Remedial Investigation
Radiologically Impacted Material
Sampling and Analysis Plan
Turnaround Time
thermoluminescent dosimetry
Unilateral Administrative Order
Volatile Organic Compounds
iii
WLLFOIA4312- 001 – 0015858
1 EXECUTIVE SUMMARY
The purpose of this project is to install a non-combustible cover (“NCC”) over those
portions ofOU-1 Areas 1 & 2 where radiologically-impacted material (RIM) is present at
the ground surface, in order to prevent potential surface fires and migration of
contaminants from those Areas, as required by the EPA’s December 9, 2015 Unilateral
Administrative Order (UAO) issued to Bridgeton Landfill, LLC, Rock Road Industries,
Inc., and Cotter Corporation (N.S.L.) (the “OU-1 Respondents”). This Work Plan
describes the work to be performed to install the NCC in accordance with the UAO.
The sequence of actions that will occur from the start of the field work until the noncombustible
cover is in place is as follows:
1) Conduct initial overland gamma survey along the outer edges of the extent of
surface RIM/anticipated extent of rock cover (as shown on the figures in the
Work Plan) in those portions of Areas 1 & 2 that are currently accessible, as
well as in the adjacent Buffer Zone and on the adjacent Crossroad Lot 2A2
property (subject to receipt of permission to access that property).
2) Install non-combustible cover in Area 1, which will include the following:
a) Perform air monitoring- both for on-site workers and for the community
1) For on-site workers -portable air sampler onjob site
2) For community- use present air monitoring program consisting of 13
air monitoring stations around perimeter of Areas 1 & 2
b) Grub and clear trees and vegetation in the areas of surface RIM
c) Chip the vegetation and place the chips on the ground in the areas to be
covered
d) Install geotextile over the cleared areas with surface RIM including the
areas containing chipped woody vegetation cuttings
e) Install 8 inches of rock over geotextile
f) Perform additional overland gamma surveys as the vegetation is cleared
from areas that were not previously accessible due to vegetation cover to
confirm extent of surface RIM
g) Install additional geotextile and rock cover as necessary to cover any
additional surface RIM that may be identified
3) Install non-combustible cover in Area 2, including the adjacent Buffer Zone,
as needed, which will include the following:
a) Perform air monitoring- both for on-site workers and for the community
3) For on-site workers- portable air sampler on job site
4) For community- use present air monitoring program consisting of 13
air monitoring stations around perimeter of Areas 1 & 2
b) Grub and clear trees and vegetation in the areas of surface RIM
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c) Chip the vegetation and place the chips on the ground in the areas to be
covered
d) Install geotextile over the cleared areas with surface RIM including the
areas containing chipped woody vegetation cuttings
e) Install 8 inches of rock over geotextile
f) Perform additional overland gamma surveys as the vegetation is cleared
from areas that were not previously accessible due to vegetation cover to
confirm extent of surface RIM
g) Install additional geotextile and rock cover as necessary to cover any
additional surface RIM that may be identified
4) Perform additional characterization including overland gamma surveying and
soil sample collection to evaluate the potential presence and if present the
extent of surface RIM that may exist on the uncovered (naturally vegetated)
portions of Crossroads Lot 2A2 (i.e., AAA Trailer property).
5) Install rock buttress in Area 2 in that portion of the berm located above the
southeast comer of the adjacent Buffer Zone (Figure 4)
6) Perform radiological soil sampling around the perimeter on the noncombustible
covers in Areas 1 & 2 (including the Buffer Zone) to confirm all
RIM at or near the surface has been covered.
a) Send soil samples to Eberline Analytical for analysis
a. request quick turnaround time for Thorium-230
b. analyze the samples using standard tum-around times for radium,
thorium and uranium isotopes plus protactimium-231 and lead-210
(i.e., the same radiological parameters that were included in the
analyses of the Phase 1D samples and the Additional
Characterization of Areas 1 and 2 samples)
b) Perform additional clearing and covering if and as necessary based on the
initial Thorium-230 results
7) Receive results of standard tum-around time radiological analyses
8) Separately, confirm that remaining trees and vegetation do not present a fire
risk that could result in potential release of RIM into the environment (if
determined necessary by the USEPA). See Sampling and Analysis Plan for
procedures to be followed.
9) Confirm of completion of project to install non-combustible cover
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Please note that many of the above items will occur concurrently, not sequentially. For
example, installation of geotextile and rock will occur concurrently with clearing of
vegetation and performance of overland gamma surveys will occur concurrently with the
vegetation clearing. Similarly, collection of verification samples will occur whenever a
sufficient length of the anticipated final perimeter of the NCC has been installed.
Surveying to provide direction for clearing and construction and to document the
construction will occur concurrently with all of the activities.
For additional information regarding the specific procedures to be followed for this
project, please refer to this Work Plan and the following documents which are an integral
part of this Work Plan:
Health and Safety Plan for Non-Combustible Cover Installation at West Lake
Landfill, Operable Unit 1, Bridgeton, St. Louis County, Missouri dated February
8, 2016.
Radiation Safety Plan for Installation of Non-Combustible Cap, West Lake
Landfill’s Operable Unit 1, 13570 St. Charles Rock Road, Bridgeton, Missouri,
63044, dated January 4, 2016
Quality Management Plan dated December 2015
Surface RIM Identification Sampling and Analysis Plan (SAP), West Lake
Superfund Site Operable Unit 1, dated December 2015
2 WORK TO BE PERFORMED
Paragraph 34.a. of the UAO identifies the following specific items to be addressed in this
Work Plan:
1. A current West Lake Landfill map clearly indicating where RIM is located at or
near the surface in OU-1. This map should also indicate which areas with surface
RIM are currently covered by vegetation or other materials and which remain
exposed to the atmosphere.
2. Plans and schedule for placement of a non-combustible cover or barrier as soon as
possible over all exposed areas at OU-1 where RIM is currently known to be
located at or near the surface and is not otherwise covered by vegetation, fill, or
other materials.
3. Plans for grubbing and clearing all trees and vegetation where RIM is currently
known to be located at or near the surface in OU -1, and placement of a noncombustible
cover or barrier over the cleared areas.
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4. Plans and schedule for the performance of testing to confirm that RIM located at
or near the surface in OU -1 has been covered.
5. Plans and schedule for ensuring the remaining trees and vegetation in OU-1 do not
present a fire risk that could result in the potential for release of RIM into the
environment.
6. Plans and schedule for air monitoring for ensuring protection of both on-site
workers and the surrounding community during grubbing and clearing of trees
and vegetation in OU-1, as well as during placement of the cover or barrier.
7. Plans for maintenance of the cover or barrier until a remedial action selected by
EPA that addresses the surficial RIM is implemented at the Site.
The anticipated activities and schedules to complete these seven items are discussed in
the following subsections of this Work Plan.
2.1 Extent of Surface RIM
The first item specified by the UAO for the NCC Work Plan is a map of the extent of
surface RIM that also shows the areas currently covered by vegetation or other materials.
2.1.1 Surface RIM Extent
The approximate extent of surface RIM was previously identified on Figures 6-1 and 6-3
of the OU-1 Remedial Investigation report (EMSI, 2000). These figures were used as the
initial basis for defining the extent of surface RIM (Figures 1 and 2). The results of the
1995 overland gamma survey (McLaren/Hart, 1996) were also reviewed to identify other
areas where surface RIM may potentially be present in Areas 1 and 2. The results of
these evaluations are summarized on Figures 3 and 4.
2.1.2 Vegetation Cover
Over the years since active waste disposal has ceased, extensive vegetative cover has
grown over the surface of Areas 1 and 2. The aerial photography used as the base
drawing for Figures 1 and 2 displays the extent of vegetation cover on Areas 1 and 2. No
survey of the extent of vegetative cover on Areas 1 and 2 has ever been performed.
Therefore, for purposes of this NCC Work Plan, the extent of vegetative cover is assumed
to extend over all portions of Areas 1 and 2 that are not otherwise covered by inert fill or
asphalt pavement (described below).
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2.1.3 Other Cover Material
A feasibility study (FS) of potential remedial alternatives was completed in 2006 for OU-
1. The FS identified regrading of the surface of Areas 1 and 2 to promote drainage in
conjunction with installation of a new engineered landfill cover as likely components of
remedial action for OU -1. In anticipation of the regrading and landfill cover construction
activities, Bridgeton Landfill prepared a Materials Management Plan (MMP) (EMSI,
2006), which was subsequently approved by the Missouri Department of Natural
Resources (MDNR). The purpose of the MMP was to allow Bridgeton Landfill to accept
for disposal inert fill material that could be placed on the surfaces of Areas 1 and 2 to
assist with the anticipated regrading and cover construction activities. Pursuant to the
MMP, over the period from approximately 2006 through 2008, Bridgeton Landfill
accepted concrete rubble, brick and other inert fill material which was placed in a
topographic low (surface depression) in Area 1 and on the ground surface in Area 2. The
extent of inert fill material on the surface of Areas 1 and 2 is shown on Figures 5 and 6.
In addition to the inert fill material, portions of the surface of Area 1 were historically
covered with asphalt pavement. The extent of the asphalt pavement in Area 1 is shown
on Figure 5. Cracks and other discontinuities exist in the asphalt pavement such that
grasses, weeds and small trees have rooted in the area of the asphalt pavement.
Lastly, as part of recently performed additional investigations in Areas 1 and 2,
vegetation was cleared and geotextile overlain by a nominal 8-inch thick layer of road
base was placed along the roads and drill pads used to access Areas 1 and 2 to perform
additional soil borings. The locations of the various roads in Areas 1 and 2 are shown on
Figures 5 and 6.
2.2 Buffer Zone and Crossroads Lot 2A2 Vegetative Areas Investigation
It should be noted that, based on samples collected by McLaren Hart in 1995 (boreholes
WL-201 through WL-208), EMSI in 1997 (samples designated FP-1 through FP-8), and
Herst & Associates in 2000 (RC-01 through RC-07), the Remedial Investigation (RI)
(EMSI, 2000) also identified occurrences of radionuclides in surface soil in the southern
portion of what at that time was property owned by Ford Motor Credit (referred to in the
RI as the Ford property but after a subsequent parcel division and sales has since been
referred to as the Buffer Zone and Crossroads Lot 2A2), located immediately to the north
and west of Area 2. Reportedly, after completion oflandfilling activities in Area 2, but
prior to establishment of a vegetative cover over the landfill berm, erosion of soil from
the landfill berm resulted in the transport of radiologically-impacted materials from Area
2 onto the adjacent Ford property (EMSI, 2000). The landfill berm and the adjacent
properties were subsequently re-vegetated by natural processes, and no subsequent
erosion or other failures are present.
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Ford sold a portion of the property to Crossroad Properties, LLC (Crossroad), and sold
the remaining portion (the Buffer Zone) to Rock Road Industries to provide a buffer
between the landfill and the adjacent properties. In November 1999, third parties scraped
the vegetation and surface soil on Crossroad Lot 2A2 and the Buffer Zone to a depth of
approximately 2 to 6 inches. These activities were unauthorized and reportedly
conducted by AAA Trailer, the current tenant of the Crossroad property. The removed
materials were piled in a berm along the southern boundary of the Buffer Zone, adjacent
to the northwestern boundary of the West Lake Landfill. A small amount of removed
materials was also placed in a small pile on the Crossroad property near the base of the
landfill berm along the east side of Lot 2A 1.
In February 2000, additional surface soil samples (RC-01 through RC-07) were collected
from the dish1rbed area and submitted for laboratory testing. Only one sample (RC-02)
obtained from the Buffer Zone, below and adjacent to the toe of the landfill berm,
contained radionuclides (thorium-230) above levels that would allow for unrestricted use.
The remainder of the samples contained either background levels of radionuclides or
levels above background but within levels that would allow for unrestricted use. The
results of the additional soil sampling indicated that most of the radiologically impacted
soil that had previously been present on the Buffer Zone and Lot 2A2 of the Crossroad
property had been removed and placed in the stockpiles. Evaluation of the soil sampling
results obtained prior to and after the 1999 disturbance indicates that approximately one
acre of the Buffer Zone may at that time still have contained some radionuclides above
levels that would allow for unrestricted land use (i.e., combined radium or combined
thorium activities greater than 5 pCi/g plus background which equates to 7.9 pCi/g).
Inspection of the area in May 2000 indicated that native vegetation had been reestablished
over both the disturbed area and the stockpiled materials. The sequence of
soil sampling activities and associated results are presented in the RI (EMSI, 2000)
A 2004 inspection of this area indicated that additional soil removal/re-grading had been
performed on the remaining portion of the Crossroad property and the adjacent Buffer
Zone property by, or on the behalf of, AAA Trailer. These activities appear to have
resulted in removal of the soil stockpiles created during the previous re-grading activity
reportedly conducted by AAA Trailer, removal of any remaining soil on Lot 2A2 and the
Buffer Zone not scraped up during the 1999 event, and placement of gravel over the
entirety of Lot 2A2 and the Buffer Zone. According to AAA Trailer, all of the soil
removed during the July 1999 grading work and the May 2003 gravel layer installation
was placed in the northeastern comer of the Buffer Zone (terra technologies, 2004).
No sampling has been performed since the most recent (May 2003) grading work
conducted by AAA Trailer, and therefore the levels and extent of radionuclides, if any,
that may remain in the soil at the Buffer Zone and Crossroad Property are unknown. As
discussed above, the entire area was covered with gravel and portions of this area were
subsequently paved by AAA Trailer. In addition, as discussed in Section 2.2 below, it is
anticipated that a temporary rock buttress will be constructed on the Buffer Zone parcel
to provide for an NCC on the landfill slope in this area. Therefore, any surface RIM that
may still exist on the Buffer Zone property will be covered by the temporary rock
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buttress. Additional soil sampling to determine current conditions with respect to
radionuclide occurrences in the Buffer Zone and Crossroad Property soil are expected to
be conducted as part of remedial design activities associated with implementation of the
selected remedy for this area.
Additional discussion of the prior sampling and activities relative to the Buffer Zone and
Crossroads Lot 2A2 can be found in the RI (EMSI, 2000), Feasibility Study (EMSI,
2006) and Supplemental Feasibility Study (EMSI, 2010).
The entire Buffer Zone is currently owned by Rock Road Industries, Inc. and is therefore
currently accessible to the Respondents for purposes of performing the required work.
The Buffer Zone will be scanned via overland gamma scan according to the procedures
specified in the Work Plan and associated planning documents (e.g., Sampling and
Analysis Plan). The overland gamma survey will be performed using Ludlum 44-10
(2×2) Sodium Iodide (Nai) detectors coupled to Ludlum 2221 survey meters modified to
integrate and transfer data from the detector at a rate of once per second to a Trimble
GeoPositioning System (GPS) which stores the gamma reading and the location of that
reading. If the scanning procedures indicate the potential for RIM, the affected areas will
be cleared of vegetation followed by placement of a geotextile fabric and a nominal 8-
inches of road base material. After clearing has occurred 10 feet beyond the extent of
surface RIM identified in the Work Plan, or as further defined by the results of the
overland gamma survey to be conducted along the perimeter of the outer boundary of the
extent of surface RIM/outer edge of the NCC, confirmation samples will be collected at
approximately 100 feet spacing along the perimeter except for those areas where the
outer edge of the surface RIM/NCC coincides with the edges of the Buffer Zone. More
frequent biased samples will be obtained from any potential erosional depositional areas
that may be identified during the vegetation clearing, overland gamma survey or NCC
installation activities.
Crossroads Lot 2A2, which is located adjacent to the Buffer Zone, is not owned or
controlled by Respondents, but is owned by others, and therefore is not accessible to the
Respondents at this time. After receipt of EPA approval to do so, the OU-1 Respondents’
Project Coordinator will contact the current owner of Crossroads Lot 2A2 to obtain
permission to conduct additional characterization via overland gamma scanning and
confirmation testing within all uncovered areas of Lot 2A2 that are contiguous with the
West lake Landfill Area 2 Fence. The same procedures (overland gamma scanning and
confirmation sampling) will be used as described above for the Buffer Zone. Upon
receipt of site access to conduct the additional characterization work on Lot 2A2, such
work will be conducted in accordance with any conditions imposed by the property
owner and as soon as personnel and equipment can be made available without otherwise
disrupting work associated with construction of the NCC. The results of the additional
characterization will be provided to the USEP A.
A specific schedule has not been established for the additional characterization of the
Buffer Zone or portions of Crossroads Lot 2A2. It is expected that once sufficient
vegetation has been cleared, it should only take approximately one day to perform the
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overland gamma survey of the Buffer Zone. This work will be done once the contractor
clears the vegetation from the Buffer Zone, which will occur after the contractor clears
the vegetation leading to the edge of the top of Area 2 and from the slope of the landfill
berm above the Buffer Zone and builds a ramp from the top of the slope down to the
Buffer Zone. A specific schedule has not been established for these clearing and rampbuilding
activities.
It is anticipated that overland gamma surveying of uncovered, natural vegetation areas on
Crossroads Lot 2A2 can be completed in a few hours (provided we receive permission to
do so). Any additional characterization work associated with certain areas of Lot 2A2
will not be contingent on any work which would be performed in the Buffer Zone.
Coordination with EPA to obtain to access and additional characterization of Lot 2A2
will begin within 14 days of EPA’s approval of the work plan.
2.3 Placement of a Non-Combustible Cover
Based on the extent of RIM described in Section 2.1 and shown on Figures 3 and 4, and
also taking into account the extent of inert fill material and road base that currently exists
in Areas 1 and 2 (Figures 5 and 6), the anticipated extent of the NCC has been identified
as shown on Figures 7 and 8. Please note that the extent of asphalt pavement in Area 1 is
not included as part of the extent of existing cover material because as noted above,
vegetation has grown up through cracks and other discontinuities in the asphalt pavement
and asphalt is not considered to be a non-combustible material. By comparison, the inert
fill material and road base that currently exist in Areas 1 and 2 were included as part of
the estimation of existing cover material. The areas of inert fill that are in close
proximity to the proposed extent of new non-combustible cover will need to be visually
inspected to determine if any additional rock cover needs to be place on or adjacent to the
existing inert fill material.
Given that the extent of surface RIM in Areas 1 and 2 is approximately 1.4 acres in Area
1 and 8.74 acres in Area 2 and the extent of existing inert fill and road base cover is
approximately 0.4 acres in Area 1 and 0.79 acres in Area 2, the total area for NCC
constmction in Areas 1 and 2 is estimated to be 1.0 and 7.95 acres, respectively. In order
to ensure that the extent of surface RIM in these areas is completely covered, the bid
specifications for the NCC will require the contractor to extend the cover placement
nominally 10 ft beyond the edge of all areas where surface RIM is identified as being
present within Areas 1 and 2; however, the cover will not extend beyond the limits of the
Area 1 or 2 waste disposal units. Therefore, the total extent of the NCC cover is
anticipated to be approximately 1.2 acres in Area 1 and 8. 7 5 acres in Area 2 for a total
area of approximately 10 acres in these two areas.
Placement of a NCC over these areas will entail cutting/removal of the existing
vegetation in these areas followed by placement of a geotextile fabric and a nominal 8-
inches of road base material. The anticipated profile for the NCC is shown on Figures 7
and 8. If evidence of surface water flows and sediment deposition is noted outside of the
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areas to be covered by the NCC, a sample of the sediment area will be collected and
tested as part of the confirmation testing (see Confirmation Testing, Section 2.5.3). If the
analytical testing of the sediment sample indicates the presence of surface RIM, the area
of sediment accumulation associated with such a sample will be covered with a geotextile
and new rock fill.
The vegetation will be cleared with a forestry mower attached to a low ground pressure
tractor such as a skid steer. The vegetation will be moistened as necessary to minimize
visible dust prior to the forestry mower advancing. Rutting will be minimized by the
equipment selection. Metal items or other debris on the surface of the existing landfill will
be moved to an area or areas within Area 1 or 2 outside of the extent of where surface RIM
exists. The debris will be stockpiled on the existing asphalt pavement in Area 1 and/or on
the existing inert fill in Area 2, or otherwise placed in an area( s) outside of the extent of
surface RIM/non-combustible cover.
Rock stockpiles may be used for temporary storage of rock prior to placement within the
NCC cover area, but it is generally expected the rock material will be delivered to the NCC
cover area via tandem on-road haul trucks, and the trucks will only drive on previously
rocked areas and deposit the rock onto the advancing front of the cleared areas. The
geotextile and rock placement will occur in such a manner that all newly cleared areas will
be covered generally within 24 hours, but not more than 48 hours after clearing.
The source of the rock will be from a local quarry (most likely the Fred Weber quarry in
Maryland Heights, MO). The field engineer will collect load tickets from the drivers to
verify at the end of the day to verify the source of rock was from a commercial quarry.
It is likely that surface RIM is present along a portion of the landfill berm on the north
side of Area 2, specifically in that portion of the berm located above the southeast comer
of the adjacent Buffer Zone (Figure 4 ). Because of the steep slope (1.5H: 1 V) associated
with the landfill berm, placement of geotextile with 8-inches of road base is not
anticipated to provide for a stable cover. Therefore, in this area, a temporary rock
buttress will be constructed from the base to near the top of the landfill berm. The rock
buttress will be constructed by clearing vegetation from the Buffer Zone and from the
landfill berm slope to the extent it can be conducted in a safe manner, followed by
placing road base material on the Buffer Zone and extending up the face of the landfill
berm. Attachment 1 presents a drawing of the preliminary design for the rock buttress.
This rock buttress would be temporary, and, if necessary, most of the rock could be
reclaimed during implementation of future remedial actions that may be implemented at
the Site.
The OU-1 Respondents have employed the procurement services ofBridgeton Landfill,
Inc. and Republic Services, Inc. to procure a contractor to perform the vegetation clearing
and construct the NCC. A bid package was completed and released to the prospective
contractors on January 12, 2016 and that bids were received by January 22, 2016.
Review of the bids and notice of intent to award were completed by February 3, 2016.
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The bid package included a sample contract with the West Lake Landfill NPL Site Trust
(“the Trust”) so the prospective contractors were aware of all contract conditions.
It is anticipated that installation of the NCC will begin on February 15, 2016 subject to
weather conditions and the availability of the contractor personnel, necessary equipment
(e.g., forestry mower) and required materials (e.g., geotextile). Prior to starting any work
on site, the selected contractor personnel will be provided General Employee Radiation
Training (GERT) if they have not already received it, as well as an overall orientation to
Bridgeton Landfill safety procedures and communication of potential hazards associated
with the NCC project. EPA was provided notice of the contractor selected to perform the
work (Keusel Excavating Co. Inc.) on February 3, 2016 as set forth in Paragraph 30 of
the UAO. EPA was provided notice of the intended start of construction on February 12,
2016, in accordance with Paragraph 36(c) of the UAO.
2.4 Vegetation Clearing
Vegetation removal and construction of the NCC are anticipated to be performed using
procedures similar to those previously employed to construct the access roads and drill
pads during the prior Phase 1, Phase 1D, and Additional Characterization of Areas 1 and
2 investigations. Specifically, the vegetation will be cut near but above the ground
surface using a “brush hog”, a skid steer with a forestry cutter/grinder attachment, or
equivalent equipment. Such equipment can cut and grind woody vegetation without
disturbing the underlying ground surface or vegetation roots. The vegetation cuttings
will be chipped and placed on the ground surface. Any significantly sized wood
vegetation) that needs to be removed will be cut with tree shears and chipped in a wood
chipper. If necessary, the woody vegetation will be moistened with a water cannon prior
to grinding to minimize chipping dust. The chipped woody vegetation will be placed
beneath the extent of the NCC prior to geotextile deployment. Any material that is too
large to chip (such as larger tree limbs or trunk sections) will be cut into 10 foot sections
and placed in low lying areas and covered with geotextile and rock. The goal will be to
minimize any uncovered logs long term. Should this not be possible, the logs will be
neatly placed in an area where there is no RIM at or near the surface.
A geotextile will be laid on top of the cleared area and vegetation chips over which
approximately 8 inches of road base material will be placed. Profile views of the final
NCC are provided on Figures 7 and 8. Based on prior experience with building drill pad
access roads in Areas 1 and 2, it is anticipated that additional road base material will need
to be placed in any depressed areas or at the base of any steep slopes (e.g., steeper than
4H:1V).
The areas of the inert fill that are in close proximity to the proposed extent of new noncombustible
cover will visually inspected to determine if any additional fill placement is
necessary in the transition area between the new rock cover and the existing inert fill.
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It is anticipated that placement of the geotextile and rock cover material will
generally occur the same day as the vegetation removal activities, but in any event
should be completed within 48 hours of the vegetation clearing in any particular
area. Should heavy rain be forecasted and an area cannot be covered the same day,
storm water waddles will be placed on any downslope areas. In addition, vegetation
clearing will not be performed during periods when severe thunderstorms or major
precipitation events (rainfall of a rate of over Y2 inch per hour) are forecasted for the
site area or when observations by on-site personnel indicate a potential for a severe
thunderstorm or major precipitation event. Additionally, on days when precipitation
is anticipated to occur, placement of geotextile and rock cover will be coordinated to
closely follow the vegetation clearing activities and the vegetation clearing will be
closely monitored and/or suspended as necessary to ensure that the geotextile and
sufficient cover necessary to anchor the geotextile can be placed prior to the
occurrence of thunderstorms.
NCC construction will only occur during days where the working temperatures will be 25
degrees or higher. The average temperature for February is approximately 35 degrees
and the average temperature for March is above 40 degrees, so this requirement should
generally not limit construction. Should the temperatures drop below freezing, caution
will be used to avoid using too much water (needed for dust suppression) to avoid ice
accumulations to prevent slips, trips or falls.
2.5 Performance Testing
It is anticipated that testing will be conducted in three phases to verify the extent of
surface RIM and to confirm that the NCC extends over the full extent of surface RIM.
2. 5 .1 Initial Testing Prior to the Start of Construction
Subject to physical access constraints posed by the existing vegetation cover, an initial
overland gamma survey will be performed along the margins of the estimated extent of
surface RIM (Figures 3 and 4) to provide an initial verification of the extent of surface
RIM. Prior to conducting the overland gamma survey, a reference area or areas will be
identified and overland gamma survey background values will be obtained from this
area(s).
The overland gamma survey will be performed using Ludlum 44-10 (2×2) Sodium Iodide
(Nai) detectors coupled to Ludlum 2221 survey meters modified to integrate and transfer
data from the detector at a rate of once per second to a Trimble GeoPositioning System
(GPS) which stores the gamma reading and the location of that reading. The detectors
will be hung approximately six-inches above the ground surface and advanced at a rate of
approximately 0.5 meters per second. Separation between the scanned transit lines will be
approximately 1.5 meters unless influenced by terrain. Stored data will be downloaded
and processed using commercially available software applications and plotted on a map
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of the Areas. Individual points will be assigned colors based on the magnitude of
instrument response at that location.
Additional details regarding the data quality objectives and the procedures to be used for
the overland gamma survey can be found in the Sampling and Analysis Plan (SAP)
(Auxier, 2015a).
No problems or issues for performance of the overland gamma survey are expected to be
encountered from vegetation hindrances because the overland gamma survey will be
performed prior to or in conjunction with the clearing of vegetation from the areas
identified as containing, or potentially containing surface RIM.
2.5.2 Additional Testing During Vegetation Clearing
Based on the maps generated from the initial overland gamma survey, remaining
inaccessible areas that may contain surface RIM will be identified for vegetation clearing.
A health physicist will then be assigned to perform additional overland gamma surveys in
conjunction with the vegetation clearing activities to further verify the extent of surface
RIM. These surveys will be conducted using the same techniques described above for
the initial survey. The results of the additional surveys will be added to the map of the
results obtained from the initial survey.
2.5.3 Confirmation Testing
Once the results of the overland gamma surveys described above define the extent of
surface RIM, surface soil samples will be obtained along the perimeter to confirm the
absence of RIM beyond the extent determined by the overland gamma surveys. It is
anticipated that the surface soil sampling will be performed outside the perimeter of the
defined surface RIM/outer extent of the NCC to verify that thorium-230 (which cannot be
detected by the overland gamma survey) is not present outside the outer limit of the new
cover at activity levels greater than the level that would allow for unrestricted land use. It
is anticipated that soil samples will be collected from locations spaced approximately 100
feet apart along the perimeter of the outer boundary of the extent of surface RIM/ outer
edge of the NCC except for those areas where the outer edge of the surface RIM
coincides with the edges of the Area 1 or Area 2 waste disposal unit boundaries. More
frequent biased samples will be obtained from any potential sediment depositional areas
that may be identified during the vegetation clearing, overland gamma survey or NCC
installation activities. This confirmation testing will occur on the edge of the 10-foot
outer clearing limit, so the area will be cleared of vegetation.
Surface soil samples (if any) will be submitted to Eberline Analytical Laboratory
(Eberline) for quick tum-around-time (TAT) isotopic thorium analysis. The quick TAT
isotopic thorium analyses will allow for an initial, quick determination as to whether the
extent ofNCC is sufficient or ifplacement of additional NCC may be required while the
NCC contractor is still present at the site. The samples will also be analyzed for isotopic
NCC Work Plan
1/4/2016 Revised2-12-16
Page 12
WLLFOIA4312- 001 – 0015870
uranium and gamma spectroscopy in order to provide data comparable to the other
investigatory data obtained from OU-1 areas.
2.6 Demonstration ofNo Risk of Release from Remaining Vegetation
Upon completion of the installation of the NCC and subject to performance of routine
inspection and maintenance activities to verify that the NCC remains effective in
isolating the RIM from the atmosphere or surface events (e.g., exposure to vegetation
fire, erosion by wind or water, etc.), there should not be any potential for surface releases
from the areas covered by the NCC.
Vegetation located outside the extent of surface RIM will remain on site. The results of
the previous (2009) collection and analysis of vegetation samples demonstrated that the
site vegetation contains only background levels ofradionuclides (T.A. Woodford and
Associates, 2009). Therefore, in the event of a vegetation fire in these areas, the
remaining vegetation at the site is not anticipated to pose any risk of release of
radionuclides.
Discussions with EPA have indicated that they are still reviewing the results of the 2009
vegetation sampling event relative to the potential for release of radionuclides in the
event a vegetation fire occurs at the site. If EPA concludes that the existing sample data
provide sufficient basis to demonstrate that the remaining vegetation would not pose a
risk of release in the event of a fire, no additional sampling will be conducted. If EPA
determines that additional sample collection and analyses are required to complete the
specified demonstration, additional samples will be obtained as necessary to demonstrate
that the remaining vegetation does not pose a threat of release of radionuclides in the
event of a fire.
The Sampling and Analysis Plan (Auxier, 2015a) being submitted in conjunction with
this Work Plan contains additional details regarding the scope and procedures to be used
in the event that additional vegetation sample collection and analyses are requested by
EPA.
2.7 Perimeter Air Monitoring
Pursuant to a prior request from EPA, the OU -1 Respondents previously implemented an
air monitoring program consisting of 13 stations located around the perimeters of Areas 1
and 2 and elsewhere at the West Lake Landfill/Bridgeton Landfill site (Figure 9).
Specifically, an Air Monitoring, Sampling and QA/QC Plan was prepared (Auxier &
Associates, Inc., 2014), and was approved by EPA on December 5, 2014. Installation of
the air monitoring stations was performed in early 2015, and continuous air monitoring
began on May 1, 2015. A report of the results from the first quarter of air monitoring
activities (May, June and July 2015) was submitted to EPA on December 9, 2015 (Auxier
and EMSI, 20 15).
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Page 13
WLLFOIA4312- 001 – 0015871
The perimeter air monitoring activities include sampling for airborne radioactive
particulates, radon gas, and volatile organic compounds (VOCs), and measurements of
gamma radiation. Sampling is performed continuously at the perimeters of OU -1 Areas 1
and 2. All 13 monitoring stations include air sampling pumps equipped with air sample
filters for collection of particulate samples for analyses of alpha and beta emitters. The
particulate filters are collected every four weeks (28 days) and sent to Eberline Analytical
for laboratory analyses. One set of the three sets of filter samples obtained during each
calendar quarter are also analyzed for uranium and thorium isotopes and for radium by
gamma spectroscopy. All 13 monitoring points also include radiation dosimeters for
measurement of gamma radiation, and alpha track etch detectors for measurement of
radon emissions that are submitted for laboratory analysis by Mirion Technologies and
AccurStar, respectively, every calendar quarter.
Five of the monitoring stations house continuous passive samplers to monitor for VOCs.
Monitoring ofVOCs is performed using the Radiello Code 130 chemical adsorbing
cartridge diffusion samplers that are left in place for periods of 14 days. These sampling
devices are submitted to EuroFins Air Toxics Ltd for VOC analyses.
Data obtained from the ongoing perimeter air monitoring program are expected to be the
primary method for evaluation of protection of the surrounding community during
installation of the NCC over the surface RIM in OU-1.
2.8 Occupational Monitoring
In addition to the continued operation of the perimeter air monitoring program currently
employed for Areas 1 and 2, temporary air monitoring activities will be conducted during
the vegetation clearing and NCC placement activities. Specifically, portable air pumps
equipped with filters will be set up near active work areas and/or installed on equipment
to obtain particulate samples for analysis for alpha and beta emitters.
Ambient radiation levels in work areas will be routinely monitored during NCC
construction. In addition, all workers will wear thermoluminescent dosimetry (TLD)
badges to monitor their exposures to gamma radiation. The data obtained from analysis
of samples collected by the portable air sampling equipment and TLDs will be used to
verify that site workers are not exposed to radiation or radioactive materials above
permissible levels.
In conjunction with use of personal protective equipment (PPE) and adherence to
procedures set forth in the Health and Safety Plan (Auxier, 2015b) and Radiation Safety
Plan (Auxier, 2015c ), the results obtained from the perimeter and portable air sampling
points and TLDs will be used to ensure protection of site workers.
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Page 14
WLLFOIA4312- 001 – 0015872
2.9 NCC Inspections and Maintenance
Quarterly inspections will be performed by a designee of the OU-1 Respondents to verify
that the NCC remains intact and that stormwater runoff, burrowing animals or other
activities have not caused any impacts that would affect the performance of the NCC.
Additional inspections will be conducted after major precipitation events of sufficient
intensity and/or duration to potentially impact the integrity of the NCC.
A description of the anticipated NCC inspection and maintenance activities is included as
Attachment 2.
3 ANTICIPATED SCHEDULE FOR NCC COMPLETION
Table 1 presents an anticipated schedule for the various activities to be conducted to
place the NCC over the surface RIM, collect and analyze samples to confirm that the
NCC completely encompasses the surface RIM, and, if necessary, collect and analyze
samples of vegetation obtained from outside the extent of surface RIM to further support
the demonstration that in the event of a fire, the remaining vegetation will not result in a
release of radionuclides. Subject to weather conditions, equipment and material
availability and other factors, the OU -1 Group anticipates installation of the additional
cover material will be completed within approximately 90 days of EPA approval of this
Work Plan and the related project plans.
The status and results of the work performed to plan, construct and inspect/maintain the
NCC cover will be tracked and reported to EPA in monthly status reports, as required by
the UAO. A final report documenting the NCC installation is anticipated to be completed
within 30 days of receipt of the final analytical laboratory report for the confirmation soil
samples.
4 PROJECT TEAM
The project team will consist primarily of contractors that have previously been working
in Areas 1 and 2 along with a construction contractor to be retained to perform the
vegetation clearing and placement of the non-combustible cover.
Engineering Management Support, Inc. (EMSI) will provide overall coordination of the
work including coordination of preparation of project plans, coordination of the various
contractors, and coordination with EPA. Specifically, Paul Rosasco, P.E., the designated
Project Coordinator under the UAO, will serve as the overall Project Coordinator for the
Respondents, with assistance from Robert Jelinek, P.E. EMSI will also be responsible
for preparation of monthly progress reports and overall coordination of the final report
for the NCC installation project.
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WLLFOIA4312- 001 – 0015873
Feezor Engineering, Inc. (FEI) will provide office and field engineering services,
including preparation of design and record drawings, supervision and documentation of
field activities, and collection of confirmation surface soil samples (as necessary). Daniel
Feezor, P.E., will serve as lead Project Engineer and Jonathan Wilkinson, P.E., will be
lead Field Engineer for this project. FEI will also perform post-installation NCC
inspections to verify that the NCC remains intact and identify any maintenance or repair
activities that may be required.
Auxier & Associates, Inc. (Auxier) will provide health physics services including
performance of radiation surveys including but not limited to overland gamma surveys,
perimeter air monitoring, occupational monitoring during NCC construction, and free
release surveys for equipment exiting Area 1 and 2. Michael R. Bollenbacher, CHP will
serve as lead health physicist and radiation safety officer. Mr. Bollenbacher will be
assisted by Cecilia Greene, MPH who will serve as the Health Physics project manager.
Alex Luna will be the on-site health physics technician and site safety officer. Auxier
will be responsible for implementation of the project health and safety and radiation
safety plans for this work.
Weaver Consultants Group (Weaver) will survey the locations where confirmation
surface soil samples are collected, provide survey control during construction, and survey
the outer limits of the final, installed NCC. Collin Carson will serve as lead surveyor for
the NCC installation project.
Eberline Analytical/Oak Ridge Laboratory will perform radionuclide analyses of soil
samples collected to provide confirmation that the NCC extends beyond the extent of
surface RIM.
Kuesel Excavating Co., Inc. was selected as the construction contractor for the vegetation
clearing and installation of the non-combustible cover over areas where RIM is present or
potentially is present at or near the ground surface in Areas 1 and 2 and the Buffer Zone.
Kuesel Excavating Co., Inc., is based in O’Fallen, Missouri and has been performing
demolition, clearing, grading, utility installation, stream back restoration, and soil
stabilization related services in Missouri for over 50 years. Relative to Bridgeton
Landfill, Kuesel recently provided demolition services and sub-grade preparation related
to construction of the leachate pre-treatment system and is currently working on
stormwater drainage improvements for the site.
5 REFERENCES
Auxier & Associates, Inc. (Auxier), 2015a, Surface Rim Identification, Sampling, and
QA/QC Plan, West Lake landfill Superfund Site Operable Unit-1, December.
Auxier, 2015b, Draft Health and Safety Plan for Non-combustible Cover Installation at
West Lake Landfill, Operable Unit-1, Bridgeton, St. Louis County, Missouri, December
21.
NCC Work Plan
1/4/2016 Revised2-12-16
Page 16
WLLFOIA4312- 001 – 0015874
Auxier, 2015c, “Radiation Safety Plan for Installation ofNon-combustible Cap, in
Operable Unit 1 of Westlake Landfill Operable Unit-1, December 21.
Auxier, 2014, Air Monitoring, Sampling and QA/QC Plan, West Lake Landfill
Superfund Site Operable Unit-I.
Auxier and EMSI, 2015, West Lake Landfill Perimeter Air Monitoring Quarterly Report,
December.
Engineering Management Support, Inc. (EMSI), 2006, Materials Management Plan, West
Lake Landfill Operable Unit 1.
EMSI, 2000, Remedial Investigation Report, West Lake Landfill Operable Unit 1, April
10.
McLaren/Hart, 1996, Overland Gamma Survey Report, West Lake Landfill Radiological
Areas 1 and 2, Bridgeton Missouri, April30.
T.A. Woodford and Associates, LLC, 2009, Vegetation Sampling Results Summary in
Support of Health and Safety Plan for Vegetation Clearing and Grubbing, March.
terra technologies, 2004, Letter to Ms. Cheryle Micinski, USEPA from David Heinze,
terra technologies re: Clarifications to Information Request, West Lake Landfill Site,
September 10, 2004.
United States Environmental Protection Agency (EPA), 2015, Letter from Alyse Stoy
(EPA) to William Beck, Esq. and Jessica Merrigan, Esq., John McGahren, Esq., Steven
Miller, Esq., and Phil Dupre, Esq. RE: In the Matter of Cotter Corporation (NSL), and
Laidlaw Waste Systems (Bridgeton), Inc. and Rock Road Industries, Inc., and the U.S.
Department of Energy, Administrative Order on Consent, EPA Docket No. VII-93-F-
0005, December 9.
EPA, U.S. Department ofEnergy, U.S. Nuclear Regulatory Commission, and U.S.
Department of Defense, 2000, Multi-Agency Radiation Survey and Site Investigation
Manual (MARSSIM), NUREG-1575, Rev 1, EPA 402-R-97-016, Rev. 1, DOE/EH-0624,
Rev. 1, August.
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Page 17
WLLFOIA4312- 001 – 0015875
Table
WLLFOIA4312- 001 – 0015876
Table 1- Westlake OU-1
Area 1 and Area 2 Non Combustible Cover Installation
ID ask Name
Submit Work Plan to USEPA
USEPA Review and Approval of Work Plan
Planning I Bidding
Send Contractors Bid Package
Pre Bid Meeting
6 Bids Due
7 Award Contract
8 Field Work
9 Conduct Overland Gamma Survey
Install NCC Area 1
Install NCC Area 2
12 Install Rock Buttress
Task
Split
Milestone
Project: West Lake NCC Constru
Date: Fri 2/12/16 Summary
Project Summary
Inactive Task
Inactive Milestone
Duration Start Finish 2016
0 days Man 1/4/16 Man 1/4/16
4wks Man 1/4/16 Fri 1/29/16
19 days Fri 1/8/16 Wed 2/3/16
1 day Fri 1/8/16 Fri 1/8/16
3 days Man 1/11/16 Wed 1/13/16
2 wks Man 1/11/16 Fri 1/22/16
8 days Man 1/25/16 Wed 2/3/16
43 days Wed 2/10/16 Fri 4/8/16
6 wks Wed 2/10/16 Tue 3/22/16
1 wk Man 2/15/16 Fri 2/19/16
4wks Man 2/22/16 Fri 3/18/16
3 wks Man 3/21/16 Fri 4/8/16
Inactive Summary External Tasks
Manual Task External Milestone
Duration-only Deadline
Manual Summary Rollup —–Manual
Summary
Progress
Manual Progress
Start-only
Finish-only
Page 1
• +
WLLFOIA4312- 001 – 0015877
Table 1- Westlake OU-1
Area 1 and Area 2 Non Combustible Cover Installation
IDl~ ~~ask IT ask Name
Mode
II!; Project Wrap Up
14 I Radiological sampling around perimeter of
NCC
15 Radiological sample testing and data
validation
16 I Final Report preparation and submittal
Task
Split
Milestone
Project: West Lake NCC Constru
Date: Fri 2/12/16 Summary
Project Summary
Inactive Task
Inactive Milestone
~Duration I Start ~Finish
Dec
2~a1n6
I Feb r I Mav I Jun I Jul
65 days Mon 3/28/16 Fri 6/24/16
1 wk Man 3/28/16 Fri 4/1/16 il
8 wks Man 4/4/16 Fri 5/27/16
4wks Man 5/30/16 Fri 6/24/16
Inactive Summary External Tasks
Manual Task External Milestone • Duration-only Deadline +
Manual Summary Rollup —— Progress
1 Manual Summary
Start-only
Finish-only
Page 2
I Manual Progress
WLLFOIA4312- 001 – 0015878
Figures
WLLFOIA4312- 001 – 0015879
M:\CUENlS\ENSI\ WESTIAKE\2015\RUBBLE -INVESTIGATION\RUBBLE -PAUL -BUILDUP.DWG-AREA 1-FIG1 01/04/2016 4:11PM
LEGEND
– – – – – – Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
(from Figure 6-3 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Notes:
x 2015 Topography And Backround Image Provided By
Cooper aerial Surveys Co. – Dated February 10, 2015
x all Elevations Are Above Mean Sea Level (amsl)
100
!
~
—__-_,j0 SCALE IN
100
FEET
Figure 1
Extent of Surface RIM as
Defined in the Rl
Area 1
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015880
LEGEND
Notes:
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
Approximately 10.6 Acres
(from Figure 6-5 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
x 2015 Topography and Backround Image Provided by
Cooper Aerial Surveys Co.- Dated February 10, 2015
x All Elevations are Above Mean Sea Level (amsl)
150
!
~
0
—..-..1 SCALE IN
150
FEET
Figure 2
Extent of Surface RIM as
Defined in the Rl
Area 2
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015881
M:\CUENlS\ENSI\ WESTIAKE\2015\RUBBLE -INVESTIGATION\RUBBLE -PAUL -BUILDUP.DWG-AREA 1-FIG3 01/04/2016 4:11PM
LEGEND
– – – – – – Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
(from Figure 6-3 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Notes:
Overland Gamma Reading,
Background or Less
Overland Gamma Reading,
2x Background or Less
Overland Gamma Reading,
More Than 2x Background
x 2015 Topography And Backround Image Provided By
Cooper aerial Surveys Co. – Dated February 10, 2015
x all Elevations Are Above Mean Sea Level (amsl)
100
!
~
0
—..-..1 SCALE IN FEET
100
Figure 3
Extent of Surface RIM and Overland
Gamma Results from the Rl
Area 1
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015882
LEGEND
Notes:
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
Approximately 10.6 Acres
(from Figure 6-5 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Potential Additional Areas Where Surface
Radionuclide Impacted Material May be Present
Approximately .74 Acres
Overland Gamma Reading,
Background or Less
Overland Gamma Reading,
2x Background or Less
Overland Gamma Reading,
More Than 2x Background
x 2015 Topography and Backround Image Provided by
Cooper Aerial Surveys Co.- Dated February 10, 2015
x All Elevations are Above Mean Sea Level (amsl)
150
!
~
0
—.-..1 SCALE IN FEET
150
Figure 4
Extent of Surface RIM and Overland
Gamma Results from the Rl
Area 2
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015883
N:\CUENTS\ENSI\ WESTIAKE\2015\RUBBLE -INVESTIGATION\RUBBLE -PAUL -BUILDUP.DWG-AREA 1 FIGS 01/04/2016 4:12PM
Notes:
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
Approximately 1.4 Acres
(from Figure 6-3 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000 )
Potential Extent of Existing Asphalt Cover
Existing Rock Cover Around Septic Tank
Area Where Inert Fill Exists
Newly Constructed Road
x 2015 Topography And Backround Image Provided By
Cooper aerial Surveys Co. – Dated February 10, 2015
x all Elevations Are Above Mean Sea Level (amsl)
120
!
~ 0 120 —– SCALE IN FEET
Figure 5
Extent of Surface RIM and Areas of
Existing Cover
Area 1
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015884
LEGEND
Notes:
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
Approximately 10.6 Acres
(from Figure 6-5 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Potential Additional Areas Where Surface
Radionuclide Impacted Material May be Present
Approximately .74 Acres
Approximate Limit of Rock Buttress
(See Attachment A for Additional Details)
Area Where Inert Fill Exists
Areas Outside Inert Fill
Where Slope Exceeds 5:1
Newly Constructed Road
x 2015 Topography and Backround Image Provided by
Cooper Aerial Surveys Co.- Dated February 10, 2015
x All Elevations are Above Mean Sea Level (amsl)
150
!
~
0
—.-..1 SCALE IN FEET
150
Figure 6
Extent of Surface RIM and Areas of
Existing Cover
Area 2
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015885
M:\CUENlS\EMSI\ WESTIAKE\2015\RUBBLE -INVESTIGATION\RUBBLE -PAUL -BUILDUP.DWG-AREA 1 FIG7 01/04/2016 4:12PM
LEGEND
Notes:
Proposed Extent of New Non-Combustible Cover
d $SS…R[ l..ffi’I.IID\ L 1 L 91 ~ ~ L $R..Hv’=
Proposed Extent of New Non-Combustible Cover
91 !! L RII\H/11- d $SS…R[ l..ffi’I.IID\ L 1 L 91 ~ ~ L
Potential Extent of Existing Asphalt Cover
Existing Rock Cover Around Septic Tank
Newly Constructed Road
d $SS…R[ LFI)I’H)\ L 1 L ~ ~ L $R..Hv’
Within Proposed Extent of New
Non-Combustible Cover)
x 2015 Topography And Backround Image Provided By
Cooper aerial Surveys Co. – Dated February 10, 2015
x all Elevations Are Above Mean Sea Level (amsl)
100
NON-COMBUSTIBLE COVER PROFILE
—–0 SCALE IN FEET
100
8 Inches (nominal) of Rock
10 oz/sy Non-Woven Geotextile
and Chipped Vegetation (if present)
Figure 7
Preliminary Extent of
Non-Combustible Cover- Area 1
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015886
LEGEND
Notes:
Proposed Extent of New Non-Combustible Cover
cJ $S’3_R[ l..ffi’\1-0\ L 1 L ~ ~ 4 ~ L $R…HJ=
Proposed Extent of New Non-Combustible Cover
91 !! L RII\H/11- L d $S’3R[ LFI)I’H)\ L v v 1 ~ T
Limit of Rock Buttress (See Attachment A for
Additional Details)
Area Where Inert Fill Exists
Areas Outside Inert Fill
Where Slope Exceeds 5:1
Newly Constructed Road
cJ $S’3R [ LFI)I’H)\ L 1 L ~ 4 L $R..Hv’
Within Proposed Extent of New
Non-Combustible Cover)
x 2015 Topography and Backround Image Provided by
Cooper Aerial Surveys Co.- Dated February 10, 2015
x All Elevations are Above Mean Sea Level (amsl)
NON-COMBUSTIBLE COVER PROFILE
8 Inches (nominal) of Rock
10 oz/sy Non-Woven Geotextile
w~~~?:!:~~i’R~~~~~Vi~~m;bi;w~~~~;:;;;:;;;~;– and Chipped Vegetation (if present)
120 0 —– SCALE IN FEET
120
Figure 8
Preliminary Extent of
Non-Combustible Cover -Area 2
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015887
0
N i :;.0::, ;
Q)
3:
/
Vi
::::;;
w
Source: Cooper Aerial Surveys Company (2014)
Legend
Environmental Monitoring Station
Meteorological Station
§ 0 600
.~ ~— I 3- EMSI
Figure 9
Air Quality Monitoring Station
Locations
West Lake Landfill OU-1
Engineering Management Support, Inc.
SCALE IN FEET
~L——————————————-~——————————————–~
WLLFOIA4312- 001 – 0015888
M:\clients\EMSI\westlake\2015\Rubble-lnvestigation \NCC-Org Chart.dwg plotted: 12/23/2015
I
Health Physics, Health & Safety,
Air Monitoring
Michael Bollenbacher, CHP, REA
Auxier & Associates, Inc.
Site Health Physicist
Alex Luna
Auxier & Associates, Inc.
I
Laboratory Analysis
US EPA Region 7
Project Manager
Tom Mahler
Project Coordinator
Paul Rosasco, P.E.
Engineering Management
Support, Inc.
Engineering
Dan Feezor P.E.
Feezor Engineering, Inc.
Field Engineer
Jonathan Wilkinson P.E.
Cover Construction
Contractor
TBD
I
Surveying
Weaver Consultants Group
Figure 10
Project Team
West Lake Landfill Superfund Site
EMS I Engineering Management Support, Inc.
WLLFOIA4312- 001 – 0015889
Attachments
WLLFOIA4312- 001 – 0015890
Attachment 1
Area 2 Sloped Rock Fill – Plan and Profile View
WLLFOIA4312- 001 – 0015891
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20
2+50
BRIDGETON LANDFILL
13570 ST. CHARLES ROCK ROAD
BRIDGETON, MISSOURI 63044
0
1+00
Station
v
BRIDGETON LANDFILL
AREA 2 SLOPED ROCK FILL
AREA 2 SLOPED ROCK FILL
2+00
Thickness Map
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
A
“T
90
80
70
60
50
40
30
20
2+50
Range Minimum Depth Maximum Depth Color
1 0 2 • 2 2 4 • 3 4 6 • 4 6 8 • 5 8 10 • 6 10 12 • 7 12 14 •
FILL VOLUME: 8,639 CY
LEGEND
BASE TOPOGRAPHY (2′ CONTOUR)
–•500 BASE TOPOGRAPHY (10′ CONTOUR)
COMPARISON GRADING (2′ CONTOUR)
–•500 COMPARISON GRADING (10′ CONTOUR)
001
PLAN AND PROFILE VI~EW====~==~~~~5
WLLFOIA4312- 001 -0015892
Attachment 2
Inspection and Maintenance Plan
WLLFOIA4312- 001 – 0015893
Attachmen

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