2016-02-10 – EPA – USACE – West Lake Landfill – Continued discussions on risk evaluations

From: Barker, Justin Required Attendees: TOM MAHLER ([email protected]); 'Kiefer, Robyn V NWK'; Charles... View Document

Post

2015-08-10 – EPA – USACE – West Lake Landfill – Radon Flux – Emanation measurements related to EPA Pyrolysis study of RIM

To: Donakowski, Joseph NWK[[email protected]]
From: Mahler, Tom
Sent: Mon 8/10/2015 9:34:18 PM
Subject: Re: Radon flux/emanation measurements related to potential EPA Pyrolysis study of
RIM from the West Lake Landfill (UNCLASSIFIED)
I’ll set up a conference line tomorrow morning and send you the information. I had to leave the office a
little earlier than I expected today.
Tom
Sent from my iPhone
>On Aug 10,2015, at 4:14PM, Donakowski, Joseph NWK
wrote:
>
> Classification: UNCLASSIFIED
> Caveats: NONE
>
> 10 sounds good to me. Would you like me to call you, or you I, or is there a conference number we can
call in if anyone else wants/needs to participate?
>
> Jough Donakowski
>Health Physicist- USACE Kansas City
> (816) 389-3993
>
>
> —–Original Message—–
> From: Mahler, Tom [mailto:[email protected]]
>Sent: Monday, August 10,2015 3:00PM
>To: Donakowski, Joseph NWK
> Subject: [EXTERNAL] RE: Radon flux/emanation measurements related to potential EPA Pyrolysis
study of RIM from the West Lake Landfill (UNCLASSIFIED)
>
> 10:00am tomorrow work?
>
>
>
> —–Original Message—–
> From: Donakowski, Joseph NWK [mailto:[email protected]]
>Sent: Monday, August 10,2015 12:16 PM
>To: Mahler, Tom
> Subject: RE: Radon flux/emanation measurements related to potential EPA Pyrolysis study of RIM from
the West Lake Landfill (UNCLASSIFIED)
>
> Classification: UNCLASSIFIED
> Caveats: NONE
>
>Yes, I’ll be free tomorrow, I get in around 7:45 so anytime between 8:00 and 4:00 would work for me.
>
> Jough Donakowski
> Health Physicist- USACE Kansas City
> (816) 389-3993
>
>
WLLFOIA4312- 001 – 0058859
> —–Original Message—–
> From: Mahler, Tom [mailto:[email protected]]
>Sent: Monday, August 10,2015 10:43 AM
>To: Donakowski, Joseph NWK
> Subject: [EXTERNAL] RE: Radon flux/emanation measurements related to potential EPA Pyrolysis
study of RIM from the West Lake Landfill (UNCLASSIFIED)
>
>Hey Jough,
>
> Just thought I would check in with you now that you are back in the office. I am free all day tomorrow
and plan to be in the office from about 7:30am central time to about 4:00pm. Any chance you would be
available for a short chat about Radon? I don’t think this would take longer than about 30 minutes.
>
>Let me know if you are available.
>
>Tom Mahler
> On-Scene Coordinator
> EPA Region 7
> 816-604-0546
>
> —–Original Message—–
> From: Donakowski, Joseph NWK [mailto:[email protected]]
>Sent: Tuesday, August 04,2015 4:01PM
>To: Mahler, Tom
> Cc: Vann, Bradley
> Subject: RE: Radon flux/emanation measurements related to potential EPA Pyrolysis study of RIM from
the West Lake Landfill (UNCLASSIFIED)
>
> Classification: UNCLASSIFIED
> Caveats: NONE
>
>Hi Tom,
>
>I’m currently TDY at our Maywood site in New Jersey doing field work and won’t be available until next
week, but I’d be available just about any time that week, so if there’s any time that works good for you I can
be available, just let me know. Thanks!
>
> Jough Donakowski
>Health Physicist- USACE Kansas City
> (816) 389-3993
>
>
> —–Original Message—–
> From: Mahler, Tom [mailto:[email protected]]
> Sent: Tuesday, August 04, 2015 1 :54 PM
>To: Donakowski, Joseph NWK
> Cc: Vann, Bradley
> Subject: [EXTERNAL] Radon flux/emanation measurements related to potential EPA Pyrolysis study of
RIM from the West Lake Landfill
>
> Sorry about the very long subject of this email…
>
>
>
>I was given your email address from Brad Vann, Remedial Project Manager for West Lake Landfill Site,
WLLFOIA4312- 001 – 0058860
because I was hoping to talk to you more about the Radon flux/emanation measurements related to a
pyrolysis study. I was given the impression that you at least initially suggested that the study include radon
and that the result might help improve the associated radon modeling of the site.
>
>
>
> My main goal is to make sure I understand as best as I can the intent or potential intent of such
measurements to help me evaluate whether the proposed sampling and measurement techniques are capable
of providing this information.
>
>
>
> I am an On-Scene Coordinator here at EPA Region 7 with a degree in Nuclear Engineering and aspiring
to become a certified health physicist (I took the first exam last month and still have a ways to go … ). I have
been asked me to help out with the pyrolysis study.
>
>
>
> Are you available to talk about radon flux/emanation at some point this week?
>
>
>
> I am available pretty much any time. Let me know what is convenient for you and thanks in advance.
>
>
>
>Tom Mahler
>
> On-Scene Coordinator
>
>US EPA Region 7
>
> 816-604-0546
>
>
> Classification: UNCLASSIFIED
> Caveats: NONE
>
>
>
> Classification: UNCLASSIFIED
> Caveats: NONE
>
>
>
> Classification: UNCLASSIFIED
> Caveats: NONE
>
>
WLLFOIA4312- 001 – 0058861

Post

2016-02-09 – EPA – West Lake Landfill – Notes on February 9, 2016 CAG meeting

To: Peterson, Mary[[email protected]]; Hague, Mark[[email protected]]; Carey,
Curtis[Carey. [email protected]]; Stoy, Alyse[[email protected]]
Cc: Washburn, Ben[[email protected]]; Mahler, Tom[[email protected]]; Vann,
Bradley[[email protected]]
From: Juett, Lynn
Sent: Tue 2/9/2016 5:57:32 AM
Subject: CAG
WLLFOIA4312 – 001 – 0014038
WLLFOIA4312 – 001 – 0014039
WLLFOIA4312 – 001 – 0014040

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

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

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

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2016-02-19 – EPA – West Lake – Communication between AAA Trailer Services and EPA

To:
From:
Sent:
Subject:
John O’[email protected]]
Mahler, Tom
Fri 2/19/2016 8:26:24 PM
Re: My Contact Information
I’m working on, John. Unfortunately the access agreement paperwork is not coming from EPA. It
is coming from all the PRPs for the Westlake landfill site. I forwarded your email to Paul
Rosasco and he is working things on his end as fast as possible.
If things can’t come together today, when do you think would be soonest the owners would be
available to sign?
I know we would like to do the investigation a week from tomorrow (one week from this
Saturday).
However, delaying for a week or two would not be a big deal.
Tom Mahler
On-scene coordinator
EPA region 7
816-604-0546
Sent from my iPhone
On Feb 19, 2016, at 2:12 PM, John O’Brien
From: Mahler, Tom L’-‘-“=~=”-‘=.:=’-====.!CJ
Sent: Thursday, February 18, 2016 2:36 PM
To: John O’Brien
Subject: My Contact Information
Hey John,
wrote:
I just wanted to provide my contact information should you or anyone at AAA want to talk
to EPA. Feel free to call or email whenever.
WLLFOIA4312 – 001 – 0015851
Tom Mahler
On-Scene Coordinator
US EPA Region 7
816-604-0546
WLLFOIA4312 – 001 – 0015852

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

From: Mahler, Tom
To: [email protected]
Cc: Vann, Bradley; Barker, Justin; Gieseke, Andrew; Juett, Lynn; Stoy, Alyse
Subject: Further sediment sampling and storm water flow information
Date: Monday, May 23, 2016 1:55:00 PM
Attachments: QAPP for West Lake Landfill – Sediment Sampling_Revision 02.pdf
160-15647_DVR_Rad_6Jan16_RM.pdf
160-16583_DVR_Rad_13Mar16_RM.pdf
Paul,
As you are aware, three sediment samples were collected on January 6th, 2016 as part of
the Additional Characterization work for Area 1 and Area 2. For each of these three
samples, EPA collected splits. After reviewing the validated data from you and your clients
in addition to the EPA split samples data (see attached), EPA has determined that SED4
and EPA’s split for this sample (SED 4-EPA DUP) contain radionuclides which meet the
definition of RIM for OU-1 of the West Lake Landfill site. Specifically the Combined
Thorium concentrations for SED4 and SED 4-EPA DUP are 16.16 pCi/g and 20.63 pCi/g
respectively which exceeds the established limit of 7.9 pCi/g.
Additionally, EPA provided a QAPP for the collection of additional sediment samples which
has since been updated. I have attached an updated version of this QAPP which includes
an updated figure that depicts the previously collected sediment samples as well as new
proposed sample locations. Specifically the QAPP requires the collection of additional
sediment samples located between SED4 and the north corner of the West Lake Landfill
property along the drainage pathway for storm water situated between the OU-1, Area 2
fence line and St. Charles Rock Road.
EPA Region 7 requires further characterization of this portion of the landfill property as
soon as access is attainable and recent storm water recedes. We are requesting that the
PRPs perform a gamma walkover survey to determine if there are any elevated areas of
gamma radiation for which biased sediment samples could be collected. In addition, EPA
Region 7 will require 5 additional sediment samples be collected approximately every 100
feet between SED 4 and the north corner of the landfill property (see attached updated
figure from the QAAP). One of these sample locations will require the collection of a
duplicate sample for data quality purposes. Finally, because of the recent storm events
which have inundated this area with storm water, the collection of an additional sample
from the SED4 location will also be required. EPA will collect these samples or will collect
100% split samples. This work is to be performed during the week of May 23, 2016. If a
gamma survey cannot be performed the week of May 23, 2016, because of residual storm
water or excessive vegetation, it may be delayed until conditions change. Please move
forward with collection of the sediment samples regardless.
Finally, EPA is also requiring the PRPs to provide definitive information on the locations of
storm water drainage that runs along the east side of the West Lake complex located
between the norther portion of the Bridgeton landfill, OU-1 Area 1, and St. Charles Rock
Road. Please ensure to include information associated with the four drop boxes and/or
inlets located immediately North and South of the landfill entrance road, as well as whether
there is a connection between the stormwater collection pond(s) in the northeast portion of
the West Lake complex, and immediately north of the complex and the sediment pond to
the north of the complex and east of St Charles Rock Road. Please provide this
information by Wednesday, May 25, 2016
Please let me know if you have any questions about these proposed sampling plan. Also,
please coordinate with me on the timing for collection of the sediment samples.
Tom Mahler
On-Scene Coordinator
US EPA Region 7
913-551-7416

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