Post

1984-04-06 – NRC – ORAU report on berm erosion surey at the West Lake Landfill

Oak Ridge
Associated Post Office Box 117
Universities Oak Ridge, Tennessee 37830
Telephone (615) 576-3305
Manpower Education.
Research, and Training
Division
April 6, 1984
Mr. William Crow /
Div. of Fuel Cycle & Mat. Safety
MS-SS396, Nuclear Regulatory Commission
Washington, DC 20555
Dear Mr. Crow:
Enclosed is a copy of the report on the survey of the
berm at the West Lake Landfill in St. Louis County, Missouri.
Please let me know if you have any questions concerning
this information.
Sincerely,
James D. Berger
Program Manager
Radiological Site Assessment Program
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Enclosure
cc: Wyngarden, NRC {3-,.:..,.)
O’Connor, Univ. of MO
McCullough, West Lake Landfill
40249270
SUPERFUNI) RF.COKDS
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SURVEY FOR BERK EROSION
WEST LAKE LANDFILL
ST. LOUIS COUNTY, MISSOURI
A.J. Boerner
*. INTRODUCTION
On March 12-13, 1984, representatives from Oak Ridge Associated
Universities (ORAU), Oak Ridge, Tennessee, performed a radiological survey
along a section of the benn bounding the West Lake Landfill. The objective
of the survey was to determine if erosion of the benn was occurring,
resulting in the spread of contamination to adjacent property. Information
collected included exposure rates, concentrations of radionuclides in
surface soil, and locations of elevated contact radiation levels relative
to the surface topography.
PROCEDURES
1. A scan of the north face of the benn was performed with Nal(Tl)
scintillation detectors to determine general areas of elevated
radiation levels. The area selected for further investigation is
shown in Figure 1. The walkover scan also identified an elevated
region along a short unpaved access road situated just west of the
Shuman Building and leading to the perimeter road; however, no further
measurements or sampling were undertaken at this location.
2. A 5 m grid system was established on the benn in an area identified by
the scan.
3. A sketch of the topography in each grid block was prepared.
Work performed by the Manpower Education, Research, and Training Division
of Oak Ridge Associated Universities, Oak Ridge, TN, under interagency
agreement DOE No. 40-770-80, NRC Fin. No. A-9093-0, between the Nuclear
Regulatory Commission and the Department of Energy.
April 6, 1984
4. Surface scans were conducted over the grid using portable Nal(Tl)
scintillation detectors. Locations of elevated contact radiation
levels were noted.
5. Exposure rate measurements were made at the surface and at 1 m above
the surface at each grid line intersection and at selected locations
•• of elevated readings. A Nal(Tl) scintillation meter calibrated with a
pressurized ionization chamber was used.
6. Surface (0-15 cm) soil samples were collected at twelve grid line
intersections and at five locations of elevated surface contact
radiation levels identified by the scan (refer to Figure 2). Two
additional samples were collected from the adjacent field.
7. Exposure rates were also measured at several locations near the
Landfill office building and a soil sample collected from an area of
elevated contact readings.
8. Soil samples were analyzed by gamma spectrometry. Radium-226 and
Th-230 were the major radionuclides of concern, although spectra were
reviewed for Pa-231 and Ac-227. One soil sample from the berm area
and the sample from near the office building were analyzed by neutron
activation to determine trace element composition.
RESULTS AND DISCUSSION
Topography
Figure 2 is a sketch of the berm area surveyed, indicating the grid
system and the major surface features. The slope of the berm is estimated
to be approximately 40°. The soil on the face of the berm appears quite
loose and only sparsely vegetated. There are several small ditches which
follow the slope; these suggest erosion or slippage of the surface soil
layer. Several small mounds of earth were also noted at the base of the
berm.
Direct Radiation Levels
The walkover scan identified levels ranging up to 600 uR/h near the
top of the berm. Levels were generally highest in a region near grid
coordinates C2 and C3 and in a ditch down-slope from these coordinates.
Contact exposure rates at C2 and C3 were 360 yR/h and 570 pR/h,
respectively. Elevated measurements (up to 280 pR/h) were also noted on
contact with a mound of soil between grid coordinates D4 and D5 at the base
of the berm. Specific “hot spots” were not present along the perimeter
road or the adjacent field; however, ambient radiation levels were
generally elevated – possibly the result of residues in the landfill berm.
Figure 3 indicates the contact exposure rates measured on the berm.
An area near the landfill office had been identified by a previous
survey as containing contaminated residues and having an elevated direct
radiation level.* Random measurements in that area (see Figure 4) indicate
exposure rates at 1 m above the surface ranging up to 45 yR/h. The maximum
level is near a small drainage ditch. The extent of the area exceeding
20 pR/h is smaller than that shown in the Radiation Management Corporation
report. This is probably the result of additional fill (1-1.5 m) which has
been placed on portions of this area, since the previous survey.
Radionuclide Concentrations in Soil
Radionuclide concentrations in surface soil samples are presented in
Table 1. With one exception, i.e. the sample from coordinate A5, these
samples all contained elevated levels of Ra-226 and/or Th-230. Ratios of
Th-230 to Ra-226 were in the range of approximately 25:1 to 40:1. Pa-231
and Ac-227 were also present in most of these samples. The maximum
concentrations of Ra-226 were 699 pCi/g and 662 pCi/g. These were in
samples S4 and S5 from areas having the highest direct radiation levels.
* L.F. Booth, et al., Radiological Survey of the West Lake Landfill.
St. Louis County. Missouri. Radiological Management Corporation,
May 1982.
Highest Th-230 concentrations were also noted in these two samples. A
sample (S7) from the mound of soil at the base of the berm contained
185 pCi/g of Ra-226 and 6720 pCi/g of Th-230.
Samples from grid line 5 along the base of the berm and from grid
line 6 along the perimeter road also had elevated radionuclide
concentrations; however they were lower than the concentrations in samples
from areas of elevated direct radiation. Samples B5, C5, and D5 were the
highest; these locations are downslope from the areas of highest residues
and in the vicinity of ditches and mounds of eroded soil. The two samples
(SI and S2) collected in the adjacent field, about 10 meters north of grid
coordinates B6 and D6, also contain elevated Ra-226 and Th-230
concentrations.
Sample S8 from the ditch near the office area contained 5.19 pCi/g of
Ra-226 and 344 pCi/g of Th-230. Neutron activation results for this sample
and the sample from coordinate E,6 indicate similar trace element contents.
Based on the Ra-226 to Th-230 ratios and other elemental contents it
appears that the residues are from the same source.
SUMMARY
A survey of a small area at the West Lake Landfill in St. Louis
County, Missouri, was conducted by ORAU to determine if erosion of the
landfill berm is resulting in spread of radioactive residues buried on this
site. Measurements of direct radiation levels and radionuclide
concentrations in soil and the physical condition of the berm area indicate
that erosion is occurring and that there are elevated concentrations of
Ra-226 and Th-230 at the base of the berm and extending into the adjacent
field.
Measurements performed at another area of known radioactive residue
burials, near the office building, indicate that there has been 1-1.5 m of
additional fill added to portions of this area during the past 3-4 years.
This added fill hs reduced the direct surface radiation levels at some
locations by approximately a factor of 2. Analyses suggest that the
residues from the berm and office areas are from the same source.
TABLE 1
RADIONUCLIDE CONCENTRATIONS IN SURFACE SOIL
Radionuclide Concentrations (pCi/g)
Location3
A5
B5
C5
D5
E5
F5
A6
B6
C6
D6
E6
F6
SI
S2
S3
S4
S5
S6
S7
S8 (near office
building)
Ra-226
1.05 +
11.3 +
6.77 +
23.2 +
1.35 +
1.32 +
2.36 +
3.98 +
3.93 +
2.84 +
5.15 +
0.98 ±
4.27 ±
4.49 +
38.3 +
662 +
699 +
72.3 +
185 ±
5.19 ±
0.30b
0.7
0.53
1.1
0.19
0.20
0.37
0.51
0.51
0.51
0.51
0.17
0.44
0.61
1.6
7
6
2.3
3
0.59
404
241
1006
13.
8.
99.
132
142
109
181
11.
132
178
1601
16170
19130
3280
6720
344
Th-230
<7.67 + 45 + 21 + 140 0 + 5.7 49 + 5.3 3 + 35.5 + 75 + 70 + 70 + 57 1 + 5.1 + 17 + 82 + 240 + 810 + 220 + 290 ± 480 ± 84 Pa-231 <0.59 <1.16 <0.89 7.54 + 3.07 <0.68 8 <0.57 <0.86 <0.81 <1.03 <0.98 <0.77 <0.71 <0.76 <1.22 7.16 + 3.47 140 ± 13 <10.1 18.3 + 5.1 34.9 ± 7.3 <1.70 Ac-227 <0.50 3.79 + 1.00 1.03 + 0.75 11.0 + 1.6 0.50 + 0.49 0.15 + 0.33 <0.46 2.82 ± 0.84 2.35 + 0.88 2.65 + 0.56 1.37 + 0.48 <0.59 <0.57 <0.23 5.78 + 2.23 207 +11 29.1 + 8.3 11.1 + 4.4 49.8 ± 5.0 2.44 j+ 0.86 a Refer to Figure 2. b Errors are 2a based on counting statistics. o o o o o o o o o o o o o q o o o • < a u O w u . O X - - > – –
FIGURE 1. Portion of North Edge of Landfill Indicating Survey Area.
B
F I E L D
N W
METERS
FIGURE 2. Map of Berm Area Indicating Berm Features, the Grid
System, and Soil Sampling Locations.
B
FIELD
N W
METERS
FIGURE 3. Areas of Elevated Contact Radiation Levels.
N
FIGURE A. Area Near Office Building Showing Region Exceeding 20 yR/h at
1 m Above the Surface and Soil Sampling Location.

Post

1980-11-17 – MDNR – West Lake Landfill – Reason for contamination in northermost area of West Lake Landfill unknown at this time

Page 1
UPDATE ON WESTLAKE LANDFILL NOV J 7
HISTORY OF WESTLAKE LANDFILL
Westlake Landfill, located in Bridgeton Missouri (St. Louis County) has been the
subject of recent inquiry. This landfill began operation prior to state regulation.
As far as our records show, this landfill first opened in the med-1960’s. Part
of the landfill lies in an old quarry and part of the landfill lies in the Missouri
River floodplain, approximately 1 1/2 miles from the river. Witnesses to this
operation, when the area of the landfill which lies in the floodplain was in
operation, note that the fill area was often actually beneath the level of the
water table. Leachate from the old quarry area of the landfill is collected and
hauled to MSD treatment plants. Construction of onsite treatment is underway.
About 48,000 gallons of leachate per day is currently being collected.
CHEMICAL WASTES
Aside from normal landfill materials, there are chemical industrial wastes and
radiologically contaminated materials deposited in this landfill. The chemical
wastes, that we know of, include about 4,000 tons of residues from the production
of insecticides and herbicides. These pesticide wastes were deposited .by Chevron
Chemical Company. Also included in the chemical wastes are waste materials from
ink manufacture and from the manufacture of glue. Among the chemical wastes that
we know of in Westlake Landfill are:
waste ink pigments oily sludges
esters alcohols insecticides
halogenated intermediates -wastewater sludges aromatics
oils -asbestos herbicides
heavy metals
RADIOACTIVE WASTES
In addition to the hazardous chemical wastes in Westlake Landfill, there are
radioactive wastes. During early 1973 Cotter Corporation buried radioactive Barium
Sulfate Slag material and rad.iologically contaminated building rubble. There are
approximately 43,000 tons of this material which contain about 7,000 tons of natural
Uranium. •
Page 2
In October, 1977, an aerial radiological ‘survey was done to determine the location
of the burial of this contaminated material (see attached map). ‘It was determined
from the aerial survey that there are two areas within the landfill which are
emitting abnormally high levels of radiation. The southermost area is the
result of the burial of contaminated Barium Sulfate Slag from the Mallinkrodt area
of the Destrehen street Uranium processing plant. (This facility in downtown St.
Louis is where material for the original nuclear weapons tests was produced.)
The northermost area contamination is on the edge of the floodplain area which is
the boundary of neighboring farmland. The reason for its elevated gamma radiation
is unknown at this time. The U. S. Nuclear Regulatory Commission has contracted
Radiation Management Corporation to do extensive on-site radiological surveys
which include groundwater analysis, core sampling, test boring, and other tests
as deemed necessary. This study should determine the reason for the elevated gamma
radiation (see attached NRC announcement).
CURRENT DNR MONITORING ACTIVITY
Geological reports from DNR’s Division of Geology and Land Survey indicated that
the local groundwater flows Northeast from the landfill into the Missouri River
alluvial floodplain. Therefore, it is highly probably that leachate from the
landfill is contaminating local wells and entering the waters of the Missouri River.
As a result, DNR has initiated sampling and monitoring activities. On September
20 and October 1, 1980, a groundwater investigation was conducted in the vicinity
of the Westlake Landfill. Two monitoring wells on the landfill site and three
*>
provate wells located Northwest of the landfill were sampled (see attached report).
The Division of Geology and Land Survey groundwater experts have evaluated data
from this sampling and determined that levels of several pollutants were significantly
higher than what ‘one would expect as background levels. Chloride, Sodium,
Lead, and Manganese showed particularly high levels. Except for Manganese, the
levels were not in violation of drinking water standards, but were high enough for
Page 3
concern.* Because of this concern, additional sampling is being conducted in
the last week of October.
Since the NRC will be conducting investigations on radioactive contamination,
DNR has requested permission to use some of their facilities to aid in our hazardous
chemical waste investigation.
The NRC has given DNR verbal permission to utilize the monitoring wells which
Radiation Management Corporation will be digging, in order that DNR may test for
the presence of chemical hazardous wastes. On October 1, 1980 DNR sent a written
request to the NRC asking for written confirmation of this permission. No reply
has been received yet.
All data collected so far has been given to the St. Louis County Health Department
for review and possible action regarding drinking water supplies.
* Manganese levels violate a secondary drinking water standard which is not a
health related standard.
10/27/80
-S.
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Post

1980-10-02 – MDNR – West Lake Landfill – Memorandum – History of Operations

MEMORANDUM
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Date: October 2, 1980
Jo: Bob Schreiber
From: Burt McCullough
Subject: Westlake Landfill
Westlake Landfill, located in Bridgeton Missouri (St. Louis County) has been
the subject of recent inquiry. This landfill began operation prior to state
regulation. As far as our records show, this landfill first opened in the
mid-1960’s. Part of the landfill lies in an old quarry and part of the landfill
lies in the Missouri River floodplain, approximately 1^ miles from the
river. Witnesses to this operation, when the area of the landfill which lies
in the floodplain was in operation, note that the fill area was often actually
beneath the level of the water table. According to file materials from
Missouri Geological Survey, it is “highly probable that leachate from the
landfill is entering the waters of the Missouri River. . . ” Leachate from
the old quarry area of the landfill is collected and hauled to MSB treatment
plants. Construction of onsite treatment facilities is underway. About 48,000
gallons of leachate per day is currently being collected.
Aside from normal landfill materials, there are chemical industrial wastes and
radiologically contaminated materials deposited in this landfill. The chemical
wastes, that we know of, include about 4,000 tons of residues from the production
of insecticides and herbicides. These pesticide wastes were deposited by
Chevron Chemical Company. Also included in the chemical wastes are waste
materials from ink manufacture and from the manufacture of glue. Among the
chemical wastes that we know of in Westlake Landfill are:
waste ink pigments
esters alcohols
halogenated intermediates
oils wastewater sludges
heavy metals asbestos
oily sludges
insecticides
aromatics
herbidices
Joseph
Fred A
Besides chemical hazardous wastes, in Westlake Landfill, there are radioactive
wastes. During early 1973 Cotter Corporation buried radioactive Barium
Sulfate Slag material and radiologically contaminated building rubble. There
are approximately 9,000 tons of this material which contain about 7,000″tons
of natural Uranium. In October, 1977, an aerial radiological survey was done to
determine the location of the burial of this contaminated material. The report
from this survey indicates that there are two burial sites. One is in the
center of the old quarry area, and the other is on the edge of the floodplain
area which borders adjacent farmland. The U.S Nuclear Regulatory Commission
has contracted Radiation Management Corporation to do extensive on-site
radiological surveys which include groundwater analysis, core sampling, test
boring, and other tests as deemed necessary. The NRC has given DNR verbal
P. Teasdale Governor Division of Environmental Quality
Lafser Director Robert J. Schreiber Jr., P.E. Director
Westlake Landfill continued
Page 2
October 2, 1980
To: Bob Schreiber
permission to utilize the monitoring wells which Radiation Management
Corporation will be digging, in order that DNR may test for the presence of
chemical hazardous wastes.
There is little known about what went into Westlake Landfill prior to State
regulation. Analysis needs to be done to determine: 1) what wastes are
deposited in Westlake Landfill, 2) if any of these pollutants are leaving
the landfill via groundwater, and 3) what threat does Westlake Landfill pose
to drinking water supplies.
cc: Fred Lafser
Ron Kucera
Jim Long
Robert Robinson
Bob Miller
Tom Doan

Post

1980-09-25 – MDNR – West Lake Landfill – Source of Contamination in Area 2 is unknown at this time

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MEMORANDUM
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SEP 2 5 1980
SOLID
Date: September 25, 1980
To: Robert J. Schreiber. through Richard F. Rankin
From: Burt McCuiiough
Subject: Westlake Landfill
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On Wednesday, September 4, 1980 I joined officials from the Nuclear
Regulatory Commission in an on-site inspection of Westlake Landfill.
The purpose of this trip was to give representatives from Radiation
Management Corporation, who has been awarded a bid to do extensive
surveys of the area, the opportunity to become familiar with the site.
It was determined from an aerial survey that there are two areas
within the landfill which are emitting abnormally high levels of
radiation; The Southernmost area is the result of the burial of
contaminated Barium Sulfate Slags from the Mallinkrodt area of
Destrelen Street Uranium processing plant. The Northernmost area of
contamination borders onto neighboring farmland. The reason for
its elevated gamma radiation is-unknown at this time. The report
which will be done by Radiation Management Corporation should answer
this question.
Westlake Landfill is a large facility. About 48,000 pounds of leachate
per day are shipped by tank truck to St. Louis Metropolitan Sewer
District to be treated.
Geological reports indicate that groundwater flows Northeast from the
landfill into the Missouri River alluvium.
Information which has been printed in newspapers on the radiological
aspects of Westlake Landfill has not necessarily been accurate.
CC: Fred Lafser
Ron Kucera
David Bedan
r’Kbbbie Robinson
40056883
SUPERFUND RECORDS
Joseph P. Teosdale Governor
Fred A. Lafser Director
Division of Environmental Quality
Robert J. Schreiber Jr., P.E. Director
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Post

1980-01-15 – MDNR – Concerns related to West Lake Landfill

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Mr. W. T. Crow
Office of Nuclear Materials
Safety and Safeguards
Nuclear Regulatory Commission
Washingtoii, D.C. 20555
Dear Mr. Crow:
This letter will confirm our telephone conversation of January 7,
1980 concerning the Westlake Landfill. I’m attaching to this
a copy of my Decrmber 31 letter to Mr. Earl Harvison, Oakridge,
Tennessee.
I would appreciate your early response to the questions raised
in that letter. I’m also attaclng a copy of the resolution
submitted by the Lity of Bridgeton to us in this matter. If we
can be of assistance to you, please let me know.
Very truly’ yours,
,eJames P. Odendahl
Director
Division of Environmental Quality
JPO;,,
cc: Senator Edwin Dirck
Keii Mille-. Dept. of Health
Solid Waste ,nagement Program
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PDR FOJA
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Joseph P. Teasdale Governor
Fred A. Lafser Director
Division of Environmental Quality
James P. Odendahl Director
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December 31, 1979
Mr. Earl Harbison
Departmcnt of Energy
Oak Ridge, Tennessee 37830
Dear Mr. Harbison:
Please find attached my letter of response to the City of Bridcet.cn
regarding their resolution relative to the disposal of radic..:tiýe
waste materials in the vicinity of the city. Mr. Rick koberts, with
the Department of Natural Resources, Solid Waste Mariagement Program,
is been in telephone comniunication with you during recent months
requesting that your office provide us with the res,:lt, of the
technical study which was conducted to determine the l.)cation ana
levels of radiation emitting from the wa;te disposed of at the
Westlake Land’ill in St. Louis County. This aerial survey of th’e
Westlake Landfill and other areas in the St. Louis Couity was cocducted
at least a year ago. The Department of Natural R_:scurces
would appreciate this information being made available in order that
we can assess the potential public health effects.
If there are reasons why the study cannot be released to the
Department of Natural Resources, I would appreciate teinc, so advisec.
Sincerely,
James P. Odendahl
Director
Division of Environmental Quality
JPO/RMR/jc
Encl.
Joszph P. Teasdale Governor
Fred A. Latser Director
Division-of Environmental QualIty
James P. Odendahl Director
December 28, 1979
IL llonorable E. I’J. (Bill) Abram
Mayor
tv ) City of Bridgeton
11955 Natural Bridge Road
0 Iq Bridgeton, Missouri 63044
cV) “-” Dear Mayor kram:
— C%4
0 Senator Edwrn L. Dirck ha, forwarded the City of Bridgzton’s Resolution
0_ R-79-12 relative to dispo:.al of radioactive material to the Department
of Natural Resources for response relative to Missouri’s role in control rr
the disposal of radioactive waste materials.
0
D • You are probably aware that the Federal Nuclear Regulatory Commission ha.,
< the primary responsibility for controlling the disposal of radioactive < • waste materials. The State of Missouri is not an agreehient state and U his no arrdnrements with ithe Nuclear Regulatory Cormission to enforce th, C re2gulatioe• within the Stdte of Missouri. At the pres2nt time the Solid 0 ý2iste Regulations of the Department of Ndtural Resources prohibit the 2 acceptance of radioactive v..a=-te materials at permitted sanitary landfill,. The:'eforL, the Westlake L.inc-fill in St. Louis County does nut have autno z ization to arcept radioactve waste materials. The Department of Nature _2,ources is interested in %..hat radioactive waste materials maý have be(: di, pcsed of -.t the Westla'e Landfill in the past and has been in corurinni - cat-on with the Departtmen. of Lnergy in Oakridge, Te!nnessee requestinc 3)- tiat they privide us with wiiat informaL ion they liiv c..btained relitt'e Q 2 tie dispoual of the waste at the 4estl (4e Landfi 11. 'r. Earl Harh iscn <• > .with the Leý…tinent of Eneýrgy has assured us he will provide us with a c
‘0 ,of the inves.iaation repo-t ,.s soon as it is availaiii(.
0 It has been indicated triat ,,’ry lo.i lev, 1 radioactive ,.*,,te materiai w-.
involved in :he disposal it the Westlakc Landfill, an( there should he ‘;
rV danijer to th.. citizens of i;ridjetor., lh. ,;ver, th; :)e( artment of Na’.uro 1
-o e’,uurces wa:its to revieq -i .uccnni’aý djt, fro,- tCie ili’partment of z:iV 6C) in/vstigatici, and stuJy b2 “e makinj .1i v recorw-nd~tt ins as to wha..
;nruld be talen.
U~) CC
Joseph P. Teasdale Governor .Divisiion o? Enviror’m .’al (ucij’y
Fred A. Lafser Director James P. Odenclani Dirzcior
• j I~Q’ I
NJISSOUJUl SEX’A’rE
j K; FIVF I.JIYO.* GI Ty
.EzDWv r L. D jRcI.&
SINATOR, 24TH DIscrIC
CAPITOL IUILDINO
.ILFFEP60N CITY. MISSOURI 69101
TELEPHOMNE 1314) 721.2540
November 8. 1979 1074t. ~l.
TEL.IPM~N’. ill
Mr. James Odendahl, Director
Division of Environmental Quality
P. 0. Box 1368
2010 Missour- Boulevard
Jefferson City, Missouii 65101
Dear Mr. Odendahl:
Attached please find a copy of a letter and rcz3c
lution that I received from Mayor bill Abram of
the City of Bridgeton, St. Louis County. Although
I realize the Nuclear Regulatory ‘Commission has
responsibility for disposal of radioactive waste
materials, I would appreciate your responding to
Mayor Abram and advising with regard to Missouri’s
role, if any, in this area.
Thanks for your help.
Sincerely,
Ewi
Edwin L. [Dirck
ELD:1s
Enclosures (2)
IF A 4 OF
CITI Y OF 1R1I[)G F-TON
Octobor 33, 1979
E.W. (1:111) AIJRAM. Mayor
M.AR T, Ili(. COF-CRAN. Admrimisttstivo Asis~sant
MARY E:.O E LLfRIMANN. City I
honorable E&.Ain L. Dirck
Stite Capitol ‘ld,).
Jefferson Ci:y, Mo. 65101
I A
(Oear Senato Di rck:
T~he City Co. rcil at its r…t’g of h’tcji)er- 24. H-79, ýass2d tf’e
crlclcsed Reclutien P-79-12, which I (iree with aid ,s of great
cencern to the residents of thre City of 3ridgeton.
fAry help )’:u can give in 1lis matter Wi II be gret ly appreciat,:.d.
Sincerely,
E. B4i( B1lAblra)m ., Mayo
EWA tp
E~ncl osure

Post

2013-11-25 Letter Feezor to EPA WLL Phase 1 Status Report

November 25, 2013
Ms. Cecilia Tapia Director Superfund Division
United States Environmental Protection Agency
Region 7 11201 Renner Boulevard Lenexa, Kansas 66219
RE: Bridgeton Landfill-West Lake Landfill: Phase 1 Status Report
Dear Ms. Tapia:
On behalf of our client, Bridgeton Landfill, LLC (h ereinafter Bridgeton Landfill), Feezor Engineering, Inc. (FEI) hereby submits an update to the Phase 1 Gamma Cone Penetrometer Test (GCPT) field investigation. This update was requested by EPA as a preliminary update and this is not a report anticip ated by the Phase 1 Work Plan. The update contained within this correspondence and att ached drawing is through Friday, November 22, 2013. Please note that because the Ph ase I work has not yet been completed and necessary calibration and correlation completed, this update and information is collected from field data and should be considered draft preliminary in nature.
The Phase 1 Work Plan is consistent with Environmen tal Protection Agency’s (EPA) September 20, 2013, letter directing the investigat ion under the Additional Work provision of the Administrative Order on Consent for the West Lake OU-1 Superfund Site.
The project was initiated by conducting General Empoyee Radiological Training (GERT) on October 28, 2013. Auxier and Associates, Inc. who is providing the radiological safety and monitoring services for the project provided th e GERT and answered any worker safety and monitoring questions. On October 29, 2013, vegetation clearing was initiated by Agricycle, Inc. Prior to any vegetation clearing AAI provided an onsite health physicist who will conducted an overland gamma scan. The hea lth physicist held the detector approximately 30 em above the ground surface and adtanced across the areas of interest in a series of straight lines at a rate of approxim ately one meter per second. The separation distance between the lines were approxim ately 1.5 meters. In all areas of vegetation clearing, no elevated overland gamma readings were detected.
406 East Walnut Street • Chatham, IL 62629 Phone (217) 483-3118 • Fax (217) 483-2356
WLLFOIA4312-001 -0022578
-2-November 25, 2013
Vegetation clearing proceeded from October 29, 2013 to November 18, 2013 by using a tree shear or a skid steer with a brush hog attachm ent. Care was taken to select paths which required a minimum amount of clearing. The tree shear was used for the majority of the clearing, while the brush hog was used in areas deemed too thick such as a thicket type vegetation. To prevent any visible dust emiss ions a water truck was available to water the vegetation. However, rain events and nat ural moisture provided sufficient wetting, and it was decided that additional waterirg was not needed for dust suppression and could create conditions more conducive to rutting.
Once the path was cleared, Agricyle deployed a 10 o unce per square yard non-woven geotextile, and then approximately 6-8 inches of ro ck aggregate was spread to advance gravel roads to each test location along the cleara:l alignments. The gravel path locations were surveyed and the locations are depicted on the attached drawing entitled GCPT
Status.
As of the end of the work day on November 22, 2013 the following paths have been constructed, which should suffice for the Phase 1 investigation.

Entrance Alignment


Main Alignment to west fence


Main Alignment to east fence


Path 1-GCPT 4-1 to GCPT 4-2


Path 2 -GCPT 5-1 to GCPT 5-4


Path 3 -GCPT 6-3 to PVC-36


Path 4-GCPT 7-2


Path 5-GCPT 9-2, WL-108, GCPT 9-1, and GCPT 7-1


Path 6-GCPT 10-2 to GCPT 10-1 to PVC-25


Path 7-GCPT 12 -2 to GCPT 12-1 to PVC-38 to PVC-28 to GCPT 11-2


Path 8-GCPT 13-1 to GCPT 13-7 (also including GCPT 13-1 to GCPT 16-1)


Path 9-GCPT 14-1 to GCPT 14-7


Path 10-GCPT 15-1 to GCPT 15-8


Path 11-GCPT 16-4 to GCPT 16-8


Path 12-Entrance Alignment west to GCPT 6-4


Path 12B -GCPT 12-6

Approximately 4,200 feet of paths have been constru cted to date. Approximately 3265 tons of rock, and approximately 400 yards of soil have been delivered to date.
ConeTec arrived on site on November 12, 2013 and, cfter obtaining the proper health and safety training, proceeded to conduct a GCPT soundi ng at the existing boring WL-111. After the AAI Health Physicist approved that the GCPT rods and the GCPT machine tracks were devoid of any radiological contamination, the GCPT rig was moved to PVC-28 and a sounding was conducted there. ConeTec was able to detect elevated gamma counts
11-25-13 GCPT Status Report.docx
WLLFOIA4312-001 -0022579
-3-November 25, 2013
within this boring. No PVC casing from the NRC stu dy was found, since under the approved materials management plan over 8 feet of c onstruction and demolition debris was placed in this area since the NRC borings were initially conducted. (As discussed below, this construction and demolition debris has proved to be an impediment with the advancement of the gamma cones along the eastern ha If of the OU-1, Area 11andfill.) After the sounding at PVC-28, the AAI health physic ist released the GCPT rig to proceed to the next location.
The next sounding occurred within the existing casing for PVC-25 an existing NRC boring. The September 27, 2013 Gamma Cone Penetration Test {GCPT) Work Plan Revis ion 2 (hereinafter referred to as the Work Plan) listed FVC-38 as a correlation boring. However, after clearing up to this boring, it was determined that the topography would deem this location unsafe for the GCPT rig. Upon consultatio n with Region 7 of the USEPA, it was determined to use PVC-25, another known impacted NR C boring. This location was beyond the construction and demolition debris fill,and the existing PVC casing was found. ConeTec was able to lower their GCPT rods into this casing and again, was able to detect elevated gamma readings. After AAI scanning and rE!ease, the GCPT rig proceeded to PVC -36, another NRC PVC casing that was discovered. T he GCPT rig was able to detect a slightly elevated gamma reading from this PVC casin g. Having completed testing of the three known radiologically impacted borings with the GCPT rig, it was decided in the field that the GCPT technology was recording relevant gam ma data. Even though statistical correlation studies and analytical sampling will be necessary in the future to provide proper correlations, the device would be used to co llect raw data at the proposed sounding locations.
Soundings occurred within the OU-1 Area 1 fenced ar ea from a general west to east progression. A summary of the raw data from the so undings is included in the attached drawing entitled GCPT Status. As of the end of the work day on November 22, 20 13 the following GCPT locations have been completed, or at least attempted with upper level rock refusal.

GCPT 4-1, 4-2


GCPT S-1, S-2, S-3, 5-4


GCPT 6-1 (also PVC-36), 6-2, 6-3, 6-4, 6-5


GCPT 7-1, 7-2, 7-3


GCPT 8-1


GCPT 9-1, 9-2, 9-3


GCPT 10-1, 10-2, 10-3, 10-4


GCPT 11-1, 11-2, 11-3, 11-4


GCPT 12-1, 12-2, 12-3, 12-4, 12-5, 12-6


GCPT 13-1, 13-2, 13-3, 13-4, 13-5, 13-6, 13-7


GCPT 14-1, 14-2, 14-3, 14-4, 14-5, 14-6, 14-7

11-25-13 GCPT Status Report.docx
WLLFOIA4312-001 -0022580

Post
Post

1995-03-09 – NRC – EPA – West Lake Landfill – Policy Issue – Deferral of Regulatory oversight to EPA

RECEIVED
2 2 1995
‘***
March 9, 1995
FOR:
FROM:
SUBJECT:
POLICY ISSUE
(Notation Vote) SECY-95-056
The Commissioners
James M. Taylor
Executive Director for Operations **
DEFERRAL OF REGULATORY OVERSIGHT TO THE U.S.
ENVIRONMENTAL PROTECTION AGENCY FOR TWO
SITES WITH RADIOACTIVE CONTAMINATION AND
LANDFILL DISPOSAL OF LICENSED MATERIAL FROM
REMEDIATION OF A THIRD SITE
PURPOSE:
To obtain the Commission’s approval for the staff to defer to the U.S.
Environmental Protection Agency (EPA) for the oversight of remediation
activities involving radioactive contamination at two sites and for staff’s
intent to allow disposal of licensed radioactive material in a hazardous waste
landfill.
SUMMARY:
The Nuclear Regulatory Commission and EPA conduct regulatory programs for site
remediation under the Atomic Energy Act (AEA) and the Resource Conservation
and Recovery Act (RCRA), and the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), respectively. Under certain
conditions, NRC staff believes it would be appropriate for NRC to defer to
EPA, or an authorized State environmental protection program, for the
oversight of remediation of radioactively contaminated sites under NRC
Contact: Heather M. Astwood, NMSS
415-5819
NOTE: TO BE MADE PUBLICLY AVAILABLE WHEN THE FINAL SRM IS MADE AVAILABLE.
Enclosure
The Commissioners – 2 –
jurisdiction. The staff is proposing to defer, to ERA and an authorized State
environmental program, regulation of remediation of two unlicensed sites:
E.I. DuPont, Newport, DE; and West Lake Landfill, Bridgeton, MO. In addition,
the staff intends to authorize disposal of licensed material generated from
remediating Dow Chemical sites in Midland and Bay City, MI, in a hazardous
waste landfill regulated by the Michigan Department of Natural Resources under
the EPA-authorized RCRA program. Remediation activities at these sites are at
various stages of completion. Based on reviews to date, the staff believes
that the remedial actions and disposal required by ERA, or the authorized
State program, will be sufficient to protect the public and the environment
from the risks associated with the radioactive contamination at these sites.
Deferral would conserve Federal and licensee resources, streamline the
remediation process by eliminating duplicative agency reviews, and simplify
the review process by consolidating regulatory oversight within a single
agency. If the Commission approves deferral and disposal, the staff would:
continue to provide limited technical assistance to ERA or State agencies, on
request, for all sites (licensed and non-licensed); monitor remediation
activities; and review all relevant documents developed by the licensee and
ERA or State for each site with an NRC license.
BACKGROUND:
As part of NRC’s decommissioning program for nuclear facilities under the AEA,
some contaminated facilities pose special problems because of the presence of
both non-radiological and radiological hazards, limited technical and
financial viability of licensees, and concurrent regulatory jurisdiction over
various aspects of decommissioning. Some of the sites are being, or w i l l be,
remediated under EPA’s Superfund Program, in accordance with CERCLA and the
National Contingency Plan in 40 CFR Part 300. Other sites involve assessment
and disposal of hazardous waste under EPA’s RCRA Program. Similar interfaces
exist between NRC and State regulatory programs, in which EPA’s authority
under CERCLA and RCRA has been delegated to States. ERA actively promotes
delegation of the RCRA program to authorized States and tends to defer to
States that are w i l l i n g to oversee preparation of the Remedial
Investigation/Feasibility Studies (RI/FS) for individual sites.
Although the RCRA and CERCLA Programs both address hazards to the environment,
CERCLA is the more comprehensive statute because it addresses both operating
and inactive facilities and includes hazardous materials, as well as source,
special nuclear, and byproduct material as defined in the AEA. The staff
previously discussed EPA’s RCRA and CERCLA Programs in SECYs 93-235 and
93-322. RCRA uses a general regulatory program to manage hazardous waste from
generation to ultimate disposal. CERCLA provides authority to respond
whenever there is a release or potential release of hazardous material. The
facility owner or operator implements RCRA corrective action, whereas CERCLA
responses may be implemented by a number of different parties, including
private or public responsible parties, States, or Federal authorities. CERCLA
“hazardous substances” include RCRA “hazardous wastes,” as well as toxic
pollutants under the Clean Water Act (CWA), Clean Air Act (CAA), and Toxic
Substances Control Act (TSCA). Although source, special nuclear, and
byproduct materials are excluded from regulation under CWA, TSCA, and RCRA,
they are included under the CAA, so they are included within the scope of
CERCLA. Consequently, ERA can require remediation of both non-radiological
The Commissioners – 3 –
and radiological contamination, including source, special nuclear, and
byproduct material, in accordance with CERCLA.1
As a general policy, ERA has declined listing NRC-licensed sites for
remediation on the National Priorities List (NPL), in deference to NRC
regulation under the AEA, provided that remediation is progressing under an
NRC license. However, ERA has required remediation under RCRA or CERCLA at
sites that exhibited non-radiological contamination (e.g., chromium
contamination at the Shieldalloy facility in Newfield, NJ) or that were
licensed by Agreement States (e.g., Homestake uranium mill in Milan, NM).
Based on the most recent version of the NPL (February 1994), the total number
of sites listed on the NPL is 1191. The Superfund Program is wellestablished,
and has defined remediation procedures and criteria, including
those that address radioactive materials. Although the remediation process
and criteria are not identical to NRC’s, they are parallel in scope and
purpose, and in the staff’s judgment, are generally adequate for the
protection of the public and the environment. A detailed explanation of the
Superfund site remediation and closure process is given in Enclosure 1 of
SECY-93-235.
The Commission has previously considered staff recommendations to establish
procedures for transferring sites from NRC to EPA, for remediation under the
Superfund Program. In a staff requirements memorandum (SRM) concerning
SECY-89-224, dated August 22, 1989, the Commission stated that it w i l l decide
whether to pursue the transfer of sites, to EPA, for remediation, on a
case-by-case basis, or through a memorandum of understanding (MOD). The
March 16, 1992, general MOD between EPA and NRC explicitly excludes matters
arising under CERCLA and RCRA. Since the general MOU was signed, NRC staff
has negotiated site-specific cooperative agreements for remediation of the
Homestake uranium m i l l , under CERCLA, and the Sequoyah Fuels and Engelhard
Corporation facilities, under RCRA. The staff is also currently discussing
cooperative agreements with State agencies in Ohio and Pennsylvania.
In another SRM dated December 21, 1989, the Commission rejected the staff’s
recommendation to develop a protocol with EPA to govern the application of
Superfund to contaminated sites. Instead of developing a protocol, the
Commission directed the staff to provide, for each site the staff proposes to
defer to EPA or a State agency, under Superfund, analyses of: (1) the cleanup
standard that would apply under Superfund, and the differences between that
standard and the AEA standard; (2) the rights and authorities the State would
have if Superfund were extended to the site; and (3) the rights and
authorities that private citizens would have to sue the Federal Government or
the licensee(s), using the citizen-suit provisions of Superfund.
More recently, the staff proposed to the Commission, in SECY 93-235, to
communicate with EPA about transferring the Safety Light Corporation (SLC)
site at Bloomsburg, PA, to EPA, to supervise site remediation under Superfund.
The rationale for the transfer was to accelerate the remediation of the site
1 CERCLA does not cover releases that are subject to NRC required
financial protection pursuant to Section 170 of the AE Act (i.e., Price
Anderson), nor releases from a processing site under Title I of the Uranium
Mill Tailing Radiation Control Act of 1978.
The Commissioners – 4 –
and limit the Federal resources devoted to the litigation to compel SLC to
remediate the site. The paper explained that during the first half of 1993,
the staff and the licensee tried unsuccessfully to settle the litigation and
the staff believed, as of the date of the paper, that further negotiations
would be futile and litigation would resume shortly. While the Commission was
considering SECY-93-235, the parties resumed negotiations; and in an SRM dated
November 2, 1993, the Commission returned SECY-93-235 to the staff,
“…pending the outcome of the negotiations,” and instructed the staff to
“…keep the Commission informed of further developments and, based on the
outcome of the negotiations, submit recommendations for further action to the
Commission, should that be necessary.” The staff recently completed
negotiations with SLC and successfully concluded a settlement agreement that
governs characterization and remediation planning for the Bloomsburg site.
In a related matter, SECY-93-136 presented the Commission with an analysis of
the State of Utah decision to allow Envirocare of Utah to use only
institutional controls as a means of reducing the risk to the public health
and safety after closure, without government land ownership. ERA regulations
do not always require government land ownership of sites such as these. The
Commission determined that this approach was adequate for protection of the
public health and safety in this particular case, and in a Director’s Decision
under 10 CFR 2.206 issued by the Office of State Programs on January 26, 1995,
the Commission did not revoke Utah’s Agreement State status.
DISCUSSION:
At sites where radioactive and non-radioactive materials are located in
distinct and separate areas, NRC and ERA oversight and regulation of remedial
actions can proceed effectively and efficiently. Although the effectiveness
of the government’s response and oversight can be strengthened through
interagency cooperation, each area can be remediated independently in
accordance with each agency’s requirements and administrative process.
However, independent regulation of remedial activities is not always possible.
There are some sites that contain commingled radioactive and non-radioactive
contamination. At other sites, the contamination is not commingled, but
remediation of one type of contamination would affect the responsible party’s
ability or approach to characterization and remediation of the other type of
contamination. In other cases, although the predominant hazard may be
associated with one type of contamination, the licensee or property owner is
not capable, technically or financially, to remediate either type of
contamination, thus preventing timely and effective completion of necessary
decommissioning or remedial actions. In yet other cases, the responsible
party desires a coordinated government response to reduce overall costs,
improve efficiency, and promote a compatible solution for both types of
contamination.
Under certain circumstances, the staff believes it would be appropriate for
NRC to defer to ERA or authorized State oversight of remediation efforts,
under CERCLA, RCRA, or State statutes. Deferral at these sites would reduce
the amount of duplicative effort by both agencies and by the site owners. For
example, the types of analyses performed by ERA as part of the development of
the RI/FS, under CERCLA (40 CFR 300.430), are very similar to the analyses
The Commissioners – 5 –
conducted by NRC in developing an Environmental Impact Statement (EIS) under
the National Environmental Policy Act of 1969 (NEPA) and 10 CFR Part 51. Both
agencies require submission of fairly extensive information on the
environmental characteristics of the contaminated sites and the nature and
extent of contamination. In addition, the agencies require preparation and
submission of a plan for implementing remedial measures found necessary to
remove or contain contamination in accordance with applicable remediation
criteria. EPA’s plan is called a Remedial Design; NRC calls this a
decommissioning plan.
Without cooperation between the agencies, therefore, it is conceivable that
site owners could be required by the government to develop separate reports
for each agency on site characterization, assessment of remediation
alternatives, projected environmental impacts, plans for remedial measures,
and documentation that the remedial measures were appropriately implemented.
Such an approach could result in an unnecessarily duplicative and burdensome
effort by the site owners and by the agencies.
At worst, the requirements of one agency could explicitly conflict with those
of the other agency, thus frustrating the government’s overall intent to
ensure protection of the public and the environment from residual
contamination. If, for example, EPA decided to allow hazardous waste to
remain onsite, to avoid excessive worker exposure and cost, and NRC decided
that commingled radioactive waste would have to be exhumed and disposed of
offsite, it would be difficult and burdensome, if not impossible, for the site
owner to simultaneously comply with-the requirements of both agencies. The
conflict would be especially significant if one action preceded the other
(e.g., EPA requires a cover to be placed over the waste; NRC later determines
that the radioactive waste needs to be removed for off-site disposal).
The staff believes that it is appropriate to rely on EPA’s environmental
remediation programs to ensure protection of the public and environment at the
DuPont and Westlake Landfill sites. Both cases may rely, at least in part, on
institutional controls to ensure long-term protection. As discussed
previously and in the attachments, such reliance on institutional controls is
somewhat inconsistent with NRC’s established policies for low-level
radioactive waste disposal (cf. State or Federal land ownership requirement
for low level waste disposal in 10 CFR 61.59(a)). However, the staff believes
that EPA remediation will be sufficient to provide adequate protection under
the Atomic Energy Act.
In addition, deferral to EPA provides numerous savings in terms of reducing
the administrative and regulatory burden on responsible parties conducting the
remediation and in conserving NRC staff resources. The staff estimates that
deferral of each site should save between 0.25 and 0.5 FTE per year in direct
staff resources required to oversee remediation at the sites. These resources
would partially duplicate the oversight functions that EPA staff will provide
in overseeing the safe and protective execution of the planned remedial
actions. In addition, deferral should save NRC an additional 0.5 FTE per year
and S600K in program support that could be necessary at each site to prepare
an Environmental Impact Statement (EIS) to support consideration of exemptions
from NRC’s existing requirements for decommissioning for unrestricted use.
The Commissioners – 6 –
Since November 1993, the staff has initiated several EISs to consider
exemption requests as appropriate considering the requirements in 10 CFR Part
51. Deferral should also improve the timeliness of remediation by avoiding
the potential delay that could be associated with administration of
independent and complementary regulatory approval processes for remediation.
Remediation could be further delayed by opportunities for legal challenges to
NRC approval of remedial actions.
Allowing disposal of the Dow wastes in the hazardous waste landfill cells in
Midland may also allow a small increase in the long-term risk to the public
and environment due to some reliance on institutional controls. As previously
described for the Westlake and DuPont site remediation projects, however, NRC
staff believes that such disposal would provide adequate protection of the
public, and any small increase in the associated risk is counterbalanced by
the improvements in efficiency, reduction in regulatory and administrative
burden, and savings of NRC and responsible party resources.
The staff does not consider, however, that these cases would necessarily
establish a precedent for resolution of other waste disposal and
decommissioning cases or establishment of general requirements in these areas.
The decisions on deferral and on approving waste disposal are specific to
these cases. In the cases of DuPont and Westlake Landfill, the radioactive
components appear to be intimately mixed with non-radiological contaminants
and wastes that are not subject to the Commission’s jurisdiction. In fact, at
least for some of the wastes, the dominant risks to the public and environment
may be attributable to the non-radiological contaminants. In addition, both
sites are already listed on the National Priorities List for remediation under
CERCLA, and the basis for listing and selection of the remedies included
consideration of the radiological contaminants.
In the Dow case, the staff has considered the merits of disposing of the
specific wastes present at the Dow sites and under the specified conditions
for disposal as proposed by the licensee and the State. Staff has already
approved other disposals of radioactive waste in or adjacent to hazardous
waste landfill cells in accordance with the provisions of 10 CFR 20.302 and
20.2002. Each of these disposals has been based on a site-specific review by
the NRC staff to ensure adequate protection of the public and that potential
radiological doses do not exceed NRC’s limits in 10 CFR Part 20. In most
cases, the staff has assured that the potential doses do not exceed a small
fraction of the public dose l i m i t . The Dow case is especially significant,
however, because it involves the disposal of a relatively large volume of
radioactive waste that will be generated in decommissioning an SDMP site and
that intrusion into the waste, if it were to occur, could result in doses that
may exceed the public dose limit (e.g., if the intruder were to live on top of
exposed waste for an extended period). The staff believes that the likelihood
of such intrusion is remote in the Dow case because of the design of the
disposal cells and the use of the general area for disposal of hazardous
waste. It is likely that an intruder into the waste would recognize that a
waste disposal cell had been breached and could suffer risk from the nonradiological
contaminants in adjacent cells even if the NRC did not authorize
disposal of the radioactive waste.
The staff would be prepared to entertain similar requests to the Dow request
from licensees to dispose of licensed material in hazardous waste landfills or
The Commissioners – 7 –
other suitable disposal facilities (e.g., monofills, sanitary landfills) in
accordance with the requirements of 10 CFR 20.2002. In such cases, as with
the Dow case, the burden would rest with the licensee to demonstrate that the
requirements of 10 CFR Part 20 will be satisfied, specifically that the
potential doses will be consistent with the Part 20 limits and are as low as
is reasonably achievable. Credit for institutional controls, such as those
that accompany Dow’s proposal, would also be considered on a site-specific
basi s.
For these reasons, the staff believes that NRC should defer to EPA or State
oversight regulatory programs for specific aspects of the remediation of two
contaminated sites: E.I. DuPont, Newport, DE; Cotter Corporation (West Lake
Landfill), Bridgeton, MO; and allow disposal of radioactive waste from
remediation in a RCRA permitted landfill for Dow Chemical, Midland and Bay
City (Salzburg Landfill), MI. By deferral, the staff means a variety of
approaches depending on the specific status of the contaminated sites.
For the DuPont site, the staff proposes to recognize EPA’s approved remedial
measures under CERCLA as being sufficiently protective of the public and
environment. The site is not currently licensed by NRC; NRC licensing and
oversight of the remediation of a small quantity of thorium waste in a
landfill would not be necessary, nor required, under the AEA. No further
action would be taken by the NRC staff, unless specifically requested by EPA.
For the West Lake Landfill site, EPA has already agreed to assume lead
responsibility for the site. The West Lake Landfill is listed in NRC’s Site
Decommissioning Management Plan (SDMP). The NRC staff is proposing to defer
to EPA oversight of remedial measures under CERCLA. EPA’s remediation of the
site already considers both radioactive and non-radioactive materials. The
site is not currently licensed by NRC; the staff would take no further action
at the site after deferral, unless specifically requested by EPA. NRC would
remove the site from the SDMP after EPA completes remedial measures at the
site.
Regarding the Dow Chemical sites in Midland and Bay City, Michigan, the staff
proposes to allow the licensee to dispose of thorium-contaminated waste in a
licensee-owned and permitted hazardous waste landfill designed and operated in
accordance with the RCRA requirements administered by EPA and the State of
Michigan. The staff would authorize disposal in accordance with NRC
requirements in 10 CFR 20.2002 and support the decision with an Environmental
Assessment that would presume the effectiveness of RCRA controls in ensuring
protection of the public and environment. Regulatory responsibility for the
management and long-term control of the thorium in the disposal site would, in
theory rest with NRC. However, in terminating the license, NRC would
recognize that controls for the hazardous waste, developed under RCRA, while
relying on land use restrictions which are not dependant on State or EPA
regulatory power, w i l l be adequate for the thorium as well. In allowing
disposal in the Salzburg Landfill, NRC would be recognizing that disposal of
thorium-contaminated wastes in a hazardous waste landfill may be acceptable
under the AEA, instead of requiring offsite disposal at a licensed radioactive
waste disposal facility. The Dow storage sites are listed in the SDMP and are
being remediated under an NRC license. NRC staff would continue to license
and regulate the remedial measures directed at removing the thorium waste from
its present locations. At such time as all waste has been satisfactorily
The Commissioners – 8 –
disposed of in the hazardous waste landfill and residual radioactivity has
been reduced in accordance with existing criteria, the staff would terminate
Dow’s license for the Midland and Bay City sites and no further action would
be taken by the NRC staff.
Background information for the DuPont, Westlake Landfill, and Dow sites is
provided in Attachments 1 to 3, respectively. The potential advantages and
disadvantages of deferral for each site are summarized in Attachment 4.
Requested Analysis:
In accordance with the Commission’s previous direction on information to
support deferral decisions, the staff provides the following analyses of:
(1) the cleanup standard that would apply under Superfund and the differences
between that standard and the AEA standard; (2) the rights and authorities the
State would have if Superfund were extended to the site; and (3) the rights
and authorities that private citizens would have to sue the Federal Government
or the licensee(s), using the citizen-suit provisions of Superfund. The
following analyses are presented in generic terms that would apply to all
three sites. The discussion about remediation criteria is only pertinent at
this time to the West Lake Landfill site; ERA has already decided to stabilize
the thorium waste in place at the Dupont site, and the thorium waste from Dow
would be disposed of in an RCRA-regulated landfill cell. To compare specific
EPA and NRC remediation standards for the West Lake Landfill, more information
would be needed on the remediation criteria EPA intends to implement at that
site. EPA will determine these criteria through the RI/FS and Record of
Decision (ROD) process, as described below.
(1) Remediation Standard
As previously stated, both NRC and EPA have been granted the authority
to regulate radioactive materials, in certain situations. To determine
what remediation standards would govern the remedial actions at a
specific site, EPA would perform a Feasibility Study (FS). This study
is the basis for the development of a ROD that establishes remediation
standards and remedial actions for each site. EPA would prepare the FS
after the site had been scored and entered on the NPL, as explained in
Enclosure 1 of SECY-93-235.
EPA’s requirements for FSs in 40 CFR 300.430(e)(2)(i) require that the
lead agency establish remedial action alternatives, including
remediation objectives and goals. The remediation goals establish
acceptable exposure levels to protect human health and the environment
and are developed considering: applicable or relevant and appropriate
requirements (ARARs) under Federal or State environmental laws,
drinking-water standards and goals, water-quality criteria, and other
factors. For known or suspected carcinogens (including ionizing
radiation), acceptable exposure levels are generally concentration
levels that represent an excess upper-bound lifetime cancer probability,
for an individual, of about 10″A and a cancer probability of 10″6 for as
many in the population as practical. The 10″6 probability is used as
the point of departure for determining remediation goals when ARARs are
not available or are not sufficiently protective, because of the
presence of multiple contaminants or multiple pathways.
The Commissioners – 9 –
These risk goals do not necessarily take into account human intrusion in
the future. If human intrusion were to be considered in the dose
pathway analysis, the calculated dose for thorium contaminated sites
could be in excess of 100 mrem/yr assuming standard exposure scenarios
(e.g., resident farmer scenario). Therefore, sites with significantly
elevated thorium concentrations would not necessarily meet the
provisions of the proposed NRC rule on radiological criteria for
decommissioning (proposed amendments to 10 CFR Part 20; 59 FR 43200).
The statement of considerations for the proposed rule acknowledges that
some sites could not meet the limits proposed in the rule. Deferral to
the Federal Superfund/RCRA approach is a possible way to address these
cases.
NRC risk analyses differ from ERA risk analyses in several ways. ERA
calculates risk based on the chance of developing cancer. NRC relates
risk to both the chance of developing cancer and the chance of a
fatality as a result of cancer. NRC staff calculated the risk to a
maximally exposed member of the public who at some time in the future,
could reside on top of the site. By using a general risk estimate of
5xlO”2 fatal cancers per sievert (5xlO~4 per rem) of received dose
developed for exposure of a large population, NRC can estimate a
potential risk, to an individual, produced by a specific exposure.
Nevertheless, were an actual measured exposure to occur, the staff
recognizes that it would be more appropriate to estimate the risk to
that individual using the cancer risk tables developed by the National
Cancer Institute.
In general, NRC has not relied on institutional controls as a means for
protecting the public or the environment for decommissioning purposes.
However, ERA and DOE have relied on institutional controls to prevent or
reduce the likelihood for human intrusion and otherwise protect the
public (e.g., restrictions on groundwater use). Staff compared
regulatory considerations of institutional controls in SECY-93-322,
dated November 26, 1993. Reliance on institutional controls directly
affects projected risks to exposed humans.
Based on information provided by the ERA staff, NRC has reviewed 19 RODs
for sites that include some radiological contamination. Most cases
involved contamination by radium-226 and its decay products and other
naturally-occurring radionuclides. In most of the RODs, ERA selected
ARARs based on EPA’s standard, for remedial action, at uranium mill
tailings sites in 40 CFR Part 192. In many cases, ERA also identified
NRC guidance in Regulatory Guide 1.86 “Termination of Operating Licenses
for Nuclear Reactors,” as an ARAR for surface contamination on buildings
and equipment. Other sources of ARARs for radiological contamination
include: NRC’s air concentration limits in 10 CFR Part 20, Appendix B;
State guidance on acceptable surface contamination; DOE orders for
acceptable public and worker doses; Federal and State water quality
standards; and Federal and State air-emission limits.
The Commissioners – 10 –
(2) State Authority under Superfund
For facilities covered by CERCLA, 42 USC 9605, et sec?., the States are
encouraged to enter into cooperative agreements to enable them to
undertake certain actions, under the National Contingency Plan (NCR), as
the lead agencies. State and local response organizations are expected
to initiate measures necessary to protect the public health and safety,
consistent with the containment and cleanup requirements in the NCR.
The RI/FS required under 40 CFR 300.430(d) and (e) are to be performed
by a lead agency, in coordination with any support agencies. Under
40 CFR 300.5, the State may be designated as the lead agency to plan and
implement a response, if it is operating pursuant to a contract or
cooperative agreement, under Section 104(d)(l) of CERCLA, or designated
as the lead agency in a Superfund Memorandum of Agreement (SMOA) or
other agreement. In addition, even if the State does not serve as lead
agency, the lead agency is required to consult with the local officials
and community representatives before commencing field work for the
remedial investigation. Under 40 CFR 300.430(c), support agencies are
afforded an opportunity to identify their own ARARs, under 40 CFR
300.430(d)(3). Support agencies are to be notified, by the lead agency,
of the alternatives that will be evaluated in detail, to facilitate the
identification of ARARs and any appropriate guidance to be considered,
under 40 CFR 300.430(e)(8).
In addition to the above, 40 CFR 300.430(e)(9)(iii)(H) requires that the
State’s concerns be assessed, including its views on the preferred and
other alternatives for remedial action and the ARARs or proposed use of
waivers.
Further, 40 CFR 300.430(f)(1)(i)(C) provides that the lead agency must
consult with the State, and that State and community acceptance are
modifying criteria that are to be considered in the remedy selection.
Section 300.430(f)(4)(i) provides that the State’s views are to be
considered by the lead agency in its final remedy selection from among
the various alternatives.
(3) The Rights of Private Citizens under Superfund
As discussed above, ERA is to solicit community participation in the
identification of ARARs and other aspects of the RI/FS process. In
addition, private citizens are authorized under CERCLA to undertake a
response action to eliminate a release of a hazardous substance,
pollutant, or contaminant, subject to the citizens’ compliance with the
provisions of 40 CFR 300.700. Various mechanisms are provided in CERCLA
for a private citizen to recover the cost of such response action.
These mechanisms are summarized in 40 CFR 300.700, and include:
(a) recovery of the response cost, plus interest, from the
parties found to be liable; and (b) recovery from Superfund of the
private citizen’s reasonable costs, plus interest.
In addition, “citizens suits” are authorized under Section 310 of
CERCLA. Private citizens are authorized to commence a civil action, on
The Commissioners – 11 –
their own behalf, against: (a) any person who is alleged to be in
violation of any standard, regulation, condition, requirement, or order
under CERCLA; and (b) any Federal official who is alleged to have failed
to perform a required duty, under CERCLA. Judicial relief, in such
actions, may consist of an order to enforce and/or correct the violation
or an order imposing any civil penalty provided for the violation; and
the court may award the prevailing party his costs of litigation,
including reasonable attorney and expert witness fees.
RECOMMENDATIONS:
That the Commission:
1. Approve deferral to EPA’s CERCLA program for the remediation of the
thorium waste located on the E. I. DuPont Superfund site in Newport, DE.
2. Approve deferral to EPA’s Superfund program for remediation of the West
Lake Landfi11/Cotter Corporation site in Bridgeton, MO.
3. Approve staff’s plans to pursue a request submitted by Dow
Chemical Company for an exemption from the unrestricted release
provisions of 10 CFR 40.42(f)(3) and to authorize disposal of
thorium waste from remediation in a landfill in accordance with
10 CFR 20.2002. The landfill would be regulated under Michigan
hazardous waste regulations that implement the RCRA program for
long term control of the waste in the Salzburg Landfill cells,
including reliance on institutional and State control and longterm
monitoring of the Salzburg Landfill site in Midland, MI.
4. Note:
a. That although EPA is authorized to regulate byproduct, source, and
special nuclear material under CERCLA and CAA, the State agencies, if
they are not NRC Agreement States, are not authorized except under CAA.
That even though NRC is allowing disposal under the RCRA program
administered by EPA and Michigan Department of Natural Resources, NRC
staff will continue to regulate remediation of the Dow Chemical storage
sites in Michigan, which are currently licensed by NRC. With respect to
the disposal in the Salzburg landfill, the staff will continue to review
pertinent documents to ensure Michigan is not applying significantly
less stringent waste disposal requirements than NRC.
b. That reliance on institutional controls over the long term may not
provide as high a level of protection for the public health and
environment as that attained if there were no reliance on institutional
controls. This lower level of assurance results from the lack of a
guarantee that there will always be a responsible party to maintain the
controls.
The Commissioners – 12 –
COORDINATION:
The Office of the General Counsel has reviewed this paper and has no legal
objection. NRC staff consulted with ERA and the States of Delaware, Missouri,
and Michigan in preparing this paper. Neither ERA nor the States objected to
the staff’s proposed approach.
~2^1/L~
x , „„ /A- -^*yl^-^
/J^mes M. Ta/lor
(ecutive Director
for Operations
Attachments:
1. Bkgd Info for E.I. DuPont
2. Bkgd Info for Cotter Corporation
West Lake Landfill
3. Bkgd Info for Dow Chemical
4. Adv/Disadv of Prop Options by Site
Commissioners’ comments or consent should be provided directly to the Office
of the Secretary by COB Friday, March 24, 1995.
Commission Staff Office comments, if any, should be submitted to the Commissioners
NLT March 17, 1995, with an information copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional review and comment,
the Commissioners and the Secretariat should be apprised of when comments may
be expected.
Distribution:
Commissioners
OGC
OCAA
DIG
OPA
OCA
ACNW
Region I
Region III
EDO
SECY
BACKGROUND INFORMATION FOR THE
E.I. DUPONT NEWPORT, DELAWARE, SITE
The E.I. DuPont site is located in Newport, Delaware, near 1-95, 1-495, and
the Christina River. The entire site is approximately 485,600 m2 (120 acres)
and contains a paint pigment production facility, a chromium dioxide
production facility, and two industrial landfills (North and South) which are
closed.
DuPont was licensed by the U.S. Atomic Energy Commission (AEC) and began using
radioactive materials at this site in 1961, for the processing of thorium into
metal alloys. The alloys consisted mostly of nickel, some chromium and
molybdenum, and thorium (approximately 2 to 5 percent by weight thorium-232).
Waste materials from this process were buried in the North Landfill,
reportedly, in accordance with 10 CFR 20.304 regulations that were in effect
at the time. According to DuPont, the thorium waste was placed in glass jars
that were subsequently placed in 55-gallon barrels together with disposable
protective clothing and debris from the waste-handling operations. The
barrels were then buried in a specific, although uncertain, section of the
North Landfill and covered with 3 m (10 feet) of soil. The area where the
thorium was buried is estimated to be 40 m by 10 m (130 ft by 35 ft) and
contains approximately 20 tons of thorium metal, which were placed in the
North Landfill over a 7 year period.
DuPont believes most of the thorium in the North Landfill consists of thorium
oxide, a relatively insoluble form of thorium. However, DuPont’s records, as
well as information in the Nuclear Regulatory Commission’s docket files,
indicate that thorium nitrate, a more soluble form of thorium, and other salts
could also have been disposed of in the North Landfill. Long-term releases
from these other forms of the thorium waste could be greater than from the
thorium oxide. They could also pose a greater threat to shallow groundwater
beneath the North Landfill site, because of leaching and subsequent transport.
The thorium burials comprised a small portion of the North Landfill area. The
remaining portion of the North Landfill was used for the disposal of
lithophone wastes (an inorganic paint pigment based on zinc and barium),
organic pigment wastes, chromium wastes, and other miscellaneous wastes,
including the off-specification thoriated nickel and other thorium wastes.
The Environmental Protection Agency (EPA) initiated the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Program for
remediation of the site in the 1980s and proposed the site for inclusion on
the National Priorities List (NPL) in 1987. EPA proposed the site for
remediation under CERCLA because of extensive non-radiological contamination.
DuPont used historical records and interviews with retired employees to
estimate the quantity of thorium that was buried in the l a n d f i l l . However,
the records are not complete and the exact quantity and form of the thorium
are not known. Although the entire DuPont site is currently undergoing
remediation, remediation of the North Landfill is of the most concern to NRC
because of the thorium buried in the landfill. The North Landfill is only a
small section of the entire 120-acre site.
Attachment 1
-2-
Based on available records of the burials, NRC staff believes that at least
some of the thorium wastes in the North Landfill exceeds the concentration
criteria in Options 1 and 2 of the 1981 Branch Technical Position (BTP)
entitled: “Disposal or Onsite Storage of Thorium or Uranium Wastes from Past
Operations” (46 FR 52061). NRC identified these criteria as the pertinent
release criteria in the Site Decommissioning Management Plan (SDMP) Action
Plan of April 16, 1992 (57 FR 13389) coupled with the principle that residual
radiation be reduced to as low as is reasonably achievable (ALARA). Because
thorium concentrations are expected to exceed these criteria in some areas by
a substantial margin (e.g., 10,000 pCi/g thorium-232), the NRC staff would
generally not consider onsite disposal as a viable disposal action.
In addition, as described above, it is possible that there are soluble forms
of thorium in the landfill, which could become mobile and enter the
groundwater beneath the site or the river adjacent to the site. DuPont has
not attempted to characterize the thorium waste in the landfill for the
following reasons: (1) the exact location of the thorium in the landfill is
not known; (2) intrusive and extrusive sampling may be necessary because the
waste is very heterogeneous, which would make accurate sampling through a
limited number of boreholes difficult; and (3) exposure to the hazardous
material in the landfill would cause risks to workers during the
characterization and sampling process.
Monitoring well sampling found slightly elevated levels of radium-226 and
radium-228 in the groundwater adjacent to the landfill. DuPont believes the
elevated levels are representative of background. Elevated levels of radium
were not found in surrounding wells or in wells located between the landfill
and the well containing the elevated readings.
EPA w i l l require DuPont to place a low-permeability cover system over the
landfill, capable of reducing infiltration by over 99 percent, to minimize
groundwater contamination below the site. In addition, DuPont is required to
construct a physical barrier wall extending from the top on the landfill,
along the river bank and down to the base of the Columbia aquifer. This wall
w i l l cause mounding of the groundwater in the landfill. Groundwater
extraction wells w i l l be installed to control this mounding. The recovered
groundwater shall be treated. This wall will prevent the contaminated
groundwater from entering the river. Monitoring will be needed to ensure
there will not be erosion of the river bank and the potential for erosion from
the river into the landfill itself.
The potential risks produced by the thorium contamination are small compared
with the risks posed by the other hazardous waste in the North Landfill, as
well as the materials on the remaining portions of the site. EPA’s risk
assessment supporting the ROD concluded that non-radiological risks
predominate over radiological risks associated with the thorium waste buried
in the landfill. EPA requires in the ROD that DuPont: monitor groundwater to
detect any potential migration of thorium or its decay products; apply
institutional controls to restrict public access to the waste and to
groundwater beneath and adjacent to the site; and assess the existence of
radiological contamination at other locations onsite. The remedial action
identified in the ROD was developed through a public process that involved
DuPont, State of Delaware, local community officials, members of the public,
and other interested parties.
The NRC staff believes that the remedial action required by EPA, under CERCLA,
-3-
would be sufficient to protect the public and the environment from the risks
associated with the thorium waste. Although NRC and ERA staffs suspect that a
majority of the thorium is in the relatively insoluble oxide form, there is a
possibility that some more soluble thorium compounds exist in the landfill.
However, with the cap, wall along the river bank, groundwater monitoring,
institutional controls, and groundwater use restrictions, the staff believes
that any significant contamination of the groundwater by thorium is unlikely
to occur. However, if it does, the staff believes the contamination would be
accompanied by other contaminants, promptly detected, and mitigated before
causing any significant health or environmental hazards.
Since the site is not currently licensed by NRC, the staff would not undertake
any other activities directly related to remediation of the site, including:
performing reviews of licensing (Superfund-required) documents; undertaking
site visits or inspections; monitoring ERA progress on the remediation; and
examining the completion of cleanup activities.
BACKGROUND INFORMATION FOR THE
WEST LAKE LANDFILL/COTTER CORPORATION
BRIDGETON, MISSOURI SITE
The West Lake Landfill is a 809,000 m2 (200-acre) tract located in St. Louis
County, Missouri, approximately 16 miles northwest of downtown St. Louis.
Beginning in 1962, portions of the property were used as an unregulated dump
for solid and liquid industrial wastes, municipal refuse, and construction
debris. In 1973, Cotter Corporation, a Nuclear Regulatory Commission
licensee, disposed of over 39,000 metric tons of uranium ore processing
residues and contaminated soil in two areas covering about 64,750 m2 (16
acres) of the site. This is a relatively small portion of the larger
809,000 m2 (200-acre) site. In 1976, the unregulated landfill was closed, and
in following years, the Missouri Department of Natural Resources issued
several permits for various portions of the 809,000 m2 site. Efforts to
remediate the site included NRC survey and site characterization work in the
1980s. In 1990, the Environmental Protection Agency (ERA) listed West Lake
Landfill as a Superfund site by adding it to the National Priorities List.
Under Superfund, EPA is now regulating remediation of the site for both
radiological and other hazardous wastes.
The radioactive wastes in the two soil areas are mostly covered by other
landfill materials. The site poses no immediate radiological threat to the
public. Radioactive wastes, in concentrations greater than the current NRC
standards for unrestricted release, are found in two soil piles and include
uranium-238, thorium-230, and radium-226. Elevated levels of radioactivity
(gross alpha particle contamination) have been detected in groundwater
monitoring wells onsite, indicating slight contamination above background.
The NRC staff proposes to defer to EPA’s Superfund Program for the remediation
of uranium contamination. NRC staff has already acknowledged that EPA’s
Superfund Program is responsible for the remediation of the radioactive waste
on this site. A letter dated May 1991 states that “. . . EPA is taking the
lead for site remediation activities . . . .” NRC staff has performed limited
reviews of EPA-required documents, including the Remedial Investigation/
Feasibility Study for the site, that included considerations of both
radiological and non-radiological material onsite. The NRC staff believes the
remedial actions that would be required by EPA, under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), would be
sufficient to protect the public and the environment from the risks associated
with the uranium contamination.
Under this deferral scenario, NRC staff would continue to provide certain
technical support to EPA, at the specific request of EPA. In addition, NRC
would retain a copy of the Record of Decision in the permanent files for the
site. The staff would take no further action at the site after deferral to
EPA, since the site is not currently licensed by the NRC.
Attachment 2
BACKGROUND INFORMATION FOR THE DOW CHEMICAL COMPANY
BAY CITY AND MIDLAND, MICHIGAN, SITES
Dow Chemical Company possesses thorium-contaminated waste under a Nuclear
Regulatory Commission license at two sites in Michigan: Bay City and Midland.
The Bay City site is located 1 mile south of Saginaw Bay and is 20 miles east
of Midland, Michigan. The thorium-contaminated waste at this site is stored
in a fenced-in area owned by Dow Chemical Company. Approximately 30,500 m3
(40,000 yd3) of thorium-contaminated waste is estimated to be stored at the
Bay City site. This waste has an average concentration of 188 pCi/g thorium-
232, with a range of from 2 to 7000 pCi/g thorium-232. Dow estimates that
there are about 9.2 Ci of thorium-232 and an equivalent amount of thorium-228
at the Bay City location.
The estimated volume of the thorium-contaminated waste at the Midland site is
over 9000 m3 (12,000 yd3). The area where the waste is stored at the Midland
site measures 50 m by 90 m (160 ft by 300 ft) and is roped off. The waste is
covered by a clay cover that is approximately 1-meter thick. The thoriumcontaminated
waste storage area is located within a larger industrial complex
that Dow owns and controls access to. The radioactivity in the waste varies
substantially and ranges up to 2000 pCi/g, with an average of 29 pCi/g
thorium-232 and an equivalent activity concentration of thorium-228. Dow
estimates that there is approximately 0.46 Ci of thorium-232 in the waste at
this site.
In 1956, the U.S. Atomic Energy Commission gave Dow Chemical Company a license
to use thorium metal and compounds to produce thorium-magnesium alloys. The
alloying process produced a thorium-contaminated waste. In 1973, the license
was amended to authorize storage only at Dow’s Bay City and Midland sites in
Michigan, and at the Madison site in Illinois. The Madison site is now under
the regulatory authority of the Illinois Department of Nuclear Safety.
Thorium-contaminated waste and associated contaminated soil are currently
being stored at both sites. Dow proposes to dispose of its thoriumcontaminated
waste in two dedicated disposal cells at the Dow-owned and
operated Salzburg Landfill in Midland. The Salzburg Landfill is permitted by
the Michigan Department of Natural Resources and the Environmental Protection
Agency (ERA), for the disposal of hazardous and non-hazardous solid wastes.
The Salzburg Landfill, is relatively large [615,100 m2 (152 acres)], and is
located 1.5 miles from the Midland site and 20 miles from the Bay City site.
The proposed disposal cell design, for the thorium-contaminated waste, would
be comprised of, from the bottom, a 6 meter clay underliner with a hydraulic
conductivity of less than 10″6 cm/s; 1 meter of recompacted clay with
hydraulic conductivity of less than 10″7 cm/s; a synthetic liner with a leak
detection and removal system consisting of a 0.33-meter sand drainage layer;
1.5 meters of clay; a geosynthetic liner; and a 0.33-meter sand leachate
drainage layer. This liner would underlie the thorium-contaminated waste
which would be covered by 1 meter of clay; a 100-mil HOPE synthetic liner;
0.33 meters of drainage medium; almost a meter (91 cm) of a frost protection
layer; and 0.66 meters of top soil. No liquid wastes are allowed to be
disposed of at the Salzburg Landfill. The approximate design area for one of
the proposed thorium-contaminated waste disposal cells is 61 m (200 ft) long
by 40 m (125 ft) wide, and the other is 221 m (725 ft) long by 23 m (75 ft)
Attachment 3
-2-
wide. Both disposal cells will be covered by a unified cover. There are 16
shallow monitoring wells around the proposed disposal cells. These monitoring
wells are required under Resource Conservation and Recovery Act (RCRA) and
State of Michigan hazardous waste requirements. Groundwater monitoring wells
and domestic wells in the area are sampled as part of the Salzburg Landfill
monitoring program.
The NRC staff proposes to allow Dow Chemical Company to dispose of licensed
material in EPA-approved RCRA designed cells in accordance with 10 CFR 20.2002
and thereby be exempt from NRC’s unrestricted release criteria of 10 CFR
40.42(j)(3) [Although the amended rule does not refer to unrestricted release,
but to release in accordance with NRC requirements, the criteria of the SDMP
Action Plan apply. These are essentially unrestricted release criteria.] Dow
has requested to bury thorium-contaminated waste in the Salzburg landfill, per
10 CFR 20.2002, at concentrations above NRC’s SDMP Action Plan criteria for
unrestricted release.
There is a parallel between what is being proposed by Dow and the burial of
low-level waste under 10 CFR Part 61. The performance objectives for the
disposal of low-level radioactive waste, as stated in 10 CFR Part 61 and the
Final Environmental Impact Statement for Part 61 (NUREG-0945), are to: 1)
protect public health and safety (and the environment) over the long term; 2)
protect the inadvertent intruder; 3) protect workers and the public during the
short-term operational phase; and 4) provide long-term stability, to eliminate
the need for active long-term maintenance after operations cease. The staff
believes that disposal of the thorium waste in the landfill would be generally
consistent with these objectives, although the staff has not completed the
kind of detailed review that would be required for a license application under
10 CFR Part 61.
For thorium contamination of the type presently stored by Dow under its
license, the dominant exposure pathway is direct exposure from human
intrusion. Thorium-232 has an extremely long half-life (in excess of 14
b i l l i o n years). Thus, the potential hazard will continue to exist whether the
material is excavated and shipped to a licensed disposal site (at an estimated
cost of about $28 million if disposed at Envirocare or significantly more if
disposed at a licensed low-level waste disposal facility) or excavated and
shipped to the Salzburg Landfill (at a cost of about $5 million). The primary
safety issue then becomes how to minimize the potential for human intrusion
over the long term under either disposal alternative. Dilution of the
contamination was not considered due to the significant increases in waste
volume that would be required to substantially reduce thorium concentrations
down to levels approaching natural background for soils in the Midland area.
As a regulated hazardous waste disposal facility, institutional controls would
be required to be maintained over the Salzburg Landfill under hazardous and
solid waste regulations. Dow states that, even though the concentration of
thorium in the waste exceeds NRC’s criteria for unrestricted release, the colocation
of the thorium waste disposal cells with the hazardous and solid
waste disposal cells would offer sufficient institutional control to deter
intrusion over the long term. The institutional controls offered by hazardous
and solid waste regulations involve environmental monitoring and reporting,
maintenance and release control, and controls on the post-closure use of the
land (i.e., no disturbance of the waste or any components of the disposal
unit). There are additional requirements for post-closure financial assurance
and a schedule for closure. Dow estimates that the pre-closure operational
-3-
period for the Salzburg Landfill will extend until approximately the year
2045. The post-closure institutional control period generally lasts 30 years
and can be extended by the ERA Regional Administrator or State agency. The
Salzburg Landfill is not a remote site, but because of the existence of the
hazardous waste already buried there, the land can never be used productively
again for farming and other non-industrial applications without extensive
remediation. Dow has already imposed restrictive covenants in the Salzburg
Landfill deed, in accordance with ERA requirements for hazardous waste
landfills. If the thorium wastes are buried in the Salzburg Landfill, Dow
proposes a requirement (to be inserted into the deed) to notify NRC (or its
successor) before disturbing the landfill.
On balance, the staff believes that disposing of the thorium wastes at the
Salzburg Landfill constitutes an as low as reasonably achievable (ALARA)
approach to remediation of the Bay City and Midland sites, and that the
conditions and restrictions placed on the landfill, combined with the RCRA
regulatory and cell design provisions, provide a comparable level of
protection of human health and the environment, as is provided at other
licensed low-level waste disposal sites. In the Office of the General
Counsel’s opinion, Dow’s proposed restrictive covenants appear adequate to
support an exemption. With one exception, the restrictive covenants, and the
co-location of the thorium-contaminated waste disposal cells with hazardous
and solid waste disposal cells, appear to achieve the same effect as if this
thorium-contaminated waste were buried at a location where State or Federal
control alone is considered sufficient to guarantee institutional care.
Inadvertent intrusion into the thorium waste disposal cells would be
controlled by the restrictive covenants on the deed as proposed by Dow in its
exemption request. The one exception is that, as with the Envirocare facility
in Utah, there is no assurance that, for the very long term, there will be a
responsible party with the obligation to take additional remedial action
should this become necessary.
Therefore, NRC staff proposes to allow disposal of licensed radioactive
material in the landfill operated by Dow and regulated by ERA and the State of
Michigan. This decision would be supported by an appropriate Environmental
Assessment, which would presume the adequacy of the cell design and
institutional controls (including ERA and Michigan regulation) in protecting
humans and the environment. NRC staff would notice in the Federal Register
its intent to issue a license amendment to allow the disposal of the waste in
the Salzburg Landfill, including the exemption. Pursuant to Subpart L of 10
CFR Part 2, the notice will offer an opportunity for an informal hearing. The
hearing would include approval of the decommissioning plan and the transfer
and disposal under 20.2002 at the Salzburg l a n d f i l l . Following completion of
the necessary safety and environmental reviews, NRC staff anticipates issuing
the amendment, provided the safety and environmental reviews are favorable.
Because the Dow storage sites are currently licensed by the NRC, the staff
would monitor the remedial activities being performed by Dow to ensure that
NRC requirements are satisfied. The staff would review all pertinent
documents and would terminate the license after disposal of the radioactive
material currently in storage at the Bay City and Midland sites and the
storage sites are cleaned up to unrestricted use standards.
ADVANTAGES AND DISADVANTAGES OF
PROPOSED OPTIONS FOR EACH SITE
Attachment 4
E. I. DUPONT CORPORATION
Administrative Alternatives for the
Remediation of the Newport, Delaware, Site
Deferral to EPA Superfund NRC Maintains Responsibility
Advantages
• Allows DuPont to continue remediation activities
in a timely and effective manner.
• Reduces delays and expense produced from
duplicative regulation.
• Ensures consistency in remediation decision for
both radiological and non-radiological waste.
• Avoids need for an NRC license.
• Promotes interagency cooperation and consistency
in selection of remedial actions.
Advantages
Remediation of the thorium contamination down to
Option 1 or 2 levels2 would reduce risk to
inadvertent intruders.
Provides higher level of assurance that remediation
is conducted in a satisfactory manner, from NRC’s
perspective.
2 Option 1 or 2 of the 1981 Branch Technical Position “Disposal or Onsite Storage
of Thorium or Uranium Wastes from Past Operations.”
-2-
Disadvantages
Relies on institutional controls for protection
of the public.
Could require removal at some point in the
future, if the thorium contaminates the
groundwater.
Reduces assurance of satisfactory remediation
from NRC’s perspective.
Disadvantages
May ultimately find that current proposed
remediation is acceptable and preferable, after
additional expense and time.
If exhumation would be required, could result in
increased risk to workers from exposure to nonradiological
and radiological wastes in the landfill
and extended storage of waste pending access to
disposal facilities.
Increases costs for DuPont, ERA, and NRC.
May require additional effort to establish location
of thorium waste in landfill.
Could require NRC license.
Could delay or impair remedial actions for the other
wastes onsite, pending resolution of the thorium
waste disposal issue._____________________
-3-
WEST LAKE LANDFILL/COTTER CORPORATION
Administrative Alternatives for the
Remediation of the Bridgeton, Missouri, Site
Deferral to ERA Superfund NRC Maintains Responsibility
Advantages
• Continues established lead responsibilities
between NRC and ERA (ERA lead).
• Reduces costs and delays produced from duplicative
regulat ion.
• Avoids need for an NRC license.
• Promotes consistency in NRC and ERA remedial
deci sions.
Advantages
• Maintains NRC control of the remediation under Atomic
Energy Act.
• May result in lower risk to public and environment if
site is remediated to Option 1 or 2 levels.
• Avoids reliance on institutional controls.
Disadvantages
• Reduces assurance that NRC w i l l find the remedial
action satisfactory because ERA has not yet
selected remedial action for the uranium
contamination.
• Introduces possibility that additional remediation
may be necessary in the future.
• Places remediation outside of NRC control; no
assurance when remedial actions w i l l occur.
Disadvantages
• Increases costs and duplicative effort for regulating
agencies and Cotter Corporation.
• May delay the remediation of the non-radioactive
materials onsite.
• May produce conflicts for Cotter if NRC and ERA
approve inconsistent remedial actions.
• May require imposition of a license through order, if
Cotter objects to license and one is required.
DON CHEMICAL COMPANY
Administrative Alternatives for the
Remediation of the Midland and Bay City, Michigan, Sites
Approve Site Disposal Request Removal & Offsite Disposal
Advantages Advantages
Reduces costs and delays from duplicative
regulation.
Allows timely completion of remediation and
termination of NRC licenses for the Midland and
Bay City sites.
Could reduce public and worker risks
from near site disposal as compared to
transporting waste across country.
Promotes consistency between NRC and ERA in terms
of remediation decisions.
Maintains NRC control of the disposal of the
radioactive waste.
May reduce long-term risks if wastes were disposed
of at a licensed disposal facility for radioactive
waste that does not rely on institutional controls.
Reduces by one the number of radioactive waste
disposal sites in the country.
Disadvantages
Additional remediation under NRC control may be
necessary at the Salzburg Landfill at some point
in the future, if warranted.
Establishes precedent for disposal of radioactive
wastes in hazardous waste landfill and for
reliance on institutional controls.
Disadvantages
• Relies on limited disposal capacity for radioactive
waste.
• Increases costs for regulating agencies and Dow
Chemical.
• May delay remediation of the Midland and Bay City
sites, pending resolution of waste disposal
location.
-5-

Post

1995-09-07 – NRC – Press Release – NRC defers to EPA on regulatory oversight for cleanup of West Lake Landfill Site in Missouri

No. 95-110 FOR IMMEDIATE RELEASE
Tel. 301/415-8200 (Thursday, September 7, 1995)
Internet:OPA@NRC.GOV
NRC DEFERS TO EPA ON REGULATORY OVERSIGHT
FOR CLEANUP OF WEST LAKE LANDFILL SITE IN MISSOURI
The Nuclear Regulatory Commission has deferred to the
Environmental Protection Agency (EPA) the regulatory oversight
for cleanup of contamination at the West Lake Landfill site in
Bridgeton, Missouri. The property, which contains both hazardous
and radioactive waste, is currently being cleaned up by EPA. it
is not covered by a current NRC license.
The NRC will remove the West Lake Landfill from its Site
Decommissioning Management Plan (SDMP) list of sites that receive
special agency management attention. Accordingly, NRC plans no
further action concerning the site unless specifically asked to
do so by EPA.
Under the national Superfund program, EPA has lead
responsibility for cleanup at West Lake. EPA added the site in
1990 to its Comprehensive Environmental Response, Compensation
and Liability National Priorities List for Uncontrolled Hazardous
Waste Sites and ranked it as number 1003.
Based on the reviews to date, NRC has concluded that the
program being administered by EPA is adequate to protect the
public and the environment from the risks associated with
radioactive contamination. NRC therefore believes that its
oversight of remediation at the site, in addition to that of EPA,
would be burdensome and duplicative.
The West Lake Landfill property, owned by Laidlaw and
Rockroad, Inc., is located on the outskirts of St. Louis.
Radioactively contaminated soil from the Cotter Corporation’s
Latty Avenue site was placed in the landfill in 1973. Two areas
on the site have a layer of radioactively contaminated soil,
mostly covered with 3 to 20 feet of other waste. The
contamination originated with residues from extraction of uranium
and radium from very rich uranium ores for the former Atomic
Energy Commission.
#
2

Post

1988-10-25 – MDNR – West Lake Landfill – Letter to EPA requesting determination of Hazard Ranking Score

_. vfv . < • • » . . . • . ,,;;, • . i. i .• /: tfd JOHNASHCROFT \y(li*Ir>
DuiMcin ol I mironnu-m.il Otulii
UIVIMOM ,,| („…,!,w jnj |J1Klsi,n
FREDERICK A. BRL’NNKR “”X” “”VM-m ,» M.in^-tm-m x-rvuvi)
irix.t,,r STATI: (>i MI>S(>riu nm>i,,n ,,f |.arkv R^…^,,,,.
DEPARTMENT OF NATURAL RESOURCES “” “1N”W”””Jllim
Di\’isioN OF I:NVIRONMI;NTAL gi’Ai.nv
I’.O. Box 176
Jefferson City. MOdSI()2
October 25, 1988
Mr. David Wagoner, Director
Waste Management Division
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
Dear Mr. Wagoner:
The U.S. Nuclear Regulatory Conmission (NRC) staff recently released
a report (NUREG-1308, June, 1988) on the radioactive wastes at the
Westlake Landfill in St. Louis County, Missouri.
In the report the NRC staff concludes that “(1) measures must be
taken to establish adequate permanent control of the radioactive
waste and to mitigate the potential long term impacts from its
existing storage conditions and (2) the information developed is
inadequate for a determination of several important issues, i.e.,
whether mixed wastes are involved, and whether on-site disposal is
practical technologically, and, if so, under what alternative
methods.” However, the report does not indicate whether the NRC will
take any further action at the site and informal communication with
the NRC staff indicates that NRC does not intend to take further
action.
The suggestion has been made by a number of state and local officials
and citizen’s groups that the U.S. Department of Energy should
undertake action at the site under the Formerly Utilized Sites
Remedial Action Program (FUSRAP). However, a letter from DOE was
received by the Missouri Department of Natural Resources on
October 30, 1987 which states that [‘the DOE has reviewed the
possibility of the Westlake Landfill being designated as a FUSRAP
site and has concluded, based on the criteria used to designate
FUSRAP sites, that the Westlake Landfill is not eligible for
consideration as a FUSRAP site. The radioactive waste was under
Nuclear Regulatory Commission license when it was brought to the
landfill and, consistent with current DOE policy, would not be
disposed of at a DOE site.”
Mr. David Wagoner
October 25, 1988
Page 2
Since no further activity is planned at the site by either the NRC or
the DOE, I request that the U.S. Environmental Protection Agency
(EPA) determine the Hazard Ranking Score (HRS) for this site and, if
appropriate, place the site on the National Priorities List (NPL).
This ranking should be conducted using all currently available
information on the site. Further, I request that EPA initiate the
Superfund process to determine potentially responsible parties and,
if necessary, initiate enforcement action to begin an appropriate
remedial action.
The Missouri Department of Natural Resources believes that the
current uncontrolled condition of the radioactive waste at the
Westlake Landfill is unacceptable and we are interested in expediting
action at this site. Please contact me if you have any questions
regarding MDNR’s position on this matter.
Sincerely,
DIVISION OF ENVIRONMENTAL QUALITY
William C. Ford/Director
WCF/dbc
cc: Mr. Jim Fiore, DOE
Mr. Germain LaRoche, NRC

Post

1980-10-02 – MDNR – West Lake Landfill – Memorandum – History of Operations

MEMORANDUM
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Date: October 2, 1980
Jo: Bob Schreiber
From: Burt McCullough
Subject: Westlake Landfill
Westlake Landfill, located in Bridgeton Missouri (St. Louis County) has been
the subject of recent inquiry. This landfill began operation prior to state
regulation. As far as our records show, this landfill first opened in the
mid-1960’s. Part of the landfill lies in an old quarry and part of the landfill
lies in the Missouri River floodplain, approximately 1^ miles from the
river. Witnesses to this operation, when the area of the landfill which lies
in the floodplain was in operation, note that the fill area was often actually
beneath the level of the water table. According to file materials from
Missouri Geological Survey, it is “highly probable that leachate from the
landfill is entering the waters of the Missouri River. . . ” Leachate from
the old quarry area of the landfill is collected and hauled to MSB treatment
plants. Construction of onsite treatment facilities is underway. About 48,000
gallons of leachate per day is currently being collected.
Aside from normal landfill materials, there are chemical industrial wastes and
radiologically contaminated materials deposited in this landfill. The chemical
wastes, that we know of, include about 4,000 tons of residues from the production
of insecticides and herbicides. These pesticide wastes were deposited by
Chevron Chemical Company. Also included in the chemical wastes are waste
materials from ink manufacture and from the manufacture of glue. Among the
chemical wastes that we know of in Westlake Landfill are:
waste ink pigments
esters alcohols
halogenated intermediates
oils wastewater sludges
heavy metals asbestos
oily sludges
insecticides
aromatics
herbidices
Joseph
Fred A
Besides chemical hazardous wastes, in Westlake Landfill, there are radioactive
wastes. During early 1973 Cotter Corporation buried radioactive Barium
Sulfate Slag material and radiologically contaminated building rubble. There
are approximately 9,000 tons of this material which contain about 7,000″tons
of natural Uranium. In October, 1977, an aerial radiological survey was done to
determine the location of the burial of this contaminated material. The report
from this survey indicates that there are two burial sites. One is in the
center of the old quarry area, and the other is on the edge of the floodplain
area which borders adjacent farmland. The U.S Nuclear Regulatory Commission
has contracted Radiation Management Corporation to do extensive on-site
radiological surveys which include groundwater analysis, core sampling, test
boring, and other tests as deemed necessary. The NRC has given DNR verbal
P. Teasdale Governor Division of Environmental Quality
Lafser Director Robert J. Schreiber Jr., P.E. Director
Westlake Landfill continued
Page 2
October 2, 1980
To: Bob Schreiber
permission to utilize the monitoring wells which Radiation Management
Corporation will be digging, in order that DNR may test for the presence of
chemical hazardous wastes.
There is little known about what went into Westlake Landfill prior to State
regulation. Analysis needs to be done to determine: 1) what wastes are
deposited in Westlake Landfill, 2) if any of these pollutants are leaving
the landfill via groundwater, and 3) what threat does Westlake Landfill pose
to drinking water supplies.
cc: Fred Lafser
Ron Kucera
Jim Long
Robert Robinson
Bob Miller
Tom Doan

Post

1979-12-31 – MDNR – Letter to DOE – Request for report on aerial survey of West Lake Landfill

———…. –.—————–· –
·~.I~
1~- 1 .
December 31, 1979
Mr. Earl Harbison
Department of Energy
0Jk Ridge, Tennessee 378JO
Dear Mr. Harbison:
//
‘ ‘
Please find attached my letter of respomc to the c:ty of Brid~etr.n
regarding their resolution relative to the disposJl of radi( .. :tivE
waste materials in the vicinity of the city. Mr. Rick koberts, \’1itl1
the Department of Natural Re:.::>urces, Sol id ‘..laste Mariag~ment Progrc::m,
1s been in telephone corm1unication with you during recent months
requesting that your office provide us \’.’ith the res1:lt-. of the
technical study which was conducted to determine the lJcation ana
levels of radiation er.iitting from the \’1a;te dispo~ec! of at tre
l·lestlake Land4’ill in St. Louis County. This aeriill su,…vey of th·:
Westlake Landfill and other areas in the St. Louis Cou1t; was corducted
at least a year ago. The Department of llJtur·al R~scurces
\’1ould appreciate this information being made availatile in order that:.
we can assess the potential public health effect~.
If there are reasons why the study cannot be rele~sed to the
Department of Natural Resources, I 111ould appreciute te1nc; so acvisei_;.
Sincerely,
James P. Odendahl
Director
Division of Environmental Quality
JPO/RMR/jc
Encl.
JostZph P. Tea~dalcr Gov

Post

1979-11-08 – Senator Dirck – Letter to MDNR – Missouri’s role in cleaning up radioactive waste at West Lake

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Jli:tl”t:Hs0:-1 CITY
Eow1N L. DrRca.:
llNATOll, 1,T … DllTlllCT’
CA,.ITOL :JUILDINO
JU”ll’llON CITY. MISSOUlll 111101
TILl,.HONI I J 14 I 711.z … 0
November 8. 1979 1014t· •r. •··.
a;. J..N,_.._ …. i.. ‘:io’J’-
TIL.IP’H .:JN’. I JI.a .
Mr. James Odendahl, Director
Division of Environmental Quality
P. 0. Box 1368
2010 Missour _ Boulev.L:·d
Jefferson City, Missouri 65101
Dear Mr. Odendahl:
Attached please find a copy of a l~tter and re~~·
lution that I received from Mayor Bill Abram o[
the City of Bridgeton, St. Louis County. Although
I realize the Nuclear Regulatory ~orrunission has
responsibility for disposal of radjoactive waste
materials, I would appreciate your responding to
Mayor Abram and advising with regard to Missouri’s
role, if any, i~ this area.
Thanks for yo~r help.
Sincerely,
(~u/.AJ~
Edwin L. flirck
CLO: ls
Enclosures (2)

Post

1979-12-28 – MDNR – West Lake Landfill – Letter to City of Bridgeton – Response to Resolution R-79-12

•.
‘ i :_ J Q.t · ,.
1—-+——jl
~ © ‘—–:- ~,.,.,-,,_…,-.
December 28, 1979
llonorable E. 1-1. (Bill) Abram
MJyor
City of nrid9eton
11955 Natural Bridge Road
Oriugeton, Missouri 6304~
Dear Mayor Al~ram:
S1~nator Edw;r, L. 01rck ha:.. fort.·arded tl1e City of nridg~ton’s Resolution
R-79-12 reliltive to dispo~.Jl of radioacti\’e milterial tc the Depa!”trnent
of ~latural Resources for re~ponse relativE· to Mi~souri’s role in control rr;
tlte disposal of radioactive wilste rnrlterials.
You are probc.bly aware thilt the Federa~ riuclear Regulatory Corm1ission fia’..
tile primary responsibility for controllinu the disposal of radioactive
w~ste materiols. The Sta:c of Missouri is not an agree1.1ent state and
h1s no arrdn~_·ement” with the :luclear Regulatory Comrnis~ion to enforce ‘:.hr!
r~ ~·ithin d.e St.1tc of t1i>souri. At the pres·:?nt tir.ie the Solid
·,J1~te Regulations of the f>cpurtnient of ildtural Resources prohit:it the
accrptance of radioactive ~d~te materials at per~it:ed sanitary lan~fil~ ..
The,.cforl’, the l·lestlake L.111dill in St. Louis County does nut lia·,ie autho
izJt.ion to accept radioac:i·.-c 1·1ast.e rnat.er~als. Tt1e DEpartment of ~at~.ir..i,
;t~~ourccs is interested in 1:hat radioac:t ive 1~aste mat!Jials r.ia1 hdve be1:;
di~.pc:;ec1 of ;.t the Wc~tla’:f’. Landfill iri tt1e past un1 hds been in corn11niC.
l’:.’on .,Jith the Oepartmen~ of Lnergy in 1).lkridge, T·~nn~c;see reciue:;tin~1
t 1tlt the; pr11vide us ~1ith 11i1Jt inf0rr:1a:.ion t~ey i1,1vr: ctitainc:d rel.1t~vc : 1
tw disp0·.3J of the v1aste i1l tl1e .Jec;tL•~’? L.:indfill. ~·r. Earl Harl 1 iscn
1·1ith the (Je~ .. ~·tment of En-~rt:Jy llas assured us he vii 11 ~rovide u~. w1 th d r ·
•)f ~lie inves·.iuation rc;:>0″~ .~s soon clS it is availa111c.
lt l1us Geen ;ndicated triat .’l’ry lo.” lr.-t l rudioacli 11c t1u::.te n.dter·iai w.1·
in·1olved in ·:he disposal H the ~.Jcstlal:f Landfiil, anc there sho•1ld her:·
·jJrl’Jer to th .. citizens of i;r·id·.1et•Jr .. 111· .. 1,!vcr, t~w :>c~.irtrnent of rla 0.:.Jr2l
~e··,uurces via:rts to 1·evicH :1l Ll.!cr1nii:ai J.Jli: fro:? t:1t r1l:parl1;1e11t of ::1r.
in·1·~stigaticr1 ar:d stuJy Li:·’.:· t: 1.akir.·J .11 -1 rf’c01m1~!rl(~.1t .inc; as to 1·1lia·. 1 .. ·
>11·1uld be tai.en.
Joseph P. Teasdale Gov;;-rnor
furd A. Lafser Director
Divi’.ii0n ot Enviror~m . , , !al (luclPy.
James P. Odendonl u1rictor

Post

1976-06-02 – MDNR – West Lake Landfill – Letter from Director Karch to NRC after Post-Dispatch Series

CHtKTOPHE* S BOND A /\ JAMES I WIISON
COVEKNOI K (l) DIRECTOR
missouri department of natural resources
P.O. »•« 1368 J.«l.f.»n City. Mifiowfi 65101 314/751-2815
June 2, 1976
Mr. James G. Keppler
Regional Director
U.S. Nuclear Regulatory Commission
799 Roosevelt Road
Glen Ellyn, IL 60137
Dear Mr. Keppler:
In articles published May 30 and June 1 (copies enclosed) St. Louis
Post-Dispatch reporter Margaret W. Freivogel presented evidence that
some seven tons of uranium were dumped in 1973 at the West Lake Landfill
in St. Louis County by an Atomic Energy Corjnission subcontractor
removing radioactive waste material fror. a site in Hazelwood, Missouri,
The area was closed as an industrial and sanitary landfill by this
Department in 1974 (a new sanitary landfill in an adjacent area protected
from groundwater contact now operates under DNR permit). The
closed area where the dumping allegedly occurred may be in direct
contact with groundwater. It has no monitoring wells to permit
evaluation of groundwater contamination.
In your letter to me of February 19, 1976 you stated that “a review by
the then AEC showed there was no significant health or environmental
hazard associated with the burial”. The letter to Cotter Corporation
from John G. Davis you enclosed stated, “It is our understanding from
your contractor that the material was then deposited under about
100 feet of refuse and earth at St. Louis County sanitary landfill
No. 1.” The investigation by the Post-Dispatch indicates that AEC_did
not know the correct location of the dumping, the local geology, nor
the actual concentration of uranium dumped. The depth cited must
also be incorrect since no landfills in the St. Louis area contain
100 feet of fill. I must therefore question the validity of the AEC
“review” of the burial operation.
I respectfully request that in view of the concerns of this Department
and the people of the St. Louis area, that the Nuclear Regulatory
Commission takes steps to:
1. Provide me with all documents which might assist me in verifying
the Post-Dispatch report, and in establishing the exact amount
and chemical form of radioactive materials allegedly dumped at
Vest Lake.
Exhibit A
1 of 4
Mr. Kcpplcr
Page 2
June 2, 1976
2. Require the Energy Research and Development Administration,
as successor to AEC’s source material operations, to
a) Include the West Lake Landfill in the areas it has selected
for intensive aerial and ground level radiation monitoring.
b) Locate the uranium precisely within the landfill, both as
to position and depth.
c) Install appropriate groundwater monitoring wells and implement
a monitoring program to determine the extent, if any, of
groundwater contamination.
d) Recommend actions to be taken to protect landfill workers
and the public from any potential hazards associated with
this material.
3. a) Advise •£ on who would be liable in the event that cleanup
costs are involved.
b) Ascertain whether federal laws or regulations were violated
by either the Atomic Energy Commission or its subcontractor
in the disposal of source material at an unlicensed site.
In a related matter, I was disappointed to learn that you do not maintain
records of radioactive waste burials carried out by licensees under
authority of Section 20.304 of Title 10 CFR. I hereby respectfully
request that your office obtain such records from all Missouri licensees
who have made such burials and make these records available to me.
Kenneth M.
Director
Division of Environmental Quality
KMK:JE:jhb
cc: Robert J. Koke, EPA Region VII
Enclosure
Exhibit A
2 of k

Post

2011-12-29 – NATIONAL REMEDY REVIEW BOARD Questions and Answers for Superfund Site Managers

..
{In Archive} State attendance at a NRRB Westlake “meeting”? ~~~ Craig Smith to: Dan Gravatt, Amy Legare 02/03/2012 01:12PM Cc: Cecilia Tapia
History: This message has been forwarded.
Archive: This message is being viewed in an archive.
Dan-In a normal pre-RoD NRRB meeting, the state (and Tribes) is/are invited to send in a thorough comment letter and to address the board and answer questions in person during the presentation half of a day long site meeting. The afternoon “deliberations” are EPA only, so the stat~ and others are excluded from those discussions. Excerpt from the Board process Qs&As (manual attached below):
“21. How do states and tribal governments participate in the reviews? For each site, the site manager should invite state and appropriate tribal representati-ves to participate in the information-gathering phase ofthe Board meeting. Typical~v. these representatives do not participate in the deliberative discussion, which the Board normally limits to EPA personnel; holvever, they may be invited to participate for a portion oftlze deliberations vl’lzere the site is a state/tribe-lead fund-financed decision or state/tribe-lead enforcement decision ·where the state or tribe seeks EPA concurrence. Otlzenvise, the Board general~y limits its deliberative discussion to Agency personnel. Regional staffshould contact the state or tribal representative early in planning for the Board meeting to discuss the background and pwpose ofthe Board, the structure ofthe reviews, and to explain how the state/tribe might best prepare for the meeting. The site manager may also provide the Community Guide (Appendix E) to these representativesforfurther information. At the meeting, the state/tribe is usually offered approximate~v 10-15 minutes to speak about their spec{(ic issues or concerns. The region should also offer the state or tribal representatives an opportunity to summarize in writing, 20 pages or less****, any technical issues they believe are pertinent to the cleanup decision, including their rationale and recommended approach for site cleanup. The site manager should attach this summmy to the site il!formation package submitted to the Board four l·veeks before the meeting. Stakeholder position papers should be included in the administrative record. ****Up to 40 pages may be submittedfor sites where the estimated remedial action costs exceed $100M”
However this is a RoD amendment, focused webinar rather than a full pre-RoD review meeting and it comes at the request of Mr. Wolford et al; so different criteria and streamlined procedures may apply. Since Cecilia and Amy have been involved directly in the HQ discussions, let’s ask of them for direction via copies of this e-mail.
Amy and Cecilia-pis advise.
Thanks all, Craig
~::.: ‘]
Finai.RPM.NRRB.Manual.12.29.11.docx
Craig W. Smith, P.E. Senior Engineer and Policy Coordinator Superfund Division 011Y J.o
40450148

llllllllllllllllllllllllllllllllllllllllllllllllll
Superfund
DUD\

USEPA Region 7 Kansas City
(913) 551-7683
Dan Gravatt Craig, I got a call from MDNR asking whether (in … 02/03/2012 10:37:12 AM
From: Dan Gravatt!R7/USEPA/US To: Craig Smith/SUPR/R7/USEPA/US@EPA Cc: Cecilia Tapia/R7/USEPA/US@EPA Date: 02/03/2012 10:37 AM Subject: State attendance at a NRRB meeting?
Craig, I got a call from MDNR asking whether (in principle) they would be able to attend the NRRB meeting. While they said they were just asking for information at this point, and not actually asking to attend, Shawn said that MDNR folks attended the past NRRB meetings for the St. Louis FUSRAP sites. See the link they provide below for more information.
Can they actually attend? It was my understanding that the State couldn’t directly participate by attending, but I defer to your more extensive knowledge of the process.
Thanks, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063
Principles and integrity are expensive, but they are among the very few things worth having.
—–Forwarded by Dan Gravatt!R7/USEPA/US on 02/03/2012 10:34AM —-.To: Dan Gravatt!R7/USEPA/US.@EPA From: “Muenks, Shawn” Date: 02/03/2012 10:14AM Subject: FW: NRRB
Shawn Muenks, P.E.
Missouri Department of Natural Resources
P.O. Box 176, Jefferson City, MO 65102-0176
Ph: (573)751-3107
email: shawn.muenks@dnr.mo.gov
From: Doster, Branden
Sent: Tuesday, January 31, 2012 2:28 PM
To: Muenks, Shawn
Subject: NRRB

http://www.epa.gov/superfund/programs/nrrb/index.htm
Branden B. Doster Chief-Remediation and Radiological Assessment Unit Federal Facilities Section Missouri Department of Natural Resources
(573) 526-2739

NATIONAL REMEDY REVIEW BOARD

Questions and Answers for
Superfund Site Managers

December 29, 2011
NRRB-Questions and Answers for Superfund Site Managers
1. What is the National Remedy Review Board?
In October 1995, the EPA Administrator announced a collection ofinitiatives designed to help control remedy costs and to promote consistent and cost-effective Superfund cleanup decisions. As one of these initiatives, the National Remedy Review Board (NRRB, the Board) reviews proposed high-cost cleanup decisions to help evaluate whether they are consistent with current Jaw, regulations, and Agency policy and guidance.
The Board is a technical and policy review group made up of members that have experience with both regional and Headquarters perspectives in the Superfund remedy selection process. Its members include senior managers and technical experts from each EPA region, as well as senior technical and policy experts from other EPA offices. These include the Office of Superfund Remediation and Technology Innovation (OSRTI), Office of Research and Development, Office of Radiation and Indoor Air, Federal Facilities Restoration and Reuse Office (FFRRO), Office of Site Remediation Enforcement, and Office of General Counsel. The Board is chaired by OSRTI. The Board generally meets quarterly to review proposed decisions that meet its cost-based review criteria. The product of the review is a memorandum sent from the Board to the regional Superfund division director that documents Board recommendations about the proposed cleanup strategy. The Board review process allows full input from EPA regional site managers and other site team members as deemed appropriate by the region whose site is under review. EPA’s site managers are asked to participate in all deliberations to ensure that the Board fully understands the circumstances influencing their proposals.
2. Which sites will the Board review?
Typically, the Board reviews cleanup strategies after the remedial investigation/feasibility study (RVFS) and before the region releases the proposed plan for comment. If necessary, the Board may review sites at other phases of cleanup, possibly before the FS is completed. The Board tries to accommodate regional preferences for scheduling reviews; however, it may not be able to meet all desired regional schedules. It is therefore imperative that site managers work closely with their Board representatives and regional management to schedule sites for review as soon as cost estimates trigger the review criteria outlined below.
Both National Priorities List (NPL) and non-NPL (e.g., “Superfund Alternative”) site actions are reviewed by the Board whenever the Agency expects the work to be done under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA), in accordance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and other relevant guidance, and when the general criteria below are met. The Board reviews sites when EPA is directly responsible for the decision or has a concurrence role, including PRP.Jead, special account-funded and federal facility-lead sites.
NRRB-Questions and Answers for Superfund Site Managers
Board Review Criteria
The Board will typically review proposed interim and final Superfund response decisions at both NPL and non-NPL (including Superfund Alternative) sites for which the proposed:

Remedial action costs more than $25 million; or


Non-time critical removal actions (NTCRA), at sites other than a federal facility, is estimated to cost more than $25 million; or

Board reviews will also occur for NPL and non-NPL sites following changes made after the release ofthe proposed plan:

A different or modified alternative (which was included in the original proposed plan) is selected by the region that costs more than 20 percent when compared to the original proposal and these costs trigger review criteria (even when the earlier proposed action had undergone Board review).


A new alternative is developed and the costs ofthe new alternative would trigger a revtew.

The Board may review (at regional discretion) sites where the proposed action’s original cost estimate increases more than 20 percent after issuance of the Proposed Plan due to either updated cost information or minor changes to the alternative that trigger review criteria. Examples of minor changes are presented in Chapter 7 ofA Guide to Preparing Superfund Proposed Plans, Records o.fDecision, and Other Remedy Selection Decision Documents, Office ofSolid Waste and Emergency Response Directive No. 9200.1-23P, July 1999 (ROD guidance).
Federal Facility Sites (other than the Department ofEnergy)
Federal facility sites (including Formerly Utilized Sites Remedial Action Program-FUSRAP) follow the same review criteria above with the exception ofNTCRAs; federal facility NTCRAs do not undergo Board review unless requested by the federal facility. Decisions at Base Realignment and Closure (BRAC) sites do not undergo Board review.
Department ofEnergy Sites
The NRRB typically will review sites where the primary contaminant is radioactive waste and the proposed remedial action costs more than $75 million. The Board will also review NPL sites with NTCRAs exceeding $30 million involving primarily radioactive waste; (per joint
NRRB-Questions and Answers for Superfund Site Managers
Department of Energy/EPA memorandum dated October 5, 1998).
3. Can Regions Request an optional early consultation?
Regions may request an optional NRRB consultation on remedial alternatives at the draft FS scoping stage or any time prior to the draft proposed plan. Regions will not be expected to respond to this early review. Regions should notify states, tribes, local governments, PRPs and local communities when a site will be the subject of an early consultation. Stakeholder, including PRPs, input (up to 10 pages) should be requested as part ofthe early consultation process. This optional consultation will not excuse a site from NRRB review at the proposed plan stage if the proposed remedial action meets the NRRB review criteria.
4. Can Regions Request an exemption from Board review?
Regions may request that the NRRB Chair exempt their eligible site from Board review. In addition, Regions can request an exemption in cases where the Region selects a different alternative (after the release ofthe Proposed Plan for public comment) which costs more than 20 percent from the original proposal and these costs trigger review. The OSRTI office director will make the final exemption decision. The Regional Division Directors can appeal a decision to deny an exemption to the OSRTI Office Director. Regions should offer states, tribes, local governments, PRPs and local communities an opportunity to summarize in writing their opinion regarding the proposed exemption decision. This information will be forwarded to the Board chair along with the exemption request. Regions will not be expected to respond to these letters but will notify the commenters of the final decision regarding an exemption.
NRRB Exemption Request Process and Criteria
The region requesting an exemption from an NRRB review should provide a summary ofthe following information to the Board chair. Exemption requests should not exceed I 0 pages.
I. Site name
2.
Media to be addressed, primary contaminants ofconcern, preliminary remediation goals

3.
Scope and role of the operable unit or response action

a. Does this action hinge on previous actions?

4.
Risk summary

5.
Remedial action objectives

6.
Alternatives-do they address

a.
TI or MNA?

b.
Treatment of principal threat waste?

NRRB -Questions and Answers for Superfund Site Managers
c.
Presumptive remedy?

d.
Addressing munitions? (no chemical COCs or groundwater)

7.
Tribal or state ARARs

8.
Stakeholder views

a. Congressional or community controversy?

9.
Decisions requiring headquarters coordination or consultation

a.
Non-time critical removal actions over$ 6M

b.
Remedies for lead, radionuclides, PCBs, asbestos, mercury and dioxin

10.
Concurrence ofregional division director on exemption request

After receipt ofthe exemption request, the Board chair will hold a conference call with the region to discuss the request. The Board chair will forward the exemption request and recommendation to the OSRTI office director. If the site is a federal facility the FFRRO Board member and office director will participate in the exemption process.
The region should seek input from site stakeholders (e.g., PRPs, states, tribes, and communities) on the request for exemption from NRRB review. Stakeholders may submit up to 10 pages stating their specific issues or concerns. Submissions may be sent to the region or Board Chair at the following address:
Amy Legare
National Remedy Review Board
US EPA
1200 Pennsylvania Ave., NW MC5204P
Washington, DC 20460

Or
Legare.amy@epa.gov
The OSRTI office director will make the final exemption dec~sion after consultation with the
regional division director and consideration ofstakeholder input.

5. Will the Board review sites with Record of Decision amendments or Explanation of
Significant Differences?

Generally, the Board reviews proposed Record of Decision (ROD) amendments where there is a . change from the original remedial strategy (e.g., moving from a containment remedy to a treatment remedy) that results in remedial action costs greater than $25 million.
NRRB -Questions and Answers for Superfund Site Managers
Generally, the Board does not review ROD amendments where the:

Original remedial strategy remains the same (e.g., where the cost increase results from an unexpected increase in contaminated soil volume), even ifthere is an appreciable change in cost (however, the region should consult with their board representative to confinn review criteria) or


Amendment results in a cost savings .

The Board usually does not review Explanation of Significant Differences unless the region believes the site would benefit from such a review.
6. Will the Board review sites with fmal ~ecord of Decision following an interim Record of Decision?
Generally, the Board will review final RODs that follow an interim ROD where there are new significant capital costs in addition to the incremental operation and maintenance (O&M) costs associated with the final ROD. When the costs of aplanned final ROD (following an interim ROD) exceed the trigger criteria due to costs driven primarily by the interim remedy’s O&M (e.g., the plant is already constructed and the remaining costs are due to long term system operation), the site does not require Board review. In lieu of a Board review, the region should conduct an optimization review, consistent with EPA guidance, before the final remedy is selected. Information on remedy optimization may be found at this linlc http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm
7. Will the Board review proposed sediment actions that are also subject to Headquarters consultation or Contaminated Sediments Technical Advisory Group review under Office of Solid Waste and Emergency Response Directive 9285.6-08, Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites?
Yes. As explained in the Office of Solid Waste and Emergency Response (OSWER) Directive 9285.6-11, OSRTI Sediment Team and NRRB Coordination at Large Sediment Sites, issued on March 5, 2004, review of consultation memos by the OSRTI Sediment Team (for Tier 1 sites) and by the Contaminated Sediment Technical Advisory Group (CST A G) will be coordinated with the Board so that the region receives only one set of comments at the time ofthe proposed plan. This process is explained in more detail below.
Tier 1 Sites
For Tier 1 sites that will undergo a NRRB review, the region should include a draft Tier 1
NRRB -Questions and Answers for Superfund Site Managers
Consideration Memo in the site information package sent to the Board. A copy ofthe Consideration Memo should also be sent to the appropriate OSRTI regional coordinator and to the OSRTI Sediment Team leader. The OSRTI Sediment Team will review the Consideration Memo and the site package, and will provide comments to the chair of the NRRB prior to the Board’s meeting on the site in question. If the draft Proposed Plan is available, it should also be submitted to the OSRTI regional coordinator and the Sediment Team Leader at that time. If it is not available, it should be submitted as soon as it is drafted. The Sediment Team will not submit separate comments on the Consideration Memo to the region.
As part of its response to the NRRB recommendations, the region should include a revised Tier 1 Consideration Memo that addresses any comments made by the NRRB related to the issues covered by the Memo. If the NRRB chair and OSRTI Sediment Team leader believe that their comments were not appropriately addressed, and after consultation with the OSRTI Regional Branch Chief, the region may be asked to make additional revisions to the Consideration Memo.
Contaminated Sediments Technical Advisory Group Sites
It is anticipated that the proposed remedy for most ofthe large sites being reviewed by the Contaminated Sediment Technical Advisory Group (CSTAG) will also meet the NRRB review requirements. Therefore, a subset ofCSTAG members will participate in the NRRB review. This subset will be selected based on expertise matching the site characteristics. When a site manager prepares the site package for the NRRB it should include a draft Tier 2 Consideration Memo. The memo should document how the region considered all 11 principles when selecting the site’s proposed remedy; the memo should normally be less than 20 pages in length. The site manager will be provided with one set ofrecommendations from this joint review.
8. What is the role of the Office of Superfund Remediation and Technology Innovation?
OSRTI will assign an ad hoc Board member for each review. The ad hoc member will be assigned based on the area ofexpertise required for the review. For example: risk assessment, contaminated sediments, radiation, groundwater contamination, or vapor intrusion. In addition, the technical regional coordinator will work closely with the Board chair on all aspects of the rev1ew.
OSRTI will also work to develop any needed policy, guidance or training materials deemed necessary after each annual review ofrecommendations. For additional information see Question
28.
NRRB -Questions and Answers for Superfund Site Managers
9. Will the Board review proposed remedies selected pursuant to presumptive remedy guidance?
Yes, unless the review is waived by the Board chair. Regions and regional Board members are encouraged to consult with the Board chair on presumptive remedies to ensure a productive review of the proposed remedy.
10. How long does a typical Board review take?
Generally, the review process takes about eight weeks, from the time the Board receives the infonnational site package until it transmits its recommendations to the region. Regions should consider this additional time in developing the site work plan and Superfund Comprehensive Accomplishment Plan targets. However, regions should also be aware that, in a few cases, Board recommendations may delay site decisions while the regional decision makers consider and respond to Board findings. Also, the region should allow adequate time for preparation of a comprehensive site package. The average preparation time is generally one to two months.
Board reviews are planned for the first month of each quarter of the year. Site managers should notify their regional Board member and the Board chair of the need for a review as soon as possible so the site can be added to the calendar of planned reviews. Generally one to two months time is needed to plan a review with travel, hotel, and meeting space accommodations.
11. What does the Board look at when it revie.ws a cleanup decision?
Generally, the Board analyzes proposed cleanup strategies to help ensure they are consistent with CERCLA, as amended, the NCP, and relevant EPA cleanup guidance. To assist Board members with these reviews, the region prepares a site information package for each site (see additional questions below and Attachment A for more details). Generally, the Board will not be reviewing the draft FS nor the draft decision document.
When the Board reviews a site, the members consider a variety ofinformation, including elements of the RIIFS process related to the development ofthe alternatives and selection ofthe preferred alternative. Site-specific circumstances often influence the nature of the discussion. Please refer to Appendix 0 for questions frequently asked by the Board.
12. What are the site manager’s responsibilities before the meeting?
NRRB -Questions and Answers for Superfund Site Managers
As soon as the site manager becomes aware that he/she has a site that may trigger the Board’s review criteria, the manager should notify his/her regional board member, who, in tum, should coordinate the NRRB review meeting date.
The site manager should:

Convey to the regional board member any preferences regarding review timing. The Board tries hard to accommodate the interests of the regions and site managers when scheduling reviews.


Provide the site-specific charging number to the Board chair as soon as possible once it has been determined that the site will come before the Board.


Contact the state and any appropriate tribes, Potentially Responsible Parties (PRPs), community groups, or federal facilities to notify them that the site triggers the review criteria. At this time, discuss with these stakeholders the procedures governing their involvement in the review process. A Community Guide is provided in Appendix E. Questions 16-21 of this packet provide additional information on the usual role of these parties in1the review process.


Prepare a site information package that the Board will use to conduct its review. Question 13 and Appendix A present information on the package and a recommended outline.


Finalize the informational site package at least four weeks before the meeting and provide the package to the relevant regional NRRB member for distribution to Board members in preparation for the site review. The package will be posted on the Board’s Quickr site so that Board members may download it at their convenience. Oversized charts, maps or tables should be mailed to the Board members. The mailing list is available from the Board’s Quickr site. Please note that two additional copies should be mailed to the Board chair for distribution to OSRTI participants.


Prepare a presentation that summarizes the site, proposed remedy, and major issues. See Appendix C for a suggested outline for the presentation.


Prepare for the meeting by expecting questions that probe beyond the basic information presented in the site information package (e.g., questions about important assumptions, models, peer reviews or tools used in developing key supporting information). Appendix

. D presents several lists ofquestions typically asked during the review and deliberations.


OPTIONAL: Participate in a pre-meeting conference call two weeks after the Board receives the site package (i.e., two weeks before the meeting) to give the Board an opportunity to ask clarifying questions regarding the factual information in the site information package and to possibly request more information prior to the board meeting, or as part ofthe region’s presentation at the board meeting. The pre-meeting conference call should provide feedback to the region prior to the board meeting as to whether the information provided is sufficient to support Board discussion and development of key/substantive recommendations. The Board chair and site manager will decide if a pre.call is necessary.

NRRB-Questions and Answers for Superfund Site Managers
Recognizing that the reviews generally are part ofEPA’s internal deliberative process, please label all documents “DRAFT-DELIBERATIVE.”
13. What should be in the site information package?
Appendix A contains a suggested outline for the site information package.
This informational package should be written as a “stand alone” and succinct document that
summarizes the key remedy selection issues faced at the site, and explains the regional rationale
for choosing its preferred cleanup strategy. Additional detailed documents may be made
available for review, at the region’s discretion, through Quickr or the Superfund Document Management System. The Board expects to base its review and any resulting recommendations primarily on this document. Inclusion of clear and well labeled maps, figures and tables usually are critical to the review. 1
Site managers should develop a site information package that tells the story and explains the rationale ofthe cleanup decision at the site in question. That is, the package should identify and explain the key remedy selection issues and support the preferred cleanup strategy. The exact content may vary based on site conditions. However, all packages should include summary inforn1ation such as site background, contaminants and media ofconcern, site characterization, conceptual site model, key modeling land use assumptions and uncertainties, risk analysis, basis
for action, the range ofalternatives considered, the preferred remedy, and the preferred remedy cost breakout. For example, if a chosen cleanup level is driven by Applicable or Relevant and Appropriate Requirements (ARARs), the information package should explain the ARAR, why the region believes it is applicable or relevant and appropriate, how it affects the remedy, etc. This information can help reduce or eliminate the need for exploring the subject during the review meeting. The package should contain a summary ofthe state and/or tribe position(s) on the site, and have attached any technical submissions from states/tribes, PRPs, federal facilities, Natural Resource Trustees, community groups and/or other stakeholders as appropriate. The Board expects to base its review and any resulting recommendations on this package.
The Board recommends that the site manager have the draft package reviewed by regional staff unfamiliar with the site to be sure the package is clear and consistent. Site managers should take advantage ofthe resources provided by their regional Board members and OSRTI’s remedy decisions branch; they can give advice on preparing for the review, assembling the package, characterizing key issues, and developing appropriate supporting information.
14. What happens at the meeting?
NRRB -Questions and Answers for Superfund Site Managers
For each site review, the Board meeting typically lasts one full day and is broken into two stages: information gathering and deliberations. The role of the various stakeholders is described in subsequent sections ofthis manual. The site manager should invite state and appropriate tribal representatives to participate in the informatimi-gatlzering phase. Typically, these representatives do not participate in the deliberative discussion, which the Board limits to EPA personnel.
The site manager begins the information-gathering phase with a short site briefing. Generally, the briefing should not repeat in detail material already presented in the infonnation package. Rather, it should include a brief overview ofthe site and focus on orienting the Board members to the key site features and key remedy selection issues. Following this briefing, state and/or tribal representatives may present their view ofkey technical issues. Generally, the total length of the presentations should not exceed one hour (typically EPA 45 minutes, state/tribe 15 minutes). The Board usually spends some time after these presentations asking technical or clarifying questions (refer to Appendix D for examples). The site manager should be familiar with community, state/tribe, and/or PRP technical comments, as the Board will explore these as appropriate.
Following the briefings and the question/answer session, the Board deliberates for several hours, focusing on whether the proposed cleanup decision is cost effective, technically sound, and otherwise consistent with the NCP and/or supported by the most current program guidance. The Board asks the site manager and other regional staff, as determined by the region, to attend the deliberations for follow-up questions and to ensure the site manager understands the Board’s proposed recommendations. A draft memorandum normally will be developed at the meeting, detailing any Board findings and recommendations.
Following the review meeting (typically within two to four weeks), the Board chair transmits a final draft of the recommendations to Board members and the site manager before issuing the final recommendations memorandum documenting any recommendations or comments to the· appropriate regional division director. EPA expects to post the recommendations memo on the Board’s web page within 30 days ofthe chair’s signature.
The Board considers the review to be an internal, deliberative, and (in certain cases) enforcement-sensitive process. Given the nature ofthe process, the Board defers to regional judgment with respect to releasing documents related to the reviews, and assumes that regions will comport with established relevant Agency policy. The Board expects the region to place the Board recommendations in the site administrative record at the time a proposed plan is published for comment. Regional materials used to support Board reviews (e.g., review packages, briefing materials, and stakeholder memoranda) should also be retained in the regional site-specific administrative record as appropriate.
15. What happens after the meeting?
Regional Response: Regional division directors are asked to respond in writing within a reasonable time frame to the Board chair regarding how the region has or will address board recommendations. As part of this response, the region is asked to describe how the Board’s review has impacted the cleanup process. The site manager is encouraged to submit a draft of the regional response to HQ to resolve any remaining issues prior to the issuance of the proposed plan. The site manager should work closely with the Board chair and OSRTI to incorporate the recommendations in the decision documents.
The Board’s existence does not change EPA’s remedy selection process as provided for in CERCLA and the NCP. The regions retain decision making authority as delineated in rormal delegations of authority. The Board does not “approve” or “disapprove” regional proposals. However, the Agency expects decision makers to give Board recommendations substantial weight when finalizing cleanup decisions. If issues arise regarding incorporation of recommendations into decision documents, the OSRTI office director can request a discussion with the regional division director to resolve them.
Public inquiries and release of information: The regions are expected to handle site-specific inquiries related to the reviews. It is expected that regions will place Board recommendations and regional response memoranda in the site administrative records on or before the date that the region issues proposed plans for public comment. See question 25 for further clarification.
Record keeping: In the case of board-related materials, OSRTI maintains the Agency records of pertinent Board-issued documents (e.g., the board memos, operating protocol, etc.). General information, site-specific Board memoranda, and regional responses are available at: http://www.epa.gov/superfund/programs/nrrb/index.htm. EPA regional offices are responsible for retaining all documents prepared for the presentation package either in the site file or administrative record as appropriate (e.g., the site information packages, PRP and stakeholder submissions and any other information used in the Board process related to the cleanup decision in question). This record-keeping policy is consistent with established Agency guidance.
Web page: The recommendations memo will be posted on the Board’s web page within 30 days of the chair’s signature. The Board’s web page will also provide a link to the Superfund Site Progress Profile that will provide links to decision documents and the administrative record. PRP and stakeholder position papers should be included in the administrative record.
16. What is the role of the PRP?
NRRB-Questions and Answers for Superfund Site Managers
The Board and its current process do not alter existing mechanisms for PRP involvement in the remedy selection process. The current process allows the PRP to work closely with the Agency in conducting the RIIFS, including appropriate, periodic meetings between EPA and the PRPs to ensure that issues such as site characterization, treatability of contaminated media, and the feasibility ofdifferent remedial options are fully considered.
When there is a PRP-lead RIIFS, the site manager should notify the PRPs ofthe pending review as soon as the region identifies the site as a review candidate. At this time, the region should offer the PRPs an opportunity to summarize in writing, 20 pages or less*, any technical issues they believe are pertinent to the cleanup decision, including their recommended approach and rationale for that approach. The site manager should attach the PRP’s summary to the site information package submitted to the Board four weeks before the meeting. PRP submissions should be made part of the administrative record.
The region, at its discretion, may solicit comments from PRPs who do not conduct the RIIFS. Generally, the region may do this in cases where PRPs have been substantively involved in RIIFS work and/or remedy selection issues, or if the region believes that PRPs may offer technical comments critical to understanding key remedy selection issues at the site.
Note that those groups that have not been working closely with the Agency early in the remedy selection process will still have the opportunity to comment formally on the proposed action during the proposed plan comment period.
PRPs are not involved in any direct discussions with the Board nor are they involved in Board meetings or pre-meeting calls. EPA is responsible for preparation ofthe Board’s review package.
17. Can Potentially Responsible Parties or others nominate sites for Board review?
Site managers may get calls from PRPs or other stakeholders asking whether a site can be nominated for Board review. The Board expects to review only those decisions that meet the review criteria.
18. What is the role of federal facilities?
Consistent with policy established by EPA’s FFRRO, the Board generally treats federal facilities as PRPs for the purpose of Board reviews.
* PRPs may submit up to 40 pages for sites where the estimated remedial action costs exceed $1OOM.
NRRB-Questions ancl Answers for Superfund Site Managers
Please refer to “Which sites will the Board review?” for federal facility review criteria.
19. What is the role ofthe community?
The Board process does not alter existing mechanisms for community involvement in the remedy selection process. The current community engagement process allows the community to work closely with the Agency in conducting the RIIFS, including appropriate, periodic meetings between EPA and the community to ensure that issues such as site characterization, treatability of contaminated media, and the feasibility of different remedial options are fully considered. The site manager may provide the NRRB Community Guide (Appendix E) to interested stakeholders.
At sites where EPA has awarded a Technical Assistance Grant (TAG) or recognized a Community Advisory Group (CAG), the site manager should notify them of the pending review as soon as the region identifies the site as a review candidate. At this time, the region should offer the TAG/CAG groups an opportunity to summarize in writing, 20 pages or less**, any technical issues they believe are pertinent to the cleanup decision, including their recommended approach and rationale for that approach. The site manager should attach this summary to the site information package submitted to the Board four weeks before the meeting. Stakeholder position papers should be included in the administrative record.
Where the site manager has established close working relationships with other stakeholder groups early in the RIIFS process, the site manager may offer these groups the opportunity to submit written technical comment at his/her discretion.
Note that those groups that have not been working closely with the Agency early in the remedy selection process will still have the opportunity to comment fonnally on the proposed action during the proposed plan comment period.
Co”mmunity members and TAG technical advisors are not involved in any direct discussions with the Board nor are they involved in Board meetings or pre-meeting calls.
20. Are Board discussions open to the general public?
No. The meetings of the Board are pre-decisional, deliberative discussions and are not open to the general public. Reviews generally occur before the region issues the proposed plan. The Agency is generally at an early stage in its decision making process when the Board meets to discuss the proposed action. The intent of this early Board review is to offer a critical discussion
** Stakeholders may submit up to 40 pages for sites where the estimated remedial action costs exceed $1OOM.
NRRB-Questions and Answers for Superfund Site Managers
on key remedy selection and cost effectiveness issues before the Agency formalizes its position on a preferred cleanup strategy. It is important to note that the Board process does not affect EPA’s current procedures for soliciting public comment on proposed cleanup plans.
The recommendations memo will be posted on the Board’s web page within 30 days of the chair’s signature. The Board’s web page will also provide a link to the Superfund Site Progress Profile that will provide links to decision documents and the administrative record. PRP and stakeholder position papers should be included in the administrative record.
21. How do states and tribal governments participate in the reviews?
For each site, the site manager should invite state and appropriate tribal representatives to participate in the information-gathering phase of the Board meeting. Typically, these representatives do not participate in the deliberative discussion, which the Board normally limits to EPA personnel; however, they may be invited to participate for a portion ofthe deliberations where the site is a state/tribe-lead fund-financed decision or state/tribe-lead enforcement decision where the state or tribe seeks EPA concurrence. Otherwise, the Board generally limits its deliberative discussion to Agency personnel.
Regional staff should contact the state or tribal representative early in planning for the Board meeting to discuss the background and purpose of the Board, the structure of the reviews, and to explain how the state/tribe might best prepare for the meeting. The site manager may also provide the Community Guide {Appendix E) to these representatives for further information. At the meeting, the state/tribe is usually offered approximately 10-15 minutes to speak about their specific issues or concerns.
The region should also offer the state or tribal representatives an opportunity to summarize in writing, 20 pages or less***, any technical issues they believe are pertinent to the cleanup decision, including their rationale and recommended approach for site cleanup. The site manager should attach this summary to the site information package submitted to the Board four weeks before the meeting. Stakeholder position papers should be included in the administrative record.
22. What is the role of contractors?
Generally, government contractors can help prepare presentation and package materials but do not participate in presentations or question and answer sessions at board meetings.
*** Up to 40 pages may be submitted for sites where the estimated remedial action costs exceed $1OOM.
NRRB-Questions and Answers for Superfund Site Managers
23. Does the region convey the Agency’s preliminary views on the remedy in question (i.e., for stakeholders to react to)?
Generally, stakeholders have an opportunity to contribute their views on remedy selection issues, consistent with the NCP and Agency guidance. Site managers should not provide stakeholders with any preliminary indication of Agency preferences beyond that which the Agency would provide in the absence of the Board’s review.
24. When is it appropriate for Natural Resource Trustee agencies or the Agency for Toxic Substances and Disease Registry to participate in board reviews?
When a Natural Resource Trustee agency or the Agency for Toxic Substances and Disease Registry have formally provided unique or specialized site-specific technical or analytical support for the RIIFS in lieu of (or to supplement) regional expertise in a particular area, the region may invite representative(s) to attend the information-gathering phase ofthe review meeting but must infonn the Board chair ofthis invitation.
25. When is it appropriate to release Board memoranda and meeting support materials?
The Agency considers the site-specific Board discussion materials, site names, and operable units under consideration to be deliberative and, where appropriate, enforcement confidential. EPA staff should refer questions regarding the nature of the Board discussions and findings to the appropriate regional board member or site manager.
The product of a Board review is typically a memorandum from the Board chair to the appropriate regional division director. While the Agency strives to be as open as possible about Board reviews, in some cases it may be appropriate for the region to withhold the Board’s recommendations memorandum until the region issues the proposed plan. At that point, the region should place the memorandum in the appropriate site administrative record. The region may release publicly its response to Board recommendations at its discretion, taking into account the internal, deliberative nature ofthe NRRB process. EPA will post the recommendations memo to the Board’s web page within 30 days ofthe chair’s signature. EPA expects that regions will make the regional response available publicly as soon as it is reasonable and appropriate to do so. EPA will also post the regional response on the Board’s web page.
In addition, the NRRB web page will provide the internet link to the Superfund Site Progress Profile that links to the site decision documents and administrative records containing stakeholder and PRP position papers.
NRRB-Questions and Answers for Superfund Site Managers
26. Where can I find information about other Board reviews?
Site managers are encouraged to visit the NRRB internet site at http://www.epa.gov/superfund/programs/nrrb/index.htm. This publicly accessible site contains basic information about the NRRB and its fonnation, criteria that triggers NRRB review, contact information for Board members, site-specific review memoranda, and regional responses to Board recommendations. Site-specific review memoranda may also be found in the site administrative record.
27. How are Board members selected?
HQ Offices and Regions will be requested every two years to re-evaluate their representatives on the NRRB to confirm that the members have the needed expertise, experience, and time to actively participate and contribute. The chair will request this reevaluation. The qualifications for NRRB board members are:

Senior Agency managers


Senior policy experts


Senior teclmical experts


Areas ofexpertise

o Remedy selection

o Cost-effectiveness

o Program implementation

o National consistency

o Applicable or relevant and appropriate requirements

o CERCLA and the NCP

o Superfund policy and guidance


Available to travel at least one week per quarter to discuss proposed remedies


Ability to commit time for a detailed analysis of review packages

o Typically three review packages per quarter


Ability to reach consensus and craft recommendations to promote both consistent and cost-effective decisions at Superfund sites

28. How are recommendations used to benefit the Superfund Program?
Every year the NRRB, in consultation with the regions and OSRTI regional coordinators, will evaluate all the reviews written over that year, looking for recurring issues. OSRTI will work to develop any needed policy, guidance or training materials.
Appendix A -Recommended Outline for the Site Infonnation Package
Appendix A
RECOMMENDED OUTLINE
FOR THE SITE INFORMATION PACKAGE

Appendix A -Recommended Outline for the Site Information Package
Recommended Outline for the Site Information Package
Inclusion of clear and well labeled maps, tables, and figures with sufficient detail are critical to the review. Time spent by the site manager in preparing the site information package, and additional regional review of the draft site information package, is to the advantage of everyone involved in the reviews, as complex site decisions will likely benefit from careful preparation.
It is recommended that an internal review ofthe draft site information package be conducted by a colleague that is unfamiliar with the site.
All reference to ROD Guidance Highlights (e.g. ROD Guidance Highlights 6-18 to 6-20) refer to examples found in OSWER Directive 9200.1-23.P, A Guide to Preparing Supe1:(und Proposed Plans, Records ofDecision, and Other Remedy Selection Decision Documents.
A. Summary (less than five pages)
1) Site Summary

Site name and location


Site account number


Orientation to the key features of the site and surrounding area


On site and surrounding land use


Brief site contamination history, and facility operational history


Identify media and primary contaminants of concern (COCs) addressed by this proposed action


List the operable units addressed by this action and the media addressed by each

2) Risk Summary
Good examples ofrisk summary tables to include in the package can be found in ROD Guidance Highlights 6-18 through 6-20.

Identify by medium and operable units, the cumulative risk (if applicable), and land use scenario(s)


Identify by medium and operable units, if applicable, the primary risk drivers

3) Cleanup levels
Include a brief summary table of remedial action objectives (RAOs) and cleanup levels. If applicable, identify by medium and operable unit (see highlight 6-21 in the ROD Guidance
Appendix A-Recommended Outline for the Site Information Package
identified in the Risk Summary section).
4) Description ofAlternatives
Describe in a brief summary table the following for each medium and operable unit (if
applicable):
• Identify remedial alternatives evaluated and associated costs

Identify expected time to achieve cleanup levels 5) Preferred Alternative In bullet format, include the following for each medium and operable unit, if applicable:

• Describe remedy and estimated costs ofmajor activities


Identify expected time to achieve cleanup levels 6) Stakeholder views


State’s position on proposed action


Other stakeholder views

B.
Detailed Information

1) Site Name, Location, and Brief Description
Include an area map and detailed site maps with well labeled key features. Include an aerial
photograph, if available.
2) Site History and Enforcement Activities
Chronological list ofsign(ficant enforcement actions, including principal PRPs.
3) Scope and Role of Operable Unit or Response Action
Discuss how the operable unit or response action addressed by the proposed plan fits into the
overall site strategy. This discussion should describe the overall site cleanup strategy, including:

The planned sequence of actions


The scope of problems those actions will address

Appendix A-Recommended Outline for the Site Information Package
• The authorities under which each action will be/has been implemented (e.g., removal, remedial final, or remedial interim)
4) Site Characteristics

Describe the Baseline Risk Assessment Conceptual Site Model (CSM) on which the risk assessment and response action are based


Provide an overview of the site, including the following:
Size of site (e.g., acres)

-Geographical and topographical information (e.g., surface waters, flood plains, wetlands) Surface and subsurface features (e.g., number and volume oftanks, lagoons, structures, and drums on the site)
– Areas of archaeological or historical importance

Describe known or suspected sources of contamination


Describe types of contamination and the affected media (summarize in tables), including the following: -Types and characteristics of contaminants (e.g., toxic, mobile, carcinogenic,

non-carcinogenic) -Quantity/volume ofwaste -Concentrations of contaminants in each medium (see ROD Guidance Highlight 6.
15) and figures that illustrate hot spots, e.g. isopleths
-RCRA hazardous wastes and affected media


Include figures showing contaminant level changes over time


Describe location of contamination and known or potential routes of migration, including

the following: -Lateral and vertical extent of contamination -Current and potential future surface and subsurface routes ofhuman or
environmental exposure -Conceptual site model ofthe potential migration pathways of COCs in all media -Human and ecological populations that are or could be affected
• For sites with groundwater and surface water contamination, describe the following: -Aquifer(s) affected or threatened by site contamination, types of geologic materials, approximate depths, whether aquifer is confined or unconfined
-Sources and source areas of groundwater and surface water contamination, including information on non-aqueous phase liquid extent, location, and characteristics
– Groundwater flow directions within each aquifer and between aquifers and groundwater discharge locations (e.g., surface waters, wetlands, other aquifers) -Appropriate maps and cross sections showing stratigraphy and monitoring well layout
Appendix A-Recommended Outline for the Site Information Package
• Identify any computer models used that served as the basis for risk, fate and transport, or ARAR compliance decisions. For non-EPA recommended model applications, list the input parameters: measured data, literature data, and default inputs used in the predicted outputs. Also, include results of model uncertainty and sensitivity analysis for key site parameters.
5) Current and Potential Future Site and Resource Uses:
Land Use

Current on-site land uses


Current adjacent/surrounding land uses


Reasonably anticipated future land uses, with expected time frames for such uses, and basis for future use assumptions (e.g., zoning maps, nearby development, 20-year development plans, dialogue with local land use planning officials and citizens).

Ground and Surface Water Use

Current ground/surface water uses on the site and in its vicinity


Potential beneficial ground/surface water uses (e.g., potential drinking water, irrigation, recreational) and basis for future use assumptions (e.g., Comprehensive State Groundwater Protection Plan, promulgated State classification, EPA groundwater classification guidelines)


If beneficial use is an anticipated drinking water source, identify the approximate time frame of projected future drinking water use (e.g., groundwater aquifer not currently used as a drinking water source but expected to be utilized in future years)


Location of anticipated use in relation to location and anticipated migration of
contamination.

6) Summary of Risk1:
Human Health Risk Assessment

Identify potentially exposed populations in current and future scenarios (e.g., worker currently working on site, adults and children living on site in the future)


Identify sensitive sub-populations (highly exposed and/or more susceptible) that may be exposed (e.g., farm families, children, subsistence fishermen)


Identify the routes by which each population group or sub-population group could reasonably be exposed to site contaminants (e.g., ingestion of contaminated groundwater

1 The site information package should include a synopsis of the risk assessment(s). Detailed information may be provided by posting documents to the Board’s Quickr site or by providing the Superfund Document Management System document identification number.
Appendix A-Recomm_ended Outline for the Site Information Package
for adults and children, inhalation of volatile contaminants for workers)

Include major assumptions about exposure frequency, duration, and other exposure factors that were included in the exposure assessment (e.g., exposure frequency [days/year], exposure duration [years], and body surface area for dennal exposure) could be included in an appendix


Highlight any non-standard exposure assumptions used in the baseline risk assessments


Provide a summary (preferably a table) that includes the following for all current and future land use scenarios presenting unacceptable risks: -Quantified carcinogenic risks for each COC in each exposure medium for each relevant exposure pathway -Combined carcinogenic risks reflecting total exposure to COCs in a given medium and pathway of exposure -Potential for non-carcinogenic impacts as quantified by the hazard quotient for each COC in each exposure medium for each exposure pathway, as appropriate

-Potential for combined non-carcinogenic effects in each medium and pathway of exposure as expressed by hazard indices, which reflect the potential additive effects of COCs that affect the same target organ or system
– Identify key uncertainties in the baseline risk assessment
• If applicable, describe how radiological risks were calculated.
Ecological Risk Assessment (particularly where these risks drive remedy selection)

What are the assessment endpoints determined to be at risk (the foundation of the
remedial decisions, that is, the risk drivers)?


Which ofthese risks would require remedial action?


Which site contaminants were determined to be causal and by which exposure routes (i.e., what is the conceptual model/exposure model?).


Describe the thresholds of exposure generating risk, and at what level of exposure do the risk levels become severe?


What is the confidence in the risk estimates? Are there documented effects?


Describe any site-specific data that were available


How large is the area for which ecological risks have been estimated?


Description ofkey species that could be exposed


Describe complete exposure pathways, present the conceptual site model


Monitoring or modeling data and assumptions


The ROD Guidance (Pages 6-22 to 6-25) provides summary tables that would supply the above requested information.

7) Remedial Action Objectives and Preliminary Remediation Goals
• Present the basis and rationale for remedial action objectives (RAOs) & preliminary remediation goals (PRGs) (e.g., current and reasonably anticipated future land use and potential beneficial groundwater use)

Describe how the RAOs & PRGs address risks identified in the risk assessment (e.g., how will the risks driving the need for action be addressed by the response action?)


Identify any key ARARs that are driving the remedy selection


Where ecological risks drive the remedy, provide the range of protective cleanup levels and their basis.


Explain how cleanup levels are developed from these goals considering the remedy
selection criteria.


Explain the role of background in the evaluation of cleanup levels .

8) Description of Alternatives:
• Provide a bulleted list and appropriate figures of the major components of each alternative. The package should include the following: -Treatment teclmologies and materials they will address (e.g., source materials constituting principal threats)
-Containment components of remedy (e.g., engineering controls, cap, hydraulic barriers) and materials they will address (e.g., low concentration source materials, treatment residuals)
– Description of institutional controls and how they will be implemented and maintained and the duration -For alternatives that depend upon monitored natural attenuation, demonstrate compliance with EPA policy

Provide the total estimated capital, annual operation and maintenance (O&M), and total present worth costs, discount rate, and the number of years over which the remedy cost estimates are projected


Summarize the capital and annual O&M costs associated with each of the major
components of each alternative

9) Comparative Analysis of Alternatives
Provide a summary table and discussion comparing alternatives that pass the threshold criteria against the nine criteria.
1 0) Principal Threat Waste
Clearly identify how source materials constituting principal threats are addressed or provide an explanation ofwhy the site does not have principal threat waste (refer to A Guide to Principal Threat and Lolli’ Level Threat Wastes-OSWER 9380.3-06FS, November 1991).
11) Preferred Alternative
Appendix A -Recommended Outline for the Site Information Package

Clearly describe the preferred alternative and how, if appropriate, it is different from the alternatives evaluated


Describe the key factor(s) that led to selecting the preferred alternative (i.e., describe how the remedy provides the best balance of tradeoffs with respect to the balancing and modifying criteria, highlighting criteria key to the decision)

12) Applicable or Relevant and Appropriate Requirements2

List the principal ARARs for the preferred alternative


Describe the ARARs that are drivers for the remedy


For each driver, explain vl’lzy it is an ARAR (versus a “to be considered”)


Where actual language ofthe regulation is key to the Board review, include a copy of the relevant section in an appendix to the package

13) Technical & Policy Issues
Include a discussion oftechnical or policy issues that require further discussion prior to implementation ofthe preferred alternative (data gathering, ARARs, treatability studies, modeling.
14) Cost Information4

Include sufficient information to provide an estimate oftotal resource costs over time

(i.e., life cycle costs) for all alternatives including (ROD Guidance Highlight 6-29) -Capital costs -Annual operations and maintenance costs -Net present value of capital and O&M costs


Cost estimate summaries should address the following: -The key cost components/elements for both Remedial Action and O&M activities -The major sources of uncertainty in the cost estimate -The discount rate used -The time expected to achieve RAOs and remedial goals

Periodic capital and/or O&M costs anticipated in future years of the project (e.g., remedy replacement or rebuild) -The methods and resources used for preparing the cost estimate (e.g., estimating guides, vendor quotes, computer cost models)


For contingency remedy decisions, the total project costs for implementing the

2 The site information package should include a synopsis of this information. Detailed information may be provided by posting documents to the Board’s Quickr site or by providing the Superfund Document Management System document identification number.
contingency should be provided in addition to the costs for the conditional action. This estimate should include treatability study costs, if applicable.
• The assumptions used to develop the cost estimate should be consistent with the stated RAOs and remedial goals (e.g., duration of the cost estimate should match time to achieve cleanup objectives).
15) Letters from Stakeholders and State
Include in the package any technical comments provided by the state or other stakeholders.
Appendix B -Sample Agenda for the Board Meeting
Appendix 8
SAMPLE AGENDA FOR THE BOARD MEETING

Appendix B -Sample Agenda for the Board Meeting
Sample NRRB Meeting Agenda
8:30-8:45 Introductions
8:45-9:45 Site Presentations (IO-I5 minutes additional time for state/tribal presentations)

9:45 -10:00 BREAK 10:00-II :30 Questions & Answers
11 :30 -I2:30 LUNCH The following sessions are for EPA staff only 12:30-2:I5 Deliberations 2:15-2:30 BREAK 2:30-3:00 Board Business (not site-specific) 3:00-5:00 Write and Review Board Recommendations
5:00 ADJOURN
Appendix C -Recommended Outline for the Board Presentation
Appendix C
RECOMMENDED OUTLINE
FOR THE BOARD PRESENTATION

Appendix C-Recommended Outline for the Board Presentation
Recommended Outline for the Board Presentation
The main emphasis of the presentation, which typically runs one hour in length, should be on the preferred alternative. Hard copies of the presentation should be provided for all Board members at the meeting (preferably two slides per page).
Although not recommended for the presentation, site managers should have key figures available (electronically ifpossible) from the Rl!FS and site infonnation package in case ofquestions during the discussions.
The following suggested times should be used as a guide but are not mandatory:

Site Summary & Risk Summary-10


RAO & Description ofAlternatives-15


Preferred Alternative-25


Stakeholder Views or Presentation-10

1) Site Summary

Orientation to the key features of the site and surrounding area (including maps)


On site and surrounding land use


Brief site contamination history, and facility operational history


Identify media and primary COCs addressed by this proposed action


List the other operable units at the site and the media addressed by each

2) Risk Summary

Identify by medium and operable units, the cumulative risk (if applicable), and land use scenario(s)


Identify by medium and operable units, if applicable, the primary risk drivers

3) Remedial Action Objectives and PROs

Present the basis and rationale for RAOs and PROs (e.g., current and reasonably
anticipated future land use and potential beneficial groundwater use)


Describe how the RAOs and PROs address risks identified in the risk assessment (e.g., how will the risks driving the need for action be addressed by the response action?)


Identify any key ARARs that are driving the remedy selection

4) Description ofAlternatives
Appendix C -Recommended Outline for the Board Presentation
Describe in bullet format the following for each medium and operable unit (if applicable):

Briefly identify key components of all remedial altematives evaluated and associated costs


Identify risk reduction and expected time to achieve cleanup levels

5) Preferred Altemative

Provide a brief summary table or figure that compares all the altematives, clearly
illustrating the commonality and differences between each altemative


For the preferred altemative, identify for each medium and operable unit: -The rationale and key factors that led to the selection of the preferred altemative -The remedy and estimated costs of major acti

Post

2012-01-04 – Considering environmental justice issues EPA should establish a CAG for West Lake Community

.. ,
PUBLIC INFORMATION CLEARANCE RECORD
I I I I

(

1. ORIGINATOR end PHONE DTBISION DA’n:
Debbie Kring, X7725 114/2012
2. PRODUCT TITLE
Ad-Announcement of Release ofthe West Lake Landfill Superfund Site Final Supplemental Feasibility Study (SFS)
3. PROPOSED USE
Announcement for the community at large, the Superfund repositories and the Record Center.
4. CONCURRENCE: SlgiHff …. Dille
OPA SUPR CNSL OPA ~ ~ Ji Thomas/Hood 01 ~~12011.l {?/’ SUPR CNSL -Singletary Gonzales
Signature in this block indicates the appropriate assistant administrator, regional administrator, head of staff office, or their delegate has reviewed and approved the material submitted to OEP or RGAD for signature.

G Drive: Product Masters File/Public Information Form 11 /1/05
~ I

40436738 ~
IIIII/I II
II IIIII IIIIIIIIIIIIIII IIIII/III/II/IIIII
Superfund
Region 7
Project/Background/Purpose:
West Lake Landfill (Superfund Site)
Atter listing the site on the NPL the EPA completed a preliminary study and determined that no immediate actions were necessary at the Westlake Landfill site while site studies are underway. Subsequently, EPA entered into a consent agreement with the responsible parties in which the parties agreed to perform field studies and engineering evaluations designed to identify the best strategies for cleanup. Remedial investigation and feasibilty study work was completed in 2006 and a proposed plan for both operable units was published in June 2006. The Record of Decision for Operable Unit 1 was signed in May 2008. The selected remedy calls for the installation of an engineered landfill cover and implementation of a long-term monitoring program. The Record of Decision for Operable Unit 2 was signed in July 2008. Under this decision, the other landfill units \\·ill be closed and monitored in accordance with Missouri solid waste regulations.
Critics of the selected remedy for OU 1. including the Missouri Coalition for the Environment. want the waste material to be excavated and shipped to an off-site location. In an April 2009 letter to the Administrator, the Great Rivers Environmental Law Center (on behalf ofthe Coalition) again raised its concerns and requested the remedy be reevaluated. After extensive consultation between the Region and Headquarters. EPA made a decision to conduct a supplemental feasibility study (SfS) for QUI that further evaluated full-scale excavation of the radiologically-contaminated landfill material and disposal either off-site or in a new, on-site engineered disposal cell. The Remedial Design/Remedial Action (RD/RA) negotiations (which sequentially follow the signing ofthe Record of Decision) \Vere put on hold in June 2009, pending the outcome of this study.
In January 20 I 0. EPA agreed to allow the Potentially-Responsible Parties ( PRPs) to perform the SFS, pursuant to the existing Administrative Order on Consent under which the PRPs had performed the Remedial investigation/Feasibility Study (RI/FS) and RD. EPA-Headquarters (Jim Woolf(Jrd) sent a letter to the Great Rivers Environmental Law Center on March 3, 2010 stating that EPA would conduct a SFS. The SFS Work Plan was approved under a cover letter dated May 21, 2010, and was released to the public in June 2010. EPA received the draft SFS report on July 23.2010. On September 22,2010. EPA met with MDNR and the PRPs to discuss comments about the report. On November 10, 2010, EPA formally submitted comments to the PRPs and requested changes to the report by January 16, 2011. The PRPS asked for an additional 60 days, which EPA granted. PRPs responses to comments are currently under rCVlC\V.
Support Needed:
Contractor support is needed to potentially provide facilitation, technical assistance to public groups (i.e., the CAG), and review of technical documents that support the site:
+
Coordinating with Public Groups (i.e .. CAG):

+
Preparing tor, Facilitating, and providing summaries at EPA & Group (CAG) Meetings (up to 6 meetings):

+
Technical Document Review and Summary of Content (estimate= 3 technical documents):

+
Developing Presentation Materials (technical document content breakdown and summary):

+
Developing Responses to Community Inquiries (technical issues);

* Currently there is not a CAG at this Superfund Site, however, due to the site complexity, the extension of the original public comment period on the Proposed Plan (6 extensions). the political inquiries. EJ considerations, and environmental group involvement. it would be a wise move on EPA’s part to have additional options in the review, response, and facilitation arenas.

Post

2012-01-04 – EPA – Request for total assessed value of businesses within the Levee District encompassing the West LakeLandfill

{In Archive} Can you get the total assessed value of businesses within the Levee District encompassing the WL landfill Cecilia Tapia to: Dan Gravatt 01/04/2012 03:13PM Cc: DeAndre Singletary, Audrey Asher
History: This message has been forwarded.
Archive: This message is being viewe~ in an archive.
Karl thought that this would be a good indicator of the private levee’s ability to maintain the levee system .
In addition he wants to know if there has ever been any flooding in the area since the levee was built.

Thanks, Cecilia Tapia Director, Superfund Division
U.S. EPA901 N. 5th Street Kansas City, KS66101 (913)551-7733 FAX: (913)551-7145 CELL:(913)449-4171 EMAIL: tapia.cecilia@epa.gov
The information., t 1 ematl and in any of tt a tachmen IS confrdenbal and may be privileged. If you are n<>l the intended 1ecip~en please destroy 1 · message. (La inlonnaaon contemda en esle menS

Post

2012-01-04 – Purpose of public interviews in the Superfund Process

·-,
/(_:.
. \ ‘ RE: West Lake Landfill: possible interivews related to the revised CIP
\,.__,-J• …1
\. -~”””C7 Muenk.s, Shawn to: Dan Gravatt, Debbie Kring 01/04/2012 04:31 PM Cc: “Doster, Branden”
1”1 orn: “Muenks, Shawn”
To: Dan Gravatt/R7/USEPA/US@EPA, Debbie Kring/R7/USEPA/US@EPA
Cc: “Doster, Branden”
Dan & Debbie,
It was our understanding that the purpose of the public interviews would be to
gauge concerns and expectations of nearby communities regarding West Lake
Landfill and how they want to be interacted with during the public comment
period. The interviews should be done prior to the public comment period and
information gathered included in the CIP. The interviews would not
necessarily be used to determine which remedy the public supports. We were
also under the impression from our discussion at the last site tour that EPA
was committed to conducting these interviews. I think a call to discuss this
issue is warranted. Please advise of availability. We are available Thursday
or Friday morning this week and Monday or Tuesday of next week.

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

P.O. Box 176, Jefferson City, MO 65102-0176 Ph: (573) 751-3107 email: shawn.muenks@dnr.mo.gov —–Original Message—-.From: Dan Gravatt [mailto:Gravatt.Dan@epamail.epa.gov] Sent: Wednesday, January 04, 2012 3:53 PM To: Muenks, Shawn; Doster, Branden Cc: Debbie Kring Subject: West Lake Landfill: possible tnterivews related to the revised CIP
Shawn, Branden,
Following up on the question you posed in yesterday’s biweekly conference call, I spoke with Debbie Kring yesterday on the issue of conducting public interviews as part of the revised CIP. Debbie stated that it has not been decided whether EPA will conduct these interviews, but if our Office of Public affairs decides to do so, they will be conducted in the spring. OPA intends to treat these interviews separately from public comment periods and/or public meetings associated with any decision documents.
If you have any other questions on this issue, please contact Debbie directly at 913-551-7725.
Sincerely, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063
Principles and integrity are expensive, but they are among the very few things worth having.
[) 7/ (~/ 40440122
llllllllllllllllllllllllllllllllllllllllllllllllll
Superfund
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Post

2012-01-10 – Monthly Status Report – December 2011 West Lake Landfill Operable Unit 1, Bridgeton, Missouri

ENGINEERING MANAGEMENT SUPPORT INC.

7220 West Jefferson Avenue, Suite 406 telephone (303) 940-3426 Lakewood, CO 80235 Telecopier (303) 940-3422
January 10, 2012 VIA: Electronic Mail
U.S. Environmental Protection Agency Region Vll 901 N.S”^ Street Kansas City, KS 66101
ATTENTION: Mr. Dan Gravatt
SUBJECT: Monthly Status Report – December 2011 West Lake Landfill Operable Unit 1, Bridgeton, Missouri
Dear Mr. Gravatt,
On behalf of Cotter Corporation (N.S.L.), Laidlaw Waste Systems (Bridgeton), Jnc, Rock Road Industries, Inc., and the United Sates Department of Energy (the “Respondents”), Engineering Management Support Inc. (EMSI) submits the attached status report for the month of December 2011 as required by paragraph 56 ofthe West Lake Landfill Administrative Order on Consent, Docket No. VII-93-F-005. Ifyou have any questions or desire additional information related to this status report or any other aspect ofthe project, please do not hesitate to contact me.
Sincerely,.
ENGINEERING MANAGEMENT SUPPORT, Inc.

Paul V. Rosasco, Distribution:
Shawn Muenks – Missouri Dept of Natural Resources
Victoria Warren – Allied Waste Industries, Inc.
Ward Herst – Herst & Associates, Inc.
Jessie Merrigan – Lathrop & Gage
Bill Beck – Lathrop & Gage
Charlotte Neitzel – Holme Roberts & Owen
Steve Golian – U. S. Department ofEnergy
Steven Miller – U. S. Department ofEnergy (via electronic mail)
Christina Richmond – U.S. Department of Justice (via electronic mail)
Dan Feezor – Feezor Engineering
Mike Bollenbacher – Auxier & Associates

40360233
I
Superfund
Monthly Status Report – December 2011
West Lake Landfill Operable Unit 1
Bridgeton, Missouri

This status report has been prepared by Engineering Management Support Inc. (EMSI) on behalf of Cotter Corporation (N.S.L.), Bridgeton Landfill, LLC (formerly known as Laidlaw Waste Systems [Bridgeton] Inc.), Rock Road Industries, Inc., and the United States Department ofEnergy (the “Respondents”) for Operable Unit -1 (OU-1) at the West Lake Landfill as required by paragraph 56 ofthe West Lake Landfill Administrative Order on Consent, Docket No. VII-93-F-005.
1. Work Performed During December 2011
Proiect Planning
A final Work Plan for preparation of a Supplemental Feasibility Study (SFS) of “complete rad removal” altematives addressing EPA and MDNR comments was submitted to EPA and MDNR on June 7, 2010.
Note – A draft Remedial Design Work Plan was submitted to EPA in November 2008. In accordance with direction from EPA, all work on design ofthe ROD-selected remedy has been put on hold until after completion ofthe SFS evaluations of “complete rad removal” altematives.
Fieldwork – Sample Collection/Analysis
None.
Report Preparation
A revised SFS report was completed and submitted to EPA and MDNR on September 30, 2011. The Respondents received comments from EPA on November 14, 2011. EMSI received comments from MDNR on November 21, 2011: EPA provided guidance relative to MDNR comments via e-mail on December 7, 2011 and via U.S. Mail on December 9, 2011. Work was performed during December to address EPA and MDNR comments and prepare a final version ofthe SFS report. The revised SFS report was submitted to EPA and.MNDR on December 16, 2011. A revised title page and revised ” compact disks without the Executive Summary were submitted on December 28, 2011. An Executive Summary was submitted separately on December 29, 2011.
The monthly progress report for November 2011 was prepared and submitted to EPA and MDNR on December 10, 2011.
December 2011 Projeci Status Report Westl..ake Landfill ou-1
I/I0/I2 Page 1
Proiect Management
None.
Meetings
None.
Correspondence
None.

2.
Analytical Data Collected During This Reporting Period None.

3.
Work Scheduled to be Performed during January and February 2012

With completion ofthe revised SFS report in December 2011, no further work on the SFS or any other aspect ofthe project is anticipated to be conducted during January or February 2012 unless additional work is requested by EPA. Per prior direction from EPA, all work towards finalizing the Remedial Design Work Plan and implementation of the remedial design activities is on hold until the SFS is completed.

4.
Problems Encountered None.

December 2011 Project Status Report West Lake Landfill OU-1
Page 2

Post

2012-01-25 – NRRB – Questions and Answers for Superfund Site Managers

{In Archive} Fw: NRRB review of Westlake Landfill Craig Smith to: Dan Gravatt 01/25/2012 03:42PM Cc: DeAndre Singletary, Audrey Asher, Robertw Jackson, Cecilia Tapia
Archive: This message is being viewed in an archive.
As Amy said, here is the current schedule of meetings:
~r-:1
FY 2012 NRRB Meeting Calendar.docx
The guidance calls for the review packages as follows, so this may influence the schedule:
“Finalize the informational site package at least four weeks before the meeting and provide the package to the relevant regional NRRB member for distribution to Board members in preparation for the site review. The package will be posted on the Board’s Quickr site so that Board members may download it at their convenience. Oversized charts, maps or tables should be mailed to the Board members. The mailing list is available from the Board’s Quickr site. Please note that two additional copies should be mailed to the Board chair for distribution to OSRTI participants.”
Let me know what looks good.
Thanks, Craig S
Craig W. Smith, P.E. Senior Engineer and Policy Coordinator Superfund Division USEPA Region 7 Kansas City
(913) 551-7683
—–Forwarded by Craig Smith/SUPR/R7/USEPAIUS on 01/25/2012 03:28PM—-.
From: Amy Legare/DC/USEPAIUS· To: Dan Gravatt/R7/USEPAIUS@EPA, Craig Smith/SUPR/R7/USEPAIUS@EPA Cc: Dave Crawford/DC/USEPAIUS@EPA, Gary Worthman/DC/USEPAIUS@EPA Date: 01/25/2012 12:28 PM Subject: NRRB review of Westlake Landfill
Hello all! It is my understanding that the Administrator, Region 7 RA, your DD, and my OD agree that the NRRB should review the remedial action planned for this site. We have some flexibility for when this could happen. We can hold a web conference (not video) during the week of February 13 or 20, or you can join· the already planned meeting the week of March 12 in Chicago. April is difficult due to spring break and we already have a packed meeting the week of April 23. The month of May is wide open. Let me know what works for you.
Here is the Q&A guide for the Board. It contains an outline for the review package and presentation.
§1
Finai.RPM.NRRB.Manual.12.29.11.doc

Amy R. Legare
011~
U.S. Environmental Protection Agency
-J.o
40450137
IIIII/IIIIIIIIIIIIIIII IIIII1111111111 /II/IIIII/III
Superfund
DllD I
OSWER/OSRTI/ARD/SARDB 5828 Potomac Yard South MC 5204P 703-347-0124
3/28/2014

Completed Reviews
October 18, 2011 (web conference) Lava Cap OU3 -R9 (consultation)
December 6-7, 2011 -Seattle (NRRB/CST AG -full 2-day meeting) Lower Duwamish -R 1 0
Planned Reviews
March 12-16, 2012-Chicago or Denver Raritan Bay Slag-R2 MEW-R9
March 26-30, 2012-Hanford, WA Tour Hanford 1 00-K Area Hanford 200 UPI Hanford 300 Area
April23-27, 2012-HQ Gowanus Canal-R2 (joint w/ CSTAG) V elsicol -R4 Montross -R9
June 18-22,2012-Philadelphia Ringwood Mine-R2 681h Street Dump -R3 American Creosote-R4
July 23-27, 2012 Sauget Area 2 -R5 Stringfellow-R9 San Gabriel -R9
October 22-26, 2012 Lower Darby -R3 Casmalia -R9
Future Passaic River-R2 (with CSTAG, 2 day meeting) Libby OU4-R8 Portland Harbor-RIO Quendall Terminals-R 10

NATIONAL REMEDY REVIEW BOARD

Questions and Answers for
Superfund Site Managers

December 29, 20 11
1. What is the National Remedy Review Board?
In October 1995, the EPA Administrator announced a collection of initiatives designed to help control remedy costs and to promote consistent and cost-effective Superfund cleanup decisions. As one of these initiatives, the National Remedy Review Board (NRRB, the Board) reviews proposed high-cost cleanup decisions to help evaluate whether they are consistent with current law, regulations, and Agency policy and guidance.
The Board is a technical and policy review group made up of members that have experience with both regional and Headquarters perspectives in the Superfund remedy selection process. Its members include senior managers and technical experts from each EPA region, as well as senior technical and policy experts from other EPA offices. These include the Office of Superfund Remediation and Technology Innovation (OSRTI), Office ofResearch and Development, Office of Radiation and Indoor Air, Federal Facilities Restoration and Reuse Office (FFRRO), Office of Site Remediation Enforcement, and Office ofGeneral Counsel. The Board is chaired by OSRTI.
The Board generally meets quarterly to review proposed decisions that meet its cost-based review criteria. The product of the review is a memorandum sent from the Board to the regional Superfund division director that documents Board recommendations about the proposed cleanup strategy. The Board review process allows full input from EPA regional site managers and other site team members as deemed appropriate by the region whose site is under review. EPA’s site managers are asked to participate in all deliberations to ensure that the Board fully understands the circumstances influencing their proposals.
2. Which sites will the Board review?
Typically, the Board reviews cleanup strategies after the remedial investigation/feasibility study (RVFS) and before the region releases the proposed plan for comment. If necessary, the Board may review sites at other phases of cleanup, possibly before the FS is completed. The Board tries to accommodate regional preferences for scheduling reviews; however, it may not be able to meet all desired regional schedules. It is therefore imperative that site managers work closely with their Board representatives and regional management to schedule sites for review as soon as cost estimates trigger the review criteria outlined below.
Both National Priorities List (NPL) and non-NPL (e.g., “Superfund Alternative”) site actions are reviewed by the Board whenever the Agency expects the work to be done underthe Comprehensive Environmental Response Compensation and Liability Act (CERCLA), in accordance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and other relevant guidance, and when the general criteria below are met. The Board reviews
sites when EPA is directly responsible for the decision or has a concurrence role, including PRP.lead, special account-funded and federal facility-lead sites.
Board Review Criteria
The Board will typically review proposed interim and final Superfund response decisions at both NPL and non-NPL (including Superfund Alternative) sites for which the proposed:

Remedial action costs more than $25 million; or


Non-time critical removal actions (NTCRA), at sites other than a federal facility, is estimated to cost more than $25 million; or

Board reviews will also occur for NPL and non-NPL sites following changes made after the release of the proposed· plan:

A different or modified alternative (which was included in the original proposed plan) is selected by the region that costs more than 20 percent when compared to the original proposal and these costs trigger review criteria (even when the earlier proposed action had undergoneBoard review).


A new alternative is developed and the costs ofthe new alternative would trigger a review.

The Board may review (at regional discretion) sites where the proposed action’s original cost estimate increases more than 20 percent after issuance ofthe Proposed Plan due to either updated cost information or minor changes to the alternative that trigger review criteria. Examples of minor changes are presented in Chapter 7 ofA Guide to Preparing Supe1:(und Proposed Plans, Records ofDecision, and Other Remedy Selection Decision Documents, Office of Solid Waste and Emergency Response Directive No. 9200.1-23P, July 1999 (ROD guidance).
Federal Facility Sites (other than the Department ofEnergy)
Federal facility sites (including Formerly Utilized Sites Remedial Action Program-FUSRAP) follow the same review criteria above with the exception ofNTCRAs; federal facility NTCRAs do not undergo Board review unless requested by the federal facility. Decisions at Base Realignment and Closure (BRAC) sites do not undergo Board review.
Department ofEnergy Sites
The NRRB typically will review sites where the primary contaminant is radioactive waste and · the proposed remedial action costs more than $75 million. The Board will also review NPL sites with NTCRAs exceeding $30 million involving primarily radioactive waste; (per joint Department of Energy/EPA memorandum dated October 5, 1998).
3. Can Regions Request an optional early consultation?
Regions may request an optional NRRB consultation on remedial alternatives at the draft FS scoping stage or any time prior to the draft proposed plan. Regions will not be expected to respond to this early review. Regions should notify states, tribes, local governments, PRPs and local communities when a site will be the subject of an early consultation. Stakeholder, including PRPs, input (up to 10 pages) should be requested as part ofthe early consultation process. This optional consultation will not excuse a site from NRRB review at the proposed plan stage ifthe proposed remedial action meets the NRRB review criteria.
4. Can Regions Request an exemption from Board review?
Regions may request that the NRRB Chair exempt their eligible site from Board review. In addition, Regions can request an exemption in cases where the Region selects a different alternative (after the release of the Proposed Plan for public comment) which costs more than 20 percent from the original proposal and these costs trigger review. The OSRTI office director will make the ‘final exemption decision. The Regional Division Directors can appeal a decision to deny an exemption to the OSRTI Office Director. Regions should offer states, tribes, local governments, PRPs and local communities an opportunity to summarize in writing their opinion regarding the proposed exemption decision. This information will be forwarded to the Board chair along with the exemption request. Regions will not be expected to respond to these letters but will notify the commenters ofthe final decision regarding an exemption.
NRRB Exemption Request Process and Criteria
The region requesting an exemption from an NRRB review should provide a summary of the following information to the Board chair. Exemption requests should not exceed 10 pages.
1.
Site name

2.
Media to be addressed, primary contaminants of concern, preliminary remediation goals

3.
Scope and role of the operable unit or response action

a. Does this action hinge on previous actions?

4.
Risk summary

5.
Remedial action objectives

6.
Alternatives-do they address

a.
TI or MNA?

b.
Treatment of principal threat waste?

c.
Presumptive remedy?

d.
Addressing munitions? (no chemical COCs or groundwater)

7.
Tribal or state ARARs

8.
Stakeholder views

a. Congressional or community controversy?

9.
Decisions requiring headquarters coordination or consultation

a.
Non-time critical removal actions over$ 6M

b.
Remedies for lead, radionuclides, PCBs, asbestos, mercury and dioxin

10.
Concurrence ofregional division director on exemption request

After receipt of the exemption request, the Board chair will hold a conference call with the region to discuss the request. The Board ch~ir will forward the exemption request and recommendation to the OSRTI office director. If the site is a federal facility the FFRRO Board member and office director will participate in the exemption process.
The region should seek input from site stakeholders (e.g., PRPs, states, tribes, and communities) on the request for exemption from NRRB review. Stakeholders may submit up to 10 pages stating their specific issues or concerns. Submissions may be sent to the region or Board Chair at the following address:
Amy Legare
National Remedy Review Board
US EPA
1200 Pennsylvania Ave., NW MC5204P
Washington, DC 20460
Or
Legare.amy@epa. gov
The OSRTI office director will make the final exemption decision after consultation with the regional division director and consideration of stakeholder input.
5. Will the Board review sites with Record of Decision amendments or Explanation of Significant Differences?
Generally, the Board reviews proposed Record of Decision (ROD) amendments where there is a change from the original remedial strategy (e.g., moving from a containment remedy to a treatment remedy) that results in remedial action costs greater than $25 million.
Generally, the Board does not review ROD amendments where the:

Original remedial strategy remains the same (e.g., where the cost increase results from an unexpected increase in contaminated soil volume), even ifthere is an appreciable change in cost (however, the region should consult with their board representative to contlnn review criteria) or


Amendment results in a cost savings.

The Board usually does not review Explanation of Significant Differences unless the region believes the site would benefit from such a review.
6. Will the Board review sites with final Record of Decision following an interim Record of Decision?
Generally, the Board will review final RODs that follow an interim ROD where there are new significant capital costs in addition to the incremental operation and maintenance (O&M) costs associated with the final ROD. When the costs of a planned final ROD (following an interim ROD) exceed the trigger criteria due to costs driven primarily by the interim remedy’s O&M (e.g., the plant is already constructed and the remaining costs are due to long term system operation), the site does not require Board review. In lieu of a Board review, the region should conduct an optimization review, consistent with EPA guidance, before the final remedy is selected. Information on remedy optimization may be found at this linlc http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm
7. Will the Board review proposed sediment actions that are also subject to Headquarters consultation or Contaminated Sediments Technical Advisory Group review under Office of Solid Waste and Emergency Response Directive 9285.6-08, Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites?
Yes. As explained in the Office of Solid Waste and Emergency Response (OSWER) Directive 9285.6-11, OSRTI Sediment Team and NRRB Coordination at Large Sediment Sites, issued on March 5, 2004, review of consultation memos by the OSRTI Sediment Team (for Tier 1 sites) and by the Contaminated Sediment Technical Advisory Group (CST A G) will be coordinated with the Board so that the region receives only one set ofcomments at the time ofthe proposed plan. This process is explained in more detail below.
Tier 1 Sites
For Tier 1 sites that will undergo a NRRB review, the region should include a draft Tier 1 Consideration Memo in the site information package sent to the Board. A copy ofthe Consideration Memo should also be sent to the appropriate OSRTI regional coordinator and to the OSRTI Sediment Team leader. The OSRTI Sediment Team will review the Consideration Memo and the site package, and will provide comments to the chair of the NRRB prior to the Board’s meeting on the site in question. If the draft Proposed Plan is available, it should also be submitted to the OSRTI regional coordinator and the Sediment Team Leader at that time. If it is not available, it should be submitted as soon as it is drafted. The Sediment Team will not submit separate comments on the Consideration Memo to the region.
As part of its response to the NRRB recommendations, the region should include a revised Tier I Consideration Memo that addresses any comments made by the NRRB related to the issues covered by the Memo. If the NRRB chair and OSRTI Sediment Team leader believe that their comments were not appropriately addressed, and after consultation with the OSRTI Regional Branch Chief, the region may be asked to make additional revisions to the Consideration Memo.
Contaminated Sediments Technical Advisory Group Sites
It is anticipated that the proposed remedy for most ofthe large sites being reviewed by the Contaminated Sediment Technical Advisory Group (CSTAG) will also meet the NRRB review requirements. Therefore, a subset ofCSTAG members will participate in the NRRB review. This subset will be selected based on expertise matching the site characteristics. When a site manager prepares the site package for the NRRB it should include a draft Tier 2 Consideration Memo. The memo should document how the region considered all 11 principles when selecting the site’s proposed remedy; the memo should normally be less than 20 pages in length. The site manager will be provided with one set of recommendations from this joint review.
8. What is the role of the Office of Superfund Remediation and Technology Innovation?
OSRTI will assign an ad hoc Board member for each review. The ad hoc member will be assigned based on the area of expertise required for the review. For example: risk assessment, contaminated sediments, radiation, groundwater contamination, or vapor intrusion. In addition, the technical regional coordinator will work closely with the Board chair on all aspects ofthe revtew.
OSRTI will also work to develop any needed policy, guidance or training materials deemed necessary after each annual review of recommendations. For additional infonnation see Question
28.
9. Will the Board review proposed remedies selected pursuant to presumptive remedy guidance?
Yes, unless the review is waived by the Board chair. Regions and regional Board members are encouraged to consult with the Board chair on presumptive remedies to ensure a productive review of t~e proposed remedy.
10. How long does a typical Board review take?
Generally, the review process takes about eight weeks, from the time the Board receives the informational site package until it transmits its recommendations to the region. Regions should consider this additional time in developing the site work plan and Superfund Comprehensive Accomplishment Plan targets. However, regions should also be aware that, in a few cases, Board recommendations may delay site decisions while the regional decision makers consider and respond to Board findings. Also, the region should allow adequate time for preparation of a comprehensive site package. The average preparation time is generally one to two months.
Board reviews are planned for the first month of each quarter of the year. Site managers should notify their regional Board member and the Board chair of the need for a review as soon as possible so the site can be added to the calendar ofplanned reviews. Generally one to two months time is needed to plan a review with travel, hotel, and meeting space accommodations.
11. What does the Board look at when it reviews a cleanup decision?
Generally, the Board analyzes proposed cleanup strategies to help ensure they are consistent with CERCLA, as amended, the NCP, and relevant EPA cleanup guidance. To assist Board members with these reviews, the region prepares a site information package for each site (see additional questions below and Attachment A for more details). Generally, the Board will not be reviewing the draft FS nor the draft decision document.
When the Board reviews a site, the members consider a variety of information, including elements ofthe RIIFS process related to the development of the alternatives and selection ofthe preferred alternative. Site-specific circumstances often influence the nature of the discussion. Please referto Appendix D for questions frequently asked by the Board.
12. What are the site manager’s responsibilities before the meeting?
As soon as the site manager becomes aware that he/she has a site that may trigger the Board’s · review criteria, the manager should notify his/her regional board member, who, in tum, should coordinate the NRRB review meeting date.
The site manager should:

Convey to the regional board member any preferences regarding review timing. The Board tries hard to accommodate the interests ofthe regions and site managers when scheduling reviews.


Provide the site-specific charging number to the Board chair as soon as possible once it has been determined that the site will come before the Board.


Contact the state and any appropriate tribes, Potentially Responsible Parties (PRPs), community groups, or federal facilities to notify them that the site triggers the review criteria. At this time, discuss with these stakeholders the procedures governing their involvement in the review process. A Community Guide is provided in Appendix E. Questions 16-21 of this packet provide additional information on the usual role ofthese parties in the review process.


Prepare a site information package that the Board will use to conduct its review . Question 13 and Appendix A present information on the package and a recommended outline.


Finalize the informational site package at least four weeks before the meeting and provide the package to the relevant regional NRRB member for distribution to Board members in preparation for the site review. The package will be posted on the Board’s Quickr site so that Board members may download it at their convenience. Oversized charts, maps or tables should be mailed to the Board members. The mailing list is available from the Board’s Quickr site. Please note that two additional copies should be mailed to the Board chair for distribution to OSRTI participants.


Prepare a presentation that summarizes the site, proposedremedy, and major issues. See Appendix C for a suggested outline forthe presentation.


Prepare for the meeting by expecting questions that probe beyond the basic information presented in the site information package (e.g., questions about important assumptions, models, peer reviews or tools used in developing key supporting information). Appendix D presents several lists ofquestions typically asked during the review and deliberations.


OPTIONAL: Participate in a pre-meeting conference call two weeks after the Board

receives the site package (i.e., two weeks before the meeting) to give the Board an opportunity to ask clarifying questions regarding the factual infonnation in the site infonnation package and to possibly request more information prior to the board meeting, or as part of the region’s presentation at the board meeting. The pre-meeting conference call should provide feedback to the region prior to the board meeting as to whether the inforn1ation provided is sufficient to support Board discussion and development of key/substantive recommendations. The Board chair and site manager will decide if a pre.call is necessary.
Recognizing that the reviews generally are part of EPA’s internal deliberative process, please label all documents “DRAFT-DELIBERATIVE.”
13. What should be in the site information package?
Appendix A contains a suggested outline for the site infonnation package.
This informational package should be written as a “stand alone” and succinct document that summarizes the key remedy selection issues faced at the site, and explains the regional rationale for choosing its preferred cleanup strategy. Additional detailed documents may be made available for review, at the region’s discretion, through Quickr or the Superfund Document Management System. The Board expects to base its review and any resulting recommendations primarily on this document. Inclusion of clear and well labeled maps, figures and tables usually are critical to the review.
Site managers should develop a site information package that tells the story and explains the rationale of the cleanup decision at the site in question. That is, the package should identify and explain the key remedy selection issues and support the preferred cleanup strategy. The exact content may vary based on site conditions. However, all packages should include summary information such as site background, contaminants and media ofconcern, site characterization, conceptual site model, key modeling land use assumptions and uncertainties, risk analysis, basis for action, the range of alternatives considered, the preferred remedy, arid the preferred remedy cost breakout. For example, if a chosen cleanup level is driven by Applicable or Relevant and Appropriate Requirements (ARARs), the information package should explain the ARAR, why the region believes it is applicable or relevant and appropriate, how it affects the remedy, etc. This information can help reduce or eliminate the need for exploring the subject during the review meeting. The package should contain a summary of the state and/or tribe position(s) on the site, and have attached any technical submissions from states/tribes, PRPs, federal facilities, Natural Resource Trustees, community groups and/or other stakeholders as appropriate. The Board expects to base its review and any resulting recommendations on this package.
The Board recommends that the site manager have the draft package reviewed by regional staff unfamiliar with the site to be sure the package is clear and consistent. Site managers should take advantage of the resources provided by their regional Board members and OSRTI’s remedy decisions branch; they can give advice on preparing for the review, assembling the package, characterizing key issues, and developing appropriate supporting information.
14. What happens at the meeting?
For each site review, the Board meeting typically lasts one full day and is broken into two stages:
i1~(ormation gathering and deliberations. The role ofthe various stakeholders is described in subsequent sections ofthis manual. The site manager should invite state and appropriate tribal representatives to participate in the information-gathering phase. Typically, these representatives do not participate in the deliberative discussion, which the Board limits to EPA personnel.
The site manager begins the information-gathering phase with a short site briefing. Generally, the briefing should not repeat in detail material already presented in the infonnation package. Rather, it should include a brief overview ofthe site and focus on orienting the Board members to the key site features and key remedy selection issues. Following this briefing; state and/or tribal representatives may present their view of key technical issues. Generally, the total length of the presentations should not exceed one hour (typically EPA 45 minutes, state/tribe 15 minutes). The Board usually spends some time after these presentations asking technical or clarifying questions (refer to Appendix 0 for examples). The site manager should be familiar with community, state/tribe, and/or PRP technical comments, as the Board will explore these as appropriate.
Following the briefings and the question/answer session, the Board deliberates for several hours, focusing on whether the proposed cleanup decision is cost effective, technically sound, and otherwise consistent with the NCP and/or supported by the most current program guidance. The Board asks the site manager and other regional staff, as determined by the region, to attend the deliberations for follow-up questions and to ensure the site manager understands the Board’s proposed recommendations. A draft memorandum normally will be developed at the meeting, detailing any Board findings and recommendations.
Following the review meeting (typically within two to four weeks), the Board chair transmits a final draft ofthe recommendations to Board members and the site manager before issuing the final recommendations memorandum documenting any recommendations or comments to the appropriate regional division director. EPA expects to post the recommendations memo on the Board’s web page within 30 days of the chair’s signature.
The Board considers the review to be an internal, deliberative, and (in certain cases) enforcement-sensitive process. Given the nature of the process, the Board defers to regional judgment with respect to releasing documents related to the reviews, and assumes that regions will comport with established relevant Agency policy. The Board expects the region to place the Board recommendations in the site administrative record at the time a proposed plan is published for comment. Regional materials used to support Board reviews (e.g., review packages, briefing materials, and stakeholder memoranda) should also be retained in the regional site-specific administrative record as appropriate.
15. What happens after the meeting?
Regional Response: Regional division directors are asked to respond in writing within a reasonable time frame to the Board chair regarding how the region has or will address board recommendations. As part of this response, the region is asked to describe how the Board’s review has impacted the cleanup process. The site manager is encouraged to submit a draft ofthe regional response to HQ to resolve any remaining issues prior to the issuance of the proposed plan. The site manager should work closely with the Board chair and OSRTI to incorporate the recommendations in the decision documents.
The Board’s existence does not change EPA’s remedy selection process as provided for in CERCLA and the NCP. The regions retain decision making authority as delineated in formal delegations of authority. The Board does not “approve” or “disapprove” regional proposals. However, the Agency expects decision makers to give Board recommendations substantial weight when finalizing cleanup decisions. Ifissues arise regarding incorporation of recommendations into decision documents, the OSRTI office director can request a discussion with the regional division director to resolve them.
Public inquiries and release ofinfonnation: The regions are expected to handle site-specific inquiries related to the reviews. It is .expected that regions will place Board recommendations and regional response memoranda in the site administrative records on or before the date that the region issues proposed plans for public comment. See question 25 for further clarification.
Record keeping: In the case ofboard-related materials, OSRTI maintains the Agency records of pertinent Board-issued documents (e.g., the board memos, operating protocol, etc.). General information, site-specific Board memoranda, and regional responses are available at: http://www.epa.gov/superfund/programs/nrrblindex.htm. EPA regional offices are responsible for retaining all documents prepared for the presentation package either in the site file or administrative record as appropriate (e.g., the site information packages, PRP and stakeholder submissions and any other information used in the Board process related to the cleanup decision in question). This record-keeping policy is consistent with established Agency guidance.
Web page: The recommendations memo will be posted on the Board’s web page within 30 days ofthe chair’s signature. The Board’s web page will also provide a link to the Superfund Site Progress Profile that will provide links to decision documents and the administrative record. PRP and stakeholder position papers should be included in the administrative record.
16. What is the role of the PRP?
The Board and its current process do not alter existing mechanisms for PRP involvement in the remedy selection process. The current process allows the PRP to work closely with the Agency in conducting the RI!FS, including appropriate, periodic meetings between EPA and the PRPs to ensure that issues such as site characterization, treatability of contaminated media, and the feasibility ofdifferent remedial options are fully considered.
When there is a PRP-lead RI!FS, the site manager should notify the PRPs of the pending review as soon as the region identifies the site as a review candidate. At this time, the region should offer the PRPs an opportunity to summarize in writing, 20 pages or less*, any technical issues they believe are pertinent to the cleanup decision, including their recommended approach and rationale for that approach. The site manager should attach the PRP’s summary to the site infonnation package submitted to the Board four weeks before the meeting. PRP submissions should be made part ofthe administrative record.
The region, at its discretion, may solicit comments from PRPs who do not conduct the RI!FS. Generally, the region may do this in cases where PRPs have been substantively involved in RI!FS work and/or remedy selection issues, or if the region believes that PRPs may offer technical comments critical to understanding key remedy selection issues at the site.
Note that those groups that have not been working closely with the Agency early in the remedy selection process will still have the opportunity to comment formally on the proposed action during the proposed plan corriment period.
PRPs are not involved in any direct discussions with the Board nor are they involved in Board meetings or pre-meeting calls. EPA is responsible for preparation of the Board’s review package.
* PRPs may submit up to 40 pages for sites where the estimated remedial action costs exceed $I OOM.
17. Can Potentially Responsible Parties or others nominate sites for Board review?
Site managers may get calls from PRPs or other stakeholders asking whether a site can be nominated for Board review. The Board expects to review only those decisions that meet the review criteria.
18. What is the role of federal facilities?
Consistent with policy established by EPA’s FFRRO, the Board generally treats federal facilities as PRPs for the purpose of Board reviews.
Please refer to “Which sites will the Board review?” for federal facility review criteria.
19. What is the role of the community?
The Board process does not alter existing mechanisms for community involvement in the remedy selection process. The current community engagement process allows the community to work closely with the Agency in conducting the RI/FS, including appropriate, periodic meetings between EPA and the community to ensure that issues such as site characterization, treatability of contaminated media, and the feasibility of different remedial options are fully considered. The site manager may provide the NRRB Community Guide (Appendix E) to interested stakeholders.
At sites where EPA has awarded a Technical Assistance Grant (TAG) or recognized a Community Advisory Group (CAG), the site manager should notify them of the pending review as soon as the region identifies the site as a review candidate. At this time, the region should offer the TAG/CAG groups an opportunity to summarize in writing, 20 pages or less**, any technical issues they believe are pertinent to the cleanup decision, including their recommended approach and rationale for that approach. The site manager should attach this summary to the site information package submitted to the Board four weeks before the meeting. Stakeholder position papers should be included in the administrative record.
Where the site manager has established close working relationships with other stakeholder groups early in the RVFS process, the site manager may offer these groups the opportunity to submit written technical comment at his/her discretion.
** Stakeholders may submit up to 40 pages for sites where the estimated remedial action costs exceed $1OOM.
Note that those groups thathave not been working closely with the Agency early in the remedy selection process will still have the opportunity to comment formally on the proposed action during the proposed plan comment period.
Community members and TAG technical advisors are not involved in any direct discussions with the Board nor are they involved in Board meetings or pre-meeting calls.
20. Are Board discussions open to the general public?
No. The meetings ofthe Board are pre-decisional, deliberative discussions and are not open to the general public. Reviews generally occur before the region issues the proposed plan. The Agency is generally at an early stage in its decision making process when the Board meets to discuss the proposed action. The intent of this early Board review is to offer a critical discussion on key remedy selection and cost effectiveness issues before the Agency formalizes its position on a preferred cleanup strategy. It is important to note that the Board process does not affect EPA’s current procedures for soliciting public comment on proposed cleanup plans.
The recommendations memo will be posted on the Board’s web page within 30 days of the chair’s signature. The Board’s web page will also provide a link to the Superfund Site Progress Profile that will provide links to decision documents and the administrative record. PRP and stakeholder position papers should be included in the administrative record.
21. How do states and tribal governments participate in the reviews?
For each site, the site manager should invite state and appropriate tribal representatives to participate in the information-gathering phase ofthe Board meeting. Typically, these representatives do not participate in the deliberative discussion, which the Board normally limits to EPA personnel; however, they may be invited to participate for a portion ofthe deliberations where the site is a state/tribe-lead fund-financed decision or state/tribe-lead enforcement decision where the state or tribe seeks EPA concurrence. Otherwise, the Board generally limits its deliberative discussion to Agency personnel.
Regional staff should contact the state or tribal representative early in planning for the Board meeting to discuss the background and purpose ofthe Board, the structure ofthe reviews, and to explain how the state/tribe might best prepare for the meeting. The site manager may also provide the Community Guide (Appendix E) to these representatives for further information. At the meeting, the state/tribe is usually offered approximately I 0-15 minutes to speak about their specific issues or concerns.
The region should also offer the state or tribal representatives an opportunity to summarize in writing, 20 pages or less***, any technical issues they believe are pertinent to the cleanup decision, including their rationale and recommended approach for site cleanup. The site manager should attach this summary to the site infonnation package submitted to the Board four weeks before the meeting. Stakeholder position papers should be included in the administrative record.
22. What is the role of contractors?
Generally, govemment contractors can help prepare presentation and package materials but do not participate in presentations or question and answer sessions at board meetings.
23. Does the region convey the Agency’s preliminary views on the remedy in question (i.e., for stakeholders to react to)?
Generally, stakeholders have an opportunity to contribute their views on remedy selection issues, consistent with the NCP and Agency guidance. Site managers should not provide stakeholders with any preliminary indication ofAgency preferences beyond that which the Agency would provide in the absence of the Board’s review.
24. When is it appropriate for Natural Resource Trustee agencies or the Agency for Toxic Substances and Disease Registry to participate in board reviews?
When a Natural Resource Trustee agency or the Agency for Toxic Substances and Disease Registry have formally provided unique or specialized site-specific teclmical or analytical support for the RIIFS in lieu of(or to supplement) regional expertise in a particular area, the region may invite representative(s) to attend the information-gathering phase ofthe review meeting but must inform the Board chair ofthis invitation.
25. When is it appropriate to release Board memoranda and meeting support materials?
The Agency considers the site-specific Board discussion materials, site names, and operable units under consideration to be deliberative and, where appropriate, enforcement confidential. EPA staff should refer questions regarding the nature ofthe Board discussions and findings to the
*** Up to 40 pages may be submitted for sites where the estimated remedial action costs exceed $1OOM.
appropriate regional board member or site manager.
The product of a Board review is typically a memorandum from the Board chair to the appropriate regional division director. While theAgency strives to be as open as possible about Board reviews, in some cases it may be appropriate for the region to withhold the Board’s recommendations memorandum until the region issues the proposed plan. At that point, the region should place the memorandum in the appropriate site administrative record. The region may release publicly its response to Board recommendations at its discretion, taking into account the internal, deliberative nature ofthe NRRB process. EPA will post the recommendations memo to the Board’s web page within 30 days of the chair’s signature. EPA expects that regions will make the regional response available publicly as soon as it is reasonable and appropriate to do so. EPA will also post the regional response on the Board’s web page.
In addition, the NRRB web page will provide the internet link to the Superfund Site Progress Profile that links to the site decision documents and administrative records containing stakeholder and PRP position papers.
26. Where can I find information about other Board reviews?
Site managers are encouraged to visit the NRRB internet site at http://www.epa.gov/superfund/programs/nrrblindex.htm. This publicly accessible site contains basic information about the NRRB and its formation, criteria that triggers NRRB review, contact information for Board members, site-specific review memoranda, and regional responses to Board recommendations. Site-specific review memoranda may also be found in the site administrative record.
27. How are Board members selected?
HQ Offices and Regions will be requested every two years to re-evaluate their representatives on the NRRB to confinn that the members have the needed expertise, experience, and time to actively participate and contribute. The chair will request this reevaluation. The qualifications for NRRB board members are:

Senior Agency managers


Senior policy experts


Senior technical experts


Areas ofexpertise

o Remedy selection

o Cost-effectiveness

o Program implementation

o National consistency

o Applicable or relevant and appropriate requirements

o CERCLA and the NCP

o Superfund policy and guidance


Available to travel at least one week per quarter to discuss proposed remedies


Ability to commit time for a detailed analysis of review packages

o Typically three review packages per quarter


Ability to reach consensus and craft recommendations to promote both consistent and cost-effective decisions at Superfund sites

28. How are recommendations used to benefit the Superfund Program?
Every year the NRRB, in consultation with the regions and OSRTI regional coordinators, will evaluate all the reviews written over that year, looking for recurring issues. OSRTI will work to develop any needed policy, guidance or training materials.
Appendix A
RECOMMENDED OUTLINE
FOR THE SITE INFORMATION PACKAGE

Recommended Outline for the Site Information Package
Inclusion of clear and well labeled maps, tables, and figures with sufficient detail are critical to the review. Time spent by the site manager in preparing the site information package, and additional regional review ofthe draft site information package, is to the advantage of everyone involved in the reviews, as complex site decisions will likely benefit from careful preparation.
It is recommended that an internal review of the draft site infom1ation package be conducted by a colleague that is unfamiliar with the site.
All reference to ROD Guidance Highlights (e.g. ROD Guidance Highlights 6-18 to 6-20) refer to examples found in OSWER Directive 9200.1-23.P, A Guide to Preparing Supe1:{imd Proposed Plans, Records ofDecision, and Other Remedy Selection Decision Documents.
A. Summary (less than five pages)
1) Site Summary

Site name and location


Site account number


Orientation to the key features ofthe site and surrounding area


On site and surrounding land use


Brief site contamination history, and facility operational history


Identify media and primary contaminants of concern (COCs) addressed by this proposed action


List the operable units addressed by this action and the media addressed by each

2) Risk Summary
Good examples ofrisk summary tables to include in the package can be found in ROD Guidance Highlights 6-18 through 6-20.

Identify by medium and operable units, the cumulative risk (if applicable), and land use scenario( s)


Identify by medium and operable units, if applicable, the primary risk drivers

3) Cleanup levels
Include a brief summary table ofremedial action objectives (RAOs) and cleanup levels. If applicable, identify by medium and operable unit (see highlight 6-21 in the ROD Guidance identified in the Risk Summary section).
4) Description of Alternatives
Describe in a brief summary table the following for each medium and operable unit (if applicable):
• Identify remedial alternatives evaluated and associated costs

Identify expected time to achieve cleanup levels 5) Preferred Alternative In bullet fonnat, include the following for each medium and operable unit, if applicable:

• Describe remedy and estimated costs of major activities


Identify expected time to achieve cleanup levels 6) Stakeholder views


State’s position on proposed action


Other stakeholder views

B.
Detailed Information

1) Site N arne, Location, and Brief Description

Include an area map and detailed site maps with well labeled key features. Include an aerial
photograph, if available.
2) Site History and Enforcement Activities
Chronological list of significant enforcement actions, including principal PRPs.

3) Scope and Role of Operable Unit or Response Action
Discuss how the operable unit or response action addressed by the proposed plan fits into the
overall site strategy. This discussion should describe the overall site cleanup strategy, including:


The planned sequence of actions


The scope of problems those actions will address


The authorities under which each action will be/has been implemented (e.g., removal, remedial final, or remedial interim)

4) Site Characteristics

Describe the Baseline Risk Assessment Conceptual Site Model (CSM) on which the risk assessment and response action are based


Provide an overview ofthe site, including the following:
Size of site (e.g., acres)

-Geographical and topographical infonnation (e.g., surface waters, flood plains, wetlands) Surface and subsurface features (e.g., number and volume oftanks, lagoons, structures, and drums on the site)
– Areas of archaeological or historical importance

Describe known or suspected sources of contamination


Describe types of contamination and the affected media (summarize in tables), including the following: -Types and characteristics of contaminants (e.g., toxic, mobile, carcinogenic,

non-carcinogenic) -Quantity/volume ofwaste -Concentrations of contaminants in each medium (see ROD Guidance Highlight 6.
15) and figures that illustrate hot spots, e.g. isopleths
-RCRA hazardous wastes and affected media


Include figures showing contaminant level changes over time


Describe location of contamination and known or potential routes of migration, including the following: Lateral and vertical extent of contamination -Current and potential future surface and subsurface routes ofhuman or environmental exposure

– Conceptual site model of the potential migration pathways of COCs in all media Human and ecological populations that are or could be affected


For sites with groundwater and surface water contamination, describe the following:

-Aquifer(s) affected or threatened by site contamination, types ofgeologic materials, approximate depths, whether aquifer is confined or unconfined Sources and source areas of groundwater and surface water contamination, including information on non-aqueous phase liquid extent, location, and characteristics
– Groundwater flow directions within each aquifer and between aquifers and groundwater discharge locations (e.g., surface waters, wetlands, other aquifers)
– Appropriate maps and cross sections showing stratigraphy and monitoring well
layout
• Identify any computer models used that served as the basis for risk, fate and transport, or ARAR compliance decisions. For non-EPA recommended model applications, list the input parameters: measured data, literature data, and default inputs used in the predicted outputs. Also, include results of model uncertainty and sensitivity analysis for key site parameters.
5) Current and Potential Future Site and Resource Uses:
Land Use

Current on-site land uses


Current adjacent/surroundingland uses


Reasonably anticipated future land uses, with expected time frames for such l!ses, and basis for future use assumptions (e.g., zoning maps, nearby development, 20-year development plans, dialogue with local land use planning officials and citizens).

Ground and Surface Water Use

Current ground/surface water uses on the site and in its vicinity


Potential beneficial ground/surface water uses (e.g., potential drinking water, irrigation, recreational) and basis for future use assumptions (e.g., Comprehensive State Groundwater Protection Plan, promulgated State classification, EPA groundwater classification guidelines)


Ifbeneficial use is an anticipated drinking water source, identify the approximate time frame ofprojected future drinking water use (e.g., groundwater aquifer not currently used as a drinking water source but expected to be utilized in future years)


Location of anticipated use in relation to location and anticipated migration of
contamination.

6) Summary ofRisk1:
Human Health Risk Assessment
• Identify potentially exposed populations in current and future scenarios (e.g., worker
currently working on site, adults and children living on site in the future)

1 The site information package should include a synopsis of the risk assessment(s). Detailed information may be provided by posting documents to the Board’s Quickr site or by providing the Superfund Document Management System document identification number.

Identify sensitive sub-populations (highly exposed and/or more susceptible) that may be exposed (e.g., farm families, children, subsistence fishermen)


Identify the routes by which each population group or sub-population group could reasonably be exposed to site contaminants (e.g., ingestion ofcontaminated groundwater for adults and children, inhalation of volatile contaminants for workers)


Include major assumptions about exposure frequency, duration, and other exposure factors that were included in the exposure assessment (e.g., exposure frequency [days/year], exposure duration [years], and body surface area for dermal exposure) could be included in an appendix


Highlight any non-standard exposure assumptions used in the baseline risk assessments


Provide a summary (preferably a table) that includes the following for all current and future land use scenarios presenting unacceptable risks: -Quantified carcinogenic risks for each COC in each exposure medium for each relevant exposure pathway -Combined carcinogenic risks reflecting total exposure to COCs in a given medium and pathway of exposure -Potential for non-carcinogenic impacts as quantified by the hazard quotient for each COC in each exposure medium for ~ach exposure pathway, as appropriate

-Potential for combined non-carcinogenic effects in each medium and pathway of exposure as expressed by hazard indices, which reflect the potential additive effects of COCs that affect the same target organ or system
– Identify key uncertainties in the baseline risk assessment
• If applicable, describe how radiological risks were calculated .
Ecological Risk Assessment (particularly where these risks drive remedy selection)

What are the assessment endpoints determined to be at risk (the foundation of the
remedial decisions, that is, the risk drivers)?


Which of these risks would require remedial action?


Which site contaminants were determined to be causal and by which exposure routes (i.e., what is the conceptual model/exposure model?).


Describe the thresholds ofexposure generating risk, and at what level ofexposure do the risk levels become severe?


What is the confidence in the risk estimates? Are there documented effects?


_Describe any site-specific data that were available


How large is the area for which ecological risks have been estimated?


Description ofkey species that could be exposed


Describe complete exposure pathways, present the conceptual site model


Monitoring or modeling data and assumptions


The ROD Guidance (Pages 6-22 to 6-25) provides summary tables that would supply the above requested information.

7) Remedial Action Objectives and Preliminary Remediation Goals

Present the basis and rationale for remedial action objectives (RAOs) & preliminary remediation goals (PRGs) (e.g., current and reasonably anticipated future land use and potential beneficial groundwater use)


Describe how the RAOs & PRGs address risks identified in the risk assessment (e.g., how will the risks driving the need for action be addressed by the response action?)


Identify any key ARARs that are driving the remedy selection


Where ecological risks drive the remedy, provide the range of protective cleanup levels and their basis.


Explain how cleanup levels are developed from these goals considering the remedy
selection criteria.


Explain the role ofbackground in the evaluation of cleanup levels.

8) Description of Alternatives:
• Provide a bulleted list and appropriate figures of the major components of each alternative. The package should include the following: -Treatment technologies and materials they will address (e.g., source materials constituting principal threats)
-Containment components ofremedy (e.g., engineering controls, cap, hydraulic barriers) and materials they will address (e.g., low concentration source materials, treatment residuals)
– Description of institutional controls and how they will be implemented and maintained and the duration -For alternatives that depend upon monitored natural attenuation, demonstrate compliance with EPA policy

Provide the total estimated capital, annual operation and maintenance (O&M), and total present worth costs, discount rate, and the number ofyears over which the remedy cost estimates are projected


Summarize the capital and annual O&M costs associated with each of the major
components of each alternative

9) Comparative Analysis of Alternatives
Provide a summary table and discussion comparing alternatives that pass the threshold criteria against the nine criteria.
1 0) Principal Threat Waste Clearly identify how source materials constituting principal threats are addressed or provide an explanation ofwhy the site does not have principal threat waste (refer to A Guide to Principal Threat and LoH’ Level Threat Wastes-OSWER 9380.3-06FS, November 1991).
11) Preferred Alternative

Clearly describe the preferred alternative and how, if appropriate, it is different from the alternatives evaluated


Describe the key factor(s) that led to selecting the preferred alternative (i.e., describe how the remedy provides the best balance oftradeoffs with respect to the balancing and modifying criteria, highlighting criteria key to the decision)

12) Applicable or Relevant and Appropriate Requirements2

List the principal ARARs for the preferred alternative


Describe the ARARs that are drivers for the remedy


For each driver, explain why it is an ARAR (versus a “to be considered”)


Where actual language of the regulation is key to the Board review, include a copy of the relevant section in an appendix to the package

13) Technical & Policy Issues
Include a discussion of technical or policy issues that require further discussion prior to implementation of the preferred alternative (data gathering, ARARs, treatability studies, modeling.
14) Cost Information4

Include sufficient information to provide an estimate of total resource costs over time

(i.e., life cycle costs) for all alternatives including (ROD Guidance Highlight 6-29) -Capital costs -Annual operations and maintenance costs -Net present value of capital and O&M costs


Cost estimate summaries should address the following: -The key cost components/elements for both Remedial Action and O&M activities -The major sources of uncertainty in the cost estimate

2 The site information package should include a synopsis of this infonnation. Detailed information may be provided by posting documents to the Board’s Quickr site or by providing the Superfund Document Management System document identification number.
– The discount rate used
-The time expected to achieve RAOs and remedial goals Periodic capital and/or O&M costs anticipated in future years ofthe project (e.g., remedy replacement or rebuild)
-The methods and resources used for preparing the cost estimate (e.g., estimating guides, vendor quotes, computer cost models)

For contingency remedy decisions, the total project costs for implementing the contingency should be provided in addition to the costs for the conditional action. This estimate should include treatability study costs, if applicable.


The assumptions used to develop the cost estimate should be consistent with the stated RAOs and remedial goals (e.g., duration of the cost estimate should match time to achieve cleanup objectives).

15) Letters from Stakeholders and State
Include in the package any technical comments provided by the state or other stakeholders.
Appendix B
SAMPLE AGENDA FOR THE BOARD MEETING

Sample NRRB Meeting Agenda
8:30-8:45 Introductions
8:45-9:45 Site Presentations (1 0-15 minutes additional time for state/tribal presentations)
9:45-10:00 BREAK 10:00-11:30 Questions & Answers 11:30-12:30 LUNCH
The following sessions are for EPA staff only 12:30-2:15 Deliberations
2:15-2:30 BREAK
2:30-3:00 Board Business (not site-specific)
3:00-5:00 Write and Review Board Recommendations
5:00 ADJOURN
Appendix C
RECOMMENDED OUTLINE
FOR THE BOARD PRESENTATION

Recommended Outline for the Board Presentation
The main emphasis of the presentation, which typically runs one hour in length, should be on the preferred alternative. Hard copies ofthe presentation should be provided for all Board members at the meeting (preferably two slides per page).
Although not reconunended for the presentation, site managers should have key figures available (electronically ifpossible) from the RJJFS and site infonnation package in case of questions during the discussions.
The following suggested times should be used as a guide but are not mandatory:

Site Summary & Risk Summary-I 0


RAO & Description ofAlternatives-I5


Preferred Alternative-25


Stakeholder Views or Presentation-I 0

I) Site Summary

Orientation to the key features of the site and surrounding area (including maps)


On site and surrounding land use


Brief site contamination history, and facility operational history


Identify media and primary COCs addressed by this proposed action


List the other operable units at the site and the media addressed by each

2) Risk Summary

Identify by medium and operable units, the cumulative risk (if applicable), and land use scenario(s)


Identify by medium and operable units, if applicable, the primary risk drivers

3) Remedial Action Objectives and PRGs

Present the basis and rationale for RAOs and PRGs (e.g., current and reasonably
anticipated future land use and potential beneficial groundwater use)


Describe how the RAOs and PRGs address risks identified in the risk assessment (e.g., how will the risks driving the need for action be addressed by the response action?)


Identify any key ARARs that are driving the remedy selection

4) Description of Alternatives Describe in bullet fonnat the following for each medium and operable unit (if applicable):

Briefly identify key components of all remedial alternatives evaluated and associated costs


Identify risk reduction and expected time to achieve cleanup levels

5) Preferred Alternative

Provide a brief summary table or figure that compares all the alternatives, clearly
illustrating the commonality and differences between each alternative


For the preferred alternative, identify for each medium and operable unit: -The rationale and key factors that led to the selection of the preferred alternative -The remedy and estimated costs ofmajor activities

Expected time to achieve cleanup levels
Major technical and other unresolved issues

6) Stakeholder views .

State’s position on the proposed action


Other stakeholder views

Appendix D

QUESTIONS FREQUENTLY ASKED
BY BOARD MEMBERS

Appendix D -Questions Frequently Asked by the NRRB Members
1) NRRB discussion guide
General Groundwater Soil Sediment
Land/Water Use What are future use assumptions for the site? Are the bases for these assumptions clear? Are these assumptions consistent with state/local designations? Have efforts been made to discuss the future use with site owners, local government representatives, and other stakeholders? . What are future use assumptions for groundwater? What are future use assumptions for land? What are future use assumptions for surface water and flood plains?
Was reuse/beneficial use considered for land, water, or treatment residuals, as appropriate?
Exposure Scenarios/Risk Assumptions Are exposure scenarios and risk assumptions reasonable and consistent with future uses? Have the latest toxicity data been used (e.g., PCBs/dioxin)? What are the risk drivers for the site-media, pathways, contaminants? Is remedial action necessary? Has the groundwater/surface water pathway been adequately considered? Has ecological risk been adequately addressed? Has ecological risk been adequately addressed? Where contaminants are bioaccumulative, were appropriate fish/shellfish consumption rates used for risk analysis and are they reasonable?
Remedial Action Objectives & Cleanup Levels What are the RAOs and cleanup levels and do they adequately address risk drivers? Is it clear how cleanup levels were selected? Are RAOs and cleanup levels reasonable and clearly linked to each other? Is it clear whether the goal is restoration and/or containment? What is the expected time frame to meet cleanup levels for groundwater? How were cleanup levels for biota selected? What is the expected time frame to meet cleanup levels for sediment and RAOs for biota? What level of fish/shellfish consumption is the remedy expected to

achieve, and when?
Appendix D-Questions Frequently Asked by the NRRB Members
General Groundwater Soil Sediment
Were a variety of cleanup levels considered? Are the major ARARs identified and are there any special issues? Have the principal threat wastes been identified and does the proposed remedy anticipate treatment or explain why it is not appropriate? Where RAOs for biota will not be met for a long time, have interim goals or benchmarks been identified as appropriate?
Remedy Effectiveness Is the preferred alternative likely to be effective in meeting cleanup levels and RAOs? Are any existing source control actions effective and have any ongoing sources been appropriately incorporated into decision-making? If treatment is proposed, is a pilot necessary and if so, is it proposed? If institutional controls are necessary, are they likely to be effective? Should a contingency remedy be specified and if so, has it been? Does the proposed remedy include monitoring adequate to evaluate remedy effectiveness? Is DNAPL likely to be present? Ifyes: Do cleanup goals adequatel

Post

2012-06-20 – Gravatt, Dan – A look into the murky future of West Lake

West Lake Landfill: bullets for fact sheet Dan Gravatt to: Debbie Kring 06/20/2012 11:05 AM
Debbie, as you requested, here is a look into the murky future of West Lake to assist you with the fact sheet:
-PRPs have agreed to do one additional round of groundwater sampling from all usable/accessible/intact monitoring wells at the site, from OU1 and OU2. Paul Rosasco’s workplan identifies 80 wells that are definitely or probably usable/accessible/intact and will be sampled. Sampling is for uranium, thorium, and radium isotopes, plus metals, VOCs and SVOCs.
-EPA received the PRP’s workplan for the groundwater sampling on June 8, and commented on it. The final workplan is due June 28.
-The PRP’s groundwater sampling work will likely begin in July and last for about a month. Both EPA and MDNR intend to split some of the groundwater samples.
-Following the PRP’s groundwater monitoring fieldwork, EPA will mobilize to the field to re-do surface gamma scans of the OU1 cells, and conduct down-hole gamma logs of the usable/accessible/intact monitoring wells. This should happen in August.
-The PRPs also agreed on June 14th to do additional studies to supplement the SFS, including a detailed study of the partial excavation alternative, other landfill cover designs, apatite treatment evaluations, groundwater fate and transport, and an adjustment to the discount rate in the cost estimate. This work will be handled under a separate work plan (probably an addendum to the original SFS WP) that has not been scoped as yet, though we expect it will take at least a year to complete these additional studies.
-It is my understanding, based on Karl’s directions at our last briefing, that we’ll have a public availability session in December or so to describe to the public the additional sampling and studies that we have planned.
Hope this helps.
Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Pax (913) 551-7063
Principles and integrity are expensive, but they are among the very few things worth having.
D?lit \lliiii~-~ 3.o

Superfund
Dl10/

Post

2012-01-25 – Legare, Amy – NRRB 2012 Meeting Schedule

{In Archive} Fw: NRRB review of Westlake Landfill Craig Smith to: Dan Gravatt 01/25/2012 03:42PM Cc: DeAndre Singletary, Audrey Asher, Robertw Jackson, Cecilia Tapia
Archive: This message is being viewed in an archive.
As Amy said, here is the current schedule of meetings:
~r-:1
FY 2012 NRRB Meeting Calendar.docx
The guidance calls for the review packages as follows, so this may influence the schedule:
“Finalize the informational site package at least four weeks before the meeting and provide the package to the relevant regional NRRB member for distribution to Board members in preparation for the site review. The package will be posted on the Board’s Quickr site so that Board members may download it at their convenience. Oversized charts, maps or tables should be mailed to the Board members. The mailing list is available from the Board’s Quickr site. Please note that two additional copies should be mailed to the Board chair for distribution to OSRTI participants.”
Let me know what looks good.
Thanks, Craig S
Craig W. Smith, P.E. Senior Engineer and Policy Coordinator Superfund Division USEPA Region 7 Kansas City
(913) 551-7683
—–Forwarded by Craig Smith/SUPR/R7/USEPAIUS on 01/25/2012 03:28PM—-.
From: Amy Legare/DC/USEPAIUS· To: Dan Gravatt/R7/USEPAIUS@EPA, Craig Smith/SUPR/R7/USEPAIUS@EPA Cc: Dave Crawford/DC/USEPAIUS@EPA, Gary Worthman/DC/USEPAIUS@EPA Date: 01/25/2012 12:28 PM Subject: NRRB review of Westlake Landfill
Hello all! It is my understanding that the Administrator, Region 7 RA, your DD, and my OD agree that the NRRB should review the remedial action planned for this site. We have some flexibility for when this could happen. We can hold a web conference (not video) during the week of February 13 or 20, or you can join· the already planned meeting the week of March 12 in Chicago. April is difficult due to spring break and we already have a packed meeting the week of April 23. The month of May is wide open. Let me know what works for you.
Here is the Q&A guide for the Board. It contains an outline for the review package and presentation.
§1
Finai.RPM.NRRB.Manual.12.29.11.doc

Amy R. Legare
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U.S. Environmental Protection Agency
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40450137
IIIII/IIIIIIIIIIIIIIII IIIII1111111111 /II/IIIII/III
Superfund
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OSWER/OSRTI/ARD/SARDB 5828 Potomac Yard South MC 5204P 703-347-0124
3/28/2014

Completed Reviews
October 18, 2011 (web conference) Lava Cap OU3 -R9 (consultation)
December 6-7, 2011 -Seattle (NRRB/CST AG -full 2-day meeting) Lower Duwamish -R 1 0
Planned Reviews
March 12-16, 2012-Chicago or Denver Raritan Bay Slag-R2 MEW-R9
March 26-30, 2012-Hanford, WA Tour Hanford 1 00-K Area Hanford 200 UPI Hanford 300 Area
April23-27, 2012-HQ Gowanus Canal-R2 (joint w/ CSTAG) V elsicol -R4 Montross -R9
June 18-22,2012-Philadelphia Ringwood Mine-R2 681h Street Dump -R3 American Creosote-R4
July 23-27, 2012 Sauget Area 2 -R5 Stringfellow-R9 San Gabriel -R9
October 22-26, 2012 Lower Darby -R3 Casmalia -R9
Future Passaic River-R2 (with CSTAG, 2 day meeting) Libby OU4-R8 Portland Harbor-RIO Quendall Terminals-R 10

NATIONAL REMEDY REVIEW BOARD

Questions and Answers for
Superfund Site Managers

December 29, 20 11
1. What is the National Remedy Review Board?
In October 1995, the EPA Administrator announced a collection of initiatives designed to help control remedy costs and to promote consistent and cost-effective Superfund cleanup decisions. As one of these initiatives, the National Remedy Review Board (NRRB, the Board) reviews proposed high-cost cleanup decisions to help evaluate whether they are consistent with current law, regulations, and Agency policy and guidance.
The Board is a technical and policy review group made up of members that have experience with both regional and Headquarters perspectives in the Superfund remedy selection process. Its members include senior managers and technical experts from each EPA region, as well as senior technical and policy experts from other EPA offices. These include the Office of Superfund Remediation and Technology Innovation (OSRTI), Office ofResearch and Development, Office of Radiation and Indoor Air, Federal Facilities Restoration and Reuse Office (FFRRO), Office of Site Remediation Enforcement, and Office ofGeneral Counsel. The Board is chaired by OSRTI.
The Board generally meets quarterly to review proposed decisions that meet its cost-based review criteria. The product of the review is a memorandum sent from the Board to the regional Superfund division director that documents Board recommendations about the proposed cleanup strategy. The Board review process allows full input from EPA regional site managers and other site team members as deemed appropriate by the region whose site is under review. EPA’s site managers are asked to participate in all deliberations to ensure that the Board fully understands the circumstances influencing their proposals.
2. Which sites will the Board review?
Typically, the Board reviews cleanup strategies after the remedial investigation/feasibility study (RVFS) and before the region releases the proposed plan for comment. If necessary, the Board may review sites at other phases of cleanup, possibly before the FS is completed. The Board tries to accommodate regional preferences for scheduling reviews; however, it may not be able to meet all desired regional schedules. It is therefore imperative that site managers work closely with their Board representatives and regional management to schedule sites for review as soon as cost estimates trigger the review criteria outlined below.
Both National Priorities List (NPL) and non-NPL (e.g., “Superfund Alternative”) site actions are reviewed by the Board whenever the Agency expects the work to be done underthe Comprehensive Environmental Response Compensation and Liability Act (CERCLA), in accordance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and other relevant guidance, and when the general criteria below are met. The Board reviews
sites when EPA is directly responsible for the decision or has a concurrence role, including PRP.lead, special account-funded and federal facility-lead sites.
Board Review Criteria
The Board will typically review proposed interim and final Superfund response decisions at both NPL and non-NPL (including Superfund Alternative) sites for which the proposed:

Remedial action costs more than $25 million; or


Non-time critical removal actions (NTCRA), at sites other than a federal facility, is estimated to cost more than $25 million; or

Board reviews will also occur for NPL and non-NPL sites following changes made after the release of the proposed· plan:

A different or modified alternative (which was included in the original proposed plan) is selected by the region that costs more than 20 percent when compared to the original proposal and these costs trigger review criteria (even when the earlier proposed action had undergoneBoard review).


A new alternative is developed and the costs ofthe new alternative would trigger a review.

The Board may review (at regional discretion) sites where the proposed action’s original cost estimate increases more than 20 percent after issuance ofthe Proposed Plan due to either updated cost information or minor changes to the alternative that trigger review criteria. Examples of minor changes are presented in Chapter 7 ofA Guide to Preparing Supe1:(und Proposed Plans, Records ofDecision, and Other Remedy Selection Decision Documents, Office of Solid Waste and Emergency Response Directive No. 9200.1-23P, July 1999 (ROD guidance).
Federal Facility Sites (other than the Department ofEnergy)
Federal facility sites (including Formerly Utilized Sites Remedial Action Program-FUSRAP) follow the same review criteria above with the exception ofNTCRAs; federal facility NTCRAs do not undergo Board review unless requested by the federal facility. Decisions at Base Realignment and Closure (BRAC) sites do not undergo Board review.
Department ofEnergy Sites
The NRRB typically will review sites where the primary contaminant is radioactive waste and · the proposed remedial action costs more than $75 million. The Board will also review NPL sites with NTCRAs exceeding $30 million involving primarily radioactive waste; (per joint Department of Energy/EPA memorandum dated October 5, 1998).
3. Can Regions Request an optional early consultation?
Regions may request an optional NRRB consultation on remedial alternatives at the draft FS scoping stage or any time prior to the draft proposed plan. Regions will not be expected to respond to this early review. Regions should notify states, tribes, local governments, PRPs and local communities when a site will be the subject of an early consultation. Stakeholder, including PRPs, input (up to 10 pages) should be requested as part ofthe early consultation process. This optional consultation will not excuse a site from NRRB review at the proposed plan stage ifthe proposed remedial action meets the NRRB review criteria.
4. Can Regions Request an exemption from Board review?
Regions may request that the NRRB Chair exempt their eligible site from Board review. In addition, Regions can request an exemption in cases where the Region selects a different alternative (after the release of the Proposed Plan for public comment) which costs more than 20 percent from the original proposal and these costs trigger review. The OSRTI office director will make the ‘final exemption decision. The Regional Division Directors can appeal a decision to deny an exemption to the OSRTI Office Director. Regions should offer states, tribes, local governments, PRPs and local communities an opportunity to summarize in writing their opinion regarding the proposed exemption decision. This information will be forwarded to the Board chair along with the exemption request. Regions will not be expected to respond to these letters but will notify the commenters ofthe final decision regarding an exemption.
NRRB Exemption Request Process and Criteria
The region requesting an exemption from an NRRB review should provide a summary of the following information to the Board chair. Exemption requests should not exceed 10 pages.
1.
Site name

2.
Media to be addressed, primary contaminants of concern, preliminary remediation goals

3.
Scope and role of the operable unit or response action

a. Does this action hinge on previous actions?

4.
Risk summary

5.
Remedial action objectives

6.
Alternatives-do they address

a.
TI or MNA?

b.
Treatment of principal threat waste?

c.
Presumptive remedy?

d.
Addressing munitions? (no chemical COCs or groundwater)

7.
Tribal or state ARARs

8.
Stakeholder views

a. Congressional or community controversy?

9.
Decisions requiring headquarters coordination or consultation

a.
Non-time critical removal actions over$ 6M

b.
Remedies for lead, radionuclides, PCBs, asbestos, mercury and dioxin

10.
Concurrence ofregional division director on exemption request

After receipt of the exemption request, the Board chair will hold a conference call with the region to discuss the request. The Board ch~ir will forward the exemption request and recommendation to the OSRTI office director. If the site is a federal facility the FFRRO Board member and office director will participate in the exemption process.
The region should seek input from site stakeholders (e.g., PRPs, states, tribes, and communities) on the request for exemption from NRRB review. Stakeholders may submit up to 10 pages stating their specific issues or concerns. Submissions may be sent to the region or Board Chair at the following address:
Amy Legare
National Remedy Review Board
US EPA
1200 Pennsylvania Ave., NW MC5204P
Washington, DC 20460
Or
Legare.amy@epa. gov
The OSRTI office director will make the final exemption decision after consultation with the regional division director and consideration of stakeholder input.
5. Will the Board review sites with Record of Decision amendments or Explanation of Significant Differences?
Generally, the Board reviews proposed Record of Decision (ROD) amendments where there is a change from the original remedial strategy (e.g., moving from a containment remedy to a treatment remedy) that results in remedial action costs greater than $25 million.
Generally, the Board does not review ROD amendments where the:

Original remedial strategy remains the same (e.g., where the cost increase results from an unexpected increase in contaminated soil volume), even ifthere is an appreciable change in cost (however, the region should consult with their board representative to contlnn review criteria) or


Amendment results in a cost savings.

The Board usually does not review Explanation of Significant Differences unless the region believes the site would benefit from such a review.
6. Will the Board review sites with final Record of Decision following an interim Record of Decision?
Generally, the Board will review final RODs that follow an interim ROD where there are new significant capital costs in addition to the incremental operation and maintenance (O&M) costs associated with the final ROD. When the costs of a planned final ROD (following an interim ROD) exceed the trigger criteria due to costs driven primarily by the interim remedy’s O&M (e.g., the plant is already constructed and the remaining costs are due to long term system operation), the site does not require Board review. In lieu of a Board review, the region should conduct an optimization review, consistent with EPA guidance, before the final remedy is selected. Information on remedy optimization may be found at this linlc http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm
7. Will the Board review proposed sediment actions that are also subject to Headquarters consultation or Contaminated Sediments Technical Advisory Group review under Office of Solid Waste and Emergency Response Directive 9285.6-08, Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites?
Yes. As explained in the Office of Solid Waste and Emergency Response (OSWER) Directive 9285.6-11, OSRTI Sediment Team and NRRB Coordination at Large Sediment Sites, issued on March 5, 2004, review of consultation memos by the OSRTI Sediment Team (for Tier 1 sites) and by the Contaminated Sediment Technical Advisory Group (CST A G) will be coordinated with the Board so that the region receives only one set ofcomments at the time ofthe proposed plan. This process is explained in more detail below.
Tier 1 Sites
For Tier 1 sites that will undergo a NRRB review, the region should include a draft Tier 1 Consideration Memo in the site information package sent to the Board. A copy ofthe Consideration Memo should also be sent to the appropriate OSRTI regional coordinator and to the OSRTI Sediment Team leader. The OSRTI Sediment Team will review the Consideration Memo and the site package, and will provide comments to the chair of the NRRB prior to the Board’s meeting on the site in question. If the draft Proposed Plan is available, it should also be submitted to the OSRTI regional coordinator and the Sediment Team Leader at that time. If it is not available, it should be submitted as soon as it is drafted. The Sediment Team will not submit separate comments on the Consideration Memo to the region.
As part of its response to the NRRB recommendations, the region should include a revised Tier I Consideration Memo that addresses any comments made by the NRRB related to the issues covered by the Memo. If the NRRB chair and OSRTI Sediment Team leader believe that their comments were not appropriately addressed, and after consultation with the OSRTI Regional Branch Chief, the region may be asked to make additional revisions to the Consideration Memo.
Contaminated Sediments Technical Advisory Group Sites
It is anticipated that the proposed remedy for most ofthe large sites being reviewed by the Contaminated Sediment Technical Advisory Group (CSTAG) will also meet the NRRB review requirements. Therefore, a subset ofCSTAG members will participate in the NRRB review. This subset will be selected based on expertise matching the site characteristics. When a site manager prepares the site package for the NRRB it should include a draft Tier 2 Consideration Memo. The memo should document how the region considered all 11 principles when selecting the site’s proposed remedy; the memo should normally be less than 20 pages in length. The site manager will be provided with one set of recommendations from this joint review.
8. What is the role of the Office of Superfund Remediation and Technology Innovation?
OSRTI will assign an ad hoc Board member for each review. The ad hoc member will be assigned based on the area of expertise required for the review. For example: risk assessment, contaminated sediments, radiation, groundwater contamination, or vapor intrusion. In addition, the technical regional coordinator will work closely with the Board chair on all aspects ofthe revtew.
OSRTI will also work to develop any needed policy, guidance or training materials deemed necessary after each annual review of recommendations. For additional infonnation see Question
28.
9. Will the Board review proposed remedies selected pursuant to presumptive remedy guidance?
Yes, unless the review is waived by the Board chair. Regions and regional Board members are encouraged to consult with the Board chair on presumptive remedies to ensure a productive review of t~e proposed remedy.
10. How long does a typical Board review take?
Generally, the review process takes about eight weeks, from the time the Board receives the informational site package until it transmits its recommendations to the region. Regions should consider this additional time in developing the site work plan and Superfund Comprehensive Accomplishment Plan targets. However, regions should also be aware that, in a few cases, Board recommendations may delay site decisions while the regional decision makers consider and respond to Board findings. Also, the region should allow adequate time for preparation of a comprehensive site package. The average preparation time is generally one to two months.
Board reviews are planned for the first month of each quarter of the year. Site managers should notify their regional Board member and the Board chair of the need for a review as soon as possible so the site can be added to the calendar ofplanned reviews. Generally one to two months time is needed to plan a review with travel, hotel, and meeting space accommodations.
11. What does the Board look at when it reviews a cleanup decision?
Generally, the Board analyzes proposed cleanup strategies to help ensure they are consistent with CERCLA, as amended, the NCP, and relevant EPA cleanup guidance. To assist Board members with these reviews, the region prepares a site information package for each site (see additional questions below and Attachment A for more details). Generally, the Board will not be reviewing the draft FS nor the draft decision document.
When the Board reviews a site, the members consider a variety of information, including elements ofthe RIIFS process related to the development of the alternatives and selection ofthe preferred alternative. Site-specific circumstances often influence the nature of the discussion. Please referto Appendix D for questions frequently asked by the Board.
12. What are the site manager’s responsibilities before the meeting?
As soon as the site manager becomes aware that he/she has a site that may trigger the Board’s · review criteria, the manager should notify his/her regional board member, who, in tum, should coordinate the NRRB review meeting date.
The site manager should:

Convey to the regional board member any preferences regarding review timing. The Board tries hard to accommodate the interests ofthe regions and site managers when scheduling reviews.


Provide the site-specific charging number to the Board chair as soon as possible once it has been determined that the site will come before the Board.


Contact the state and any appropriate tribes, Potentially Responsible Parties (PRPs), community groups, or federal facilities to notify them that the site triggers the review criteria. At this time, discuss with these stakeholders the procedures governing their involvement in the review process. A Community Guide is provided in Appendix E. Questions 16-21 of this packet provide additional information on the usual role ofthese parties in the review process.


Prepare a site information package that the Board will use to conduct its review . Question 13 and Appendix A present information on the package and a recommended outline.


Finalize the informational site package at least four weeks before the meeting and provide the package to the relevant regional NRRB member for distribution to Board members in preparation for the site review. The package will be posted on the Board’s Quickr site so that Board members may download it at their convenience. Oversized charts, maps or tables should be mailed to the Board members. The mailing list is available from the Board’s Quickr site. Please note that two additional copies should be mailed to the Board chair for distribution to OSRTI participants.


Prepare a presentation that summarizes the site, proposedremedy, and major issues. See Appendix C for a suggested outline forthe presentation.


Prepare for the meeting by expecting questions that probe beyond the basic information presented in the site information package (e.g., questions about important assumptions, models, peer reviews or tools used in developing key supporting information). Appendix D presents several lists ofquestions typically asked during the review and deliberations.


OPTIONAL: Participate in a pre-meeting conference call two weeks after the Board

receives the site package (i.e., two weeks before the meeting) to give the Board an opportunity to ask clarifying questions regarding the factual infonnation in the site infonnation package and to possibly request more information prior to the board meeting, or as part of the region’s presentation at the board meeting. The pre-meeting conference call should provide feedback to the region prior to the board meeting as to whether the inforn1ation provided is sufficient to support Board discussion and development of key/substantive recommendations. The Board chair and site manager will decide if a pre.call is necessary.
Recognizing that the reviews generally are part of EPA’s internal deliberative process, please label all documents “DRAFT-DELIBERATIVE.”
13. What should be in the site information package?
Appendix A contains a suggested outline for the site infonnation package.
This informational package should be written as a “stand alone” and succinct document that summarizes the key remedy selection issues faced at the site, and explains the regional rationale for choosing its preferred cleanup strategy. Additional detailed documents may be made available for review, at the region’s discretion, through Quickr or the Superfund Document Management System. The Board expects to base its review and any resulting recommendations primarily on this document. Inclusion of clear and well labeled maps, figures and tables usually are critical to the review.
Site managers should develop a site information package that tells the story and explains the rationale of the cleanup decision at the site in question. That is, the package should identify and explain the key remedy selection issues and support the preferred cleanup strategy. The exact content may vary based on site conditions. However, all packages should include summary information such as site background, contaminants and media ofconcern, site characterization, conceptual site model, key modeling land use assumptions and uncertainties, risk analysis, basis for action, the range of alternatives considered, the preferred remedy, arid the preferred remedy cost breakout. For example, if a chosen cleanup level is driven by Applicable or Relevant and Appropriate Requirements (ARARs), the information package should explain the ARAR, why the region believes it is applicable or relevant and appropriate, how it affects the remedy, etc. This information can help reduce or eliminate the need for exploring the subject during the review meeting. The package should contain a summary of the state and/or tribe position(s) on the site, and have attached any technical submissions from states/tribes, PRPs, federal facilities, Natural Resource Trustees, community groups and/or other stakeholders as appropriate. The Board expects to base its review and any resulting recommendations on this package.
The Board recommends that the site manager have the draft package reviewed by regional staff unfamiliar with the site to be sure the package is clear and consistent. Site managers should take advantage of the resources provided by their regional Board members and OSRTI’s remedy decisions branch; they can give advice on preparing for the review, assembling the package, characterizing key issues, and developing appropriate supporting information.
14. What happens at the meeting?
For each site review, the Board meeting typically lasts one full day and is broken into two stages:
i1~(ormation gathering and deliberations. The role ofthe various stakeholders is described in subsequent sections ofthis manual. The site manager should invite state and appropriate tribal representatives to participate in the information-gathering phase. Typically, these representatives do not participate in the deliberative discussion, which the Board limits to EPA personnel.
The site manager begins the information-gathering phase with a short site briefing. Generally, the briefing should not repeat in detail material already presented in the infonnation package. Rather, it should include a brief overview ofthe site and focus on orienting the Board members to the key site features and key remedy selection issues. Following this briefing; state and/or tribal representatives may present their view of key technical issues. Generally, the total length of the presentations should not exceed one hour (typically EPA 45 minutes, state/tribe 15 minutes). The Board usually spends some time after these presentations asking technical or clarifying questions (refer to Appendix 0 for examples). The site manager should be familiar with community, state/tribe, and/or PRP technical comments, as the Board will explore these as appropriate.
Following the briefings and the question/answer session, the Board deliberates for several hours, focusing on whether the proposed cleanup decision is cost effective, technically sound, and otherwise consistent with the NCP and/or supported by the most current program guidance. The Board asks the site manager and other regional staff, as determined by the region, to attend the deliberations for follow-up questions and to ensure the site manager understands the Board’s proposed recommendations. A draft memorandum normally will be developed at the meeting, detailing any Board findings and recommendations.
Following the review meeting (typically within two to four weeks), the Board chair transmits a final draft ofthe recommendations to Board members and the site manager before issuing the final recommendations memorandum documenting any recommendations or comments to the appropriate regional division director. EPA expects to post the recommendations memo on the Board’s web page within 30 days of the chair’s signature.
The Board considers the review to be an internal, deliberative, and (in certain cases) enforcement-sensitive process. Given the nature of the process, the Board defers to regional judgment with respect to releasing documents related to the reviews, and assumes that regions will comport with established relevant Agency policy. The Board expects the region to place the Board recommendations in the site administrative record at the time a proposed plan is published for comment. Regional materials used to support Board reviews (e.g., review packages, briefing materials, and stakeholder memoranda) should also be retained in the regional site-specific administrative record as appropriate.
15. What happens after the meeting?
Regional Response: Regional division directors are asked to respond in writing within a reasonable time frame to the Board chair regarding how the region has or will address board recommendations. As part of this response, the region is asked to describe how the Board’s review has impacted the cleanup process. The site manager is encouraged to submit a draft ofthe regional response to HQ to resolve any remaining issues prior to the issuance of the proposed plan. The site manager should work closely with the Board chair and OSRTI to incorporate the recommendations in the decision documents.
The Board’s existence does not change EPA’s remedy selection process as provided for in CERCLA and the NCP. The regions retain decision making authority as delineated in formal delegations of authority. The Board does not “approve” or “disapprove” regional proposals. However, the Agency expects decision makers to give Board recommendations substantial weight when finalizing cleanup decisions. Ifissues arise regarding incorporation of recommendations into decision documents, the OSRTI office director can request a discussion with the regional division director to resolve them.
Public inquiries and release ofinfonnation: The regions are expected to handle site-specific inquiries related to the reviews. It is .expected that regions will place Board recommendations and regional response memoranda in the site administrative records on or before the date that the region issues proposed plans for public comment. See question 25 for further clarification.
Record keeping: In the case ofboard-related materials, OSRTI maintains the Agency records of pertinent Board-issued documents (e.g., the board memos, operating protocol, etc.). General information, site-specific Board memoranda, and regional responses are available at: http://www.epa.gov/superfund/programs/nrrblindex.htm. EPA regional offices are responsible for retaining all documents prepared for the presentation package either in the site file or administrative record as appropriate (e.g., the site information packages, PRP and stakeholder submissions and any other information used in the Board process related to the cleanup decision in question). This record-keeping policy is consistent with established Agency guidance.
Web page: The recommendations memo will be posted on the Board’s web page within 30 days ofthe chair’s signature. The Board’s web page will also provide a link to the Superfund Site Progress Profile that will provide links to decision documents and the administrative record. PRP and stakeholder position papers should be included in the administrative record.
16. What is the role of the PRP?
The Board and its current process do not alter existing mechanisms for PRP involvement in the remedy selection process. The current process allows the PRP to work closely with the Agency in conducting the RI!FS, including appropriate, periodic meetings between EPA and the PRPs to ensure that issues such as site characterization, treatability of contaminated media, and the feasibility ofdifferent remedial options are fully considered.
When there is a PRP-lead RI!FS, the site manager should notify the PRPs of the pending review as soon as the region identifies the site as a review candidate. At this time, the region should offer the PRPs an opportunity to summarize in writing, 20 pages or less*, any technical issues they believe are pertinent to the cleanup decision, including their recommended approach and rationale for that approach. The site manager should attach the PRP’s summary to the site infonnation package submitted to the Board four weeks before the meeting. PRP submissions should be made part ofthe administrative record.
The region, at its discretion, may solicit comments from PRPs who do not conduct the RI!FS. Generally, the region may do this in cases where PRPs have been substantively involved in RI!FS work and/or remedy selection issues, or if the region believes that PRPs may offer technical comments critical to understanding key remedy selection issues at the site.
Note that those groups that have not been working closely with the Agency early in the remedy selection process will still have the opportunity to comment formally on the proposed action during the proposed plan corriment period.
PRPs are not involved in any direct discussions with the Board nor are they involved in Board meetings or pre-meeting calls. EPA is responsible for preparation of the Board’s review package.
* PRPs may submit up to 40 pages for sites where the estimated remedial action costs exceed $I OOM.
17. Can Potentially Responsible Parties or others nominate sites for Board review?
Site managers may get calls from PRPs or other stakeholders asking whether a site can be nominated for Board review. The Board expects to review only those decisions that meet the review criteria.
18. What is the role of federal facilities?
Consistent with policy established by EPA’s FFRRO, the Board generally treats federal facilities as PRPs for the purpose of Board reviews.
Please refer to “Which sites will the Board review?” for federal facility review criteria.
19. What is the role of the community?
The Board process does not alter existing mechanisms for community involvement in the remedy selection process. The current community engagement process allows the community to work closely with the Agency in conducting the RI/FS, including appropriate, periodic meetings between EPA and the community to ensure that issues such as site characterization, treatability of contaminated media, and the feasibility of different remedial options are fully considered. The site manager may provide the NRRB Community Guide (Appendix E) to interested stakeholders.
At sites where EPA has awarded a Technical Assistance Grant (TAG) or recognized a Community Advisory Group (CAG), the site manager should notify them of the pending review as soon as the region identifies the site as a review candidate. At this time, the region should offer the TAG/CAG groups an opportunity to summarize in writing, 20 pages or less**, any technical issues they believe are pertinent to the cleanup decision, including their recommended approach and rationale for that approach. The site manager should attach this summary to the site information package submitted to the Board four weeks before the meeting. Stakeholder position papers should be included in the administrative record.
Where the site manager has established close working relationships with other stakeholder groups early in the RVFS process, the site manager may offer these groups the opportunity to submit written technical comment at his/her discretion.
** Stakeholders may submit up to 40 pages for sites where the estimated remedial action costs exceed $1OOM.
Note that those groups thathave not been working closely with the Agency early in the remedy selection process will still have the opportunity to comment formally on the proposed action during the proposed plan comment period.
Community members and TAG technical advisors are not involved in any direct discussions with the Board nor are they involved in Board meetings or pre-meeting calls.
20. Are Board discussions open to the general public?
No. The meetings ofthe Board are pre-decisional, deliberative discussions and are not open to the general public. Reviews generally occur before the region issues the proposed plan. The Agency is generally at an early stage in its decision making process when the Board meets to discuss the proposed action. The intent of this early Board review is to offer a critical discussion on key remedy selection and cost effectiveness issues before the Agency formalizes its position on a preferred cleanup strategy. It is important to note that the Board process does not affect EPA’s current procedures for soliciting public comment on proposed cleanup plans.
The recommendations memo will be posted on the Board’s web page within 30 days of the chair’s signature. The Board’s web page will also provide a link to the Superfund Site Progress Profile that will provide links to decision documents and the administrative record. PRP and stakeholder position papers should be included in the administrative record.
21. How do states and tribal governments participate in the reviews?
For each site, the site manager should invite state and appropriate tribal representatives to participate in the information-gathering phase ofthe Board meeting. Typically, these representatives do not participate in the deliberative discussion, which the Board normally limits to EPA personnel; however, they may be invited to participate for a portion ofthe deliberations where the site is a state/tribe-lead fund-financed decision or state/tribe-lead enforcement decision where the state or tribe seeks EPA concurrence. Otherwise, the Board generally limits its deliberative discussion to Agency personnel.
Regional staff should contact the state or tribal representative early in planning for the Board meeting to discuss the background and purpose ofthe Board, the structure ofthe reviews, and to explain how the state/tribe might best prepare for the meeting. The site manager may also provide the Community Guide (Appendix E) to these representatives for further information. At the meeting, the state/tribe is usually offered approximately I 0-15 minutes to speak about their specific issues or concerns.
The region should also offer the state or tribal representatives an opportunity to summarize in writing, 20 pages or less***, any technical issues they believe are pertinent to the cleanup decision, including their rationale and recommended approach for site cleanup. The site manager should attach this summary to the site infonnation package submitted to the Board four weeks before the meeting. Stakeholder position papers should be included in the administrative record.
22. What is the role of contractors?
Generally, govemment contractors can help prepare presentation and package materials but do not participate in presentations or question and answer sessions at board meetings.
23. Does the region convey the Agency’s preliminary views on the remedy in question (i.e., for stakeholders to react to)?
Generally, stakeholders have an opportunity to contribute their views on remedy selection issues, consistent with the NCP and Agency guidance. Site managers should not provide stakeholders with any preliminary indication ofAgency preferences beyond that which the Agency would provide in the absence of the Board’s review.
24. When is it appropriate for Natural Resource Trustee agencies or the Agency for Toxic Substances and Disease Registry to participate in board reviews?
When a Natural Resource Trustee agency or the Agency for Toxic Substances and Disease Registry have formally provided unique or specialized site-specific teclmical or analytical support for the RIIFS in lieu of(or to supplement) regional expertise in a particular area, the region may invite representative(s) to attend the information-gathering phase ofthe review meeting but must inform the Board chair ofthis invitation.
25. When is it appropriate to release Board memoranda and meeting support materials?
The Agency considers the site-specific Board discussion materials, site names, and operable units under consideration to be deliberative and, where appropriate, enforcement confidential. EPA staff should refer questions regarding the nature ofthe Board discussions and findings to the
*** Up to 40 pages may be submitted for sites where the estimated remedial action costs exceed $1OOM.
appropriate regional board member or site manager.
The product of a Board review is typically a memorandum from the Board chair to the appropriate regional division director. While theAgency strives to be as open as possible about Board reviews, in some cases it may be appropriate for the region to withhold the Board’s recommendations memorandum until the region issues the proposed plan. At that point, the region should place the memorandum in the appropriate site administrative record. The region may release publicly its response to Board recommendations at its discretion, taking into account the internal, deliberative nature ofthe NRRB process. EPA will post the recommendations memo to the Board’s web page within 30 days of the chair’s signature. EPA expects that regions will make the regional response available publicly as soon as it is reasonable and appropriate to do so. EPA will also post the regional response on the Board’s web page.
In addition, the NRRB web page will provide the internet link to the Superfund Site Progress Profile that links to the site decision documents and administrative records containing stakeholder and PRP position papers.
26. Where can I find information about other Board reviews?
Site managers are encouraged to visit the NRRB internet site at http://www.epa.gov/superfund/programs/nrrblindex.htm. This publicly accessible site contains basic information about the NRRB and its formation, criteria that triggers NRRB review, contact information for Board members, site-specific review memoranda, and regional responses to Board recommendations. Site-specific review memoranda may also be found in the site administrative record.
27. How are Board members selected?
HQ Offices and Regions will be requested every two years to re-evaluate their representatives on the NRRB to confinn that the members have the needed expertise, experience, and time to actively participate and contribute. The chair will request this reevaluation. The qualifications for NRRB board members are:

Senior Agency managers


Senior policy experts


Senior technical experts


Areas ofexpertise

o Remedy selection

o Cost-effectiveness

o Program implementation

o National consistency

o Applicable or relevant and appropriate requirements

o CERCLA and the NCP

o Superfund policy and guidance


Available to travel at least one week per quarter to discuss proposed remedies


Ability to commit time for a detailed analysis of review packages

o Typically three review packages per quarter


Ability to reach consensus and craft recommendations to promote both consistent and cost-effective decisions at Superfund sites

28. How are recommendations used to benefit the Superfund Program?
Every year the NRRB, in consultation with the regions and OSRTI regional coordinators, will evaluate all the reviews written over that year, looking for recurring issues. OSRTI will work to develop any needed policy, guidance or training materials.
Appendix A
RECOMMENDED OUTLINE
FOR THE SITE INFORMATION PACKAGE

Recommended Outline for the Site Information Package
Inclusion of clear and well labeled maps, tables, and figures with sufficient detail are critical to the review. Time spent by the site manager in preparing the site information package, and additional regional review ofthe draft site information package, is to the advantage of everyone involved in the reviews, as complex site decisions will likely benefit from careful preparation.
It is recommended that an internal review of the draft site infom1ation package be conducted by a colleague that is unfamiliar with the site.
All reference to ROD Guidance Highlights (e.g. ROD Guidance Highlights 6-18 to 6-20) refer to examples found in OSWER Directive 9200.1-23.P, A Guide to Preparing Supe1:{imd Proposed Plans, Records ofDecision, and Other Remedy Selection Decision Documents.
A. Summary (less than five pages)
1) Site Summary

Site name and location


Site account number


Orientation to the key features ofthe site and surrounding area


On site and surrounding land use


Brief site contamination history, and facility operational history


Identify media and primary contaminants of concern (COCs) addressed by this proposed action


List the operable units addressed by this action and the media addressed by each

2) Risk Summary
Good examples ofrisk summary tables to include in the package can be found in ROD Guidance Highlights 6-18 through 6-20.

Identify by medium and operable units, the cumulative risk (if applicable), and land use scenario( s)


Identify by medium and operable units, if applicable, the primary risk drivers

3) Cleanup levels
Include a brief summary table ofremedial action objectives (RAOs) and cleanup levels. If applicable, identify by medium and operable unit (see highlight 6-21 in the ROD Guidance identified in the Risk Summary section).
4) Description of Alternatives
Describe in a brief summary table the following for each medium and operable unit (if applicable):
• Identify remedial alternatives evaluated and associated costs

Identify expected time to achieve cleanup levels 5) Preferred Alternative In bullet fonnat, include the following for each medium and operable unit, if applicable:

• Describe remedy and estimated costs of major activities


Identify expected time to achieve cleanup levels 6) Stakeholder views


State’s position on proposed action


Other stakeholder views

B.
Detailed Information

1) Site N arne, Location, and Brief Description

Include an area map and detailed site maps with well labeled key features. Include an aerial
photograph, if available.
2) Site History and Enforcement Activities
Chronological list of significant enforcement actions, including principal PRPs.

3) Scope and Role of Operable Unit or Response Action
Discuss how the operable unit or response action addressed by the proposed plan fits into the
overall site strategy. This discussion should describe the overall site cleanup strategy, including:


The planned sequence of actions


The scope of problems those actions will address


The authorities under which each action will be/has been implemented (e.g., removal, remedial final, or remedial interim)

4) Site Characteristics

Describe the Baseline Risk Assessment Conceptual Site Model (CSM) on which the risk assessment and response action are based


Provide an overview ofthe site, including the following:
Size of site (e.g., acres)

-Geographical and topographical infonnation (e.g., surface waters, flood plains, wetlands) Surface and subsurface features (e.g., number and volume oftanks, lagoons, structures, and drums on the site)
– Areas of archaeological or historical importance

Describe known or suspected sources of contamination


Describe types of contamination and the affected media (summarize in tables), including the following: -Types and characteristics of contaminants (e.g., toxic, mobile, carcinogenic,

non-carcinogenic) -Quantity/volume ofwaste -Concentrations of contaminants in each medium (see ROD Guidance Highlight 6.
15) and figures that illustrate hot spots, e.g. isopleths
-RCRA hazardous wastes and affected media


Include figures showing contaminant level changes over time


Describe location of contamination and known or potential routes of migration, including the following: Lateral and vertical extent of contamination -Current and potential future surface and subsurface routes ofhuman or environmental exposure

– Conceptual site model of the potential migration pathways of COCs in all media Human and ecological populations that are or could be affected


For sites with groundwater and surface water contamination, describe the following:

-Aquifer(s) affected or threatened by site contamination, types ofgeologic materials, approximate depths, whether aquifer is confined or unconfined Sources and source areas of groundwater and surface water contamination, including information on non-aqueous phase liquid extent, location, and characteristics
– Groundwater flow directions within each aquifer and between aquifers and groundwater discharge locations (e.g., surface waters, wetlands, other aquifers)
– Appropriate maps and cross sections showing stratigraphy and monitoring well
layout
• Identify any computer models used that served as the basis for risk, fate and transport, or ARAR compliance decisions. For non-EPA recommended model applications, list the input parameters: measured data, literature data, and default inputs used in the predicted outputs. Also, include results of model uncertainty and sensitivity analysis for key site parameters.
5) Current and Potential Future Site and Resource Uses:
Land Use

Current on-site land uses


Current adjacent/surroundingland uses


Reasonably anticipated future land uses, with expected time frames for such l!ses, and basis for future use assumptions (e.g., zoning maps, nearby development, 20-year development plans, dialogue with local land use planning officials and citizens).

Ground and Surface Water Use

Current ground/surface water uses on the site and in its vicinity


Potential beneficial ground/surface water uses (e.g., potential drinking water, irrigation, recreational) and basis for future use assumptions (e.g., Comprehensive State Groundwater Protection Plan, promulgated State classification, EPA groundwater classification guidelines)


Ifbeneficial use is an anticipated drinking water source, identify the approximate time frame ofprojected future drinking water use (e.g., groundwater aquifer not currently used as a drinking water source but expected to be utilized in future years)


Location of anticipated use in relation to location and anticipated migration of
contamination.

6) Summary ofRisk1:
Human Health Risk Assessment
• Identify potentially exposed populations in current and future scenarios (e.g., worker
currently working on site, adults and children living on site in the future)

1 The site information package should include a synopsis of the risk assessment(s). Detailed information may be provided by posting documents to the Board’s Quickr site or by providing the Superfund Document Management System document identification number.

Identify sensitive sub-populations (highly exposed and/or more susceptible) that may be exposed (e.g., farm families, children, subsistence fishermen)


Identify the routes by which each population group or sub-population group could reasonably be exposed to site contaminants (e.g., ingestion ofcontaminated groundwater for adults and children, inhalation of volatile contaminants for workers)


Include major assumptions about exposure frequency, duration, and other exposure factors that were included in the exposure assessment (e.g., exposure frequency [days/year], exposure duration [years], and body surface area for dermal exposure) could be included in an appendix


Highlight any non-standard exposure assumptions used in the baseline risk assessments


Provide a summary (preferably a table) that includes the following for all current and future land use scenarios presenting unacceptable risks: -Quantified carcinogenic risks for each COC in each exposure medium for each relevant exposure pathway -Combined carcinogenic risks reflecting total exposure to COCs in a given medium and pathway of exposure -Potential for non-carcinogenic impacts as quantified by the hazard quotient for each COC in each exposure medium for ~ach exposure pathway, as appropriate

-Potential for combined non-carcinogenic effects in each medium and pathway of exposure as expressed by hazard indices, which reflect the potential additive effects of COCs that affect the same target organ or system
– Identify key uncertainties in the baseline risk assessment
• If applicable, describe how radiological risks were calculated .
Ecological Risk Assessment (particularly where these risks drive remedy selection)

What are the assessment endpoints determined to be at risk (the foundation of the
remedial decisions, that is, the risk drivers)?


Which of these risks would require remedial action?


Which site contaminants were determined to be causal and by which exposure routes (i.e., what is the conceptual model/exposure model?).


Describe the thresholds ofexposure generating risk, and at what level ofexposure do the risk levels become severe?


What is the confidence in the risk estimates? Are there documented effects?


_Describe any site-specific data that were available


How large is the area for which ecological risks have been estimated?


Description ofkey species that could be exposed


Describe complete exposure pathways, present the conceptual site model


Monitoring or modeling data and assumptions


The ROD Guidance (Pages 6-22 to 6-25) provides summary tables that would supply the above requested information.

7) Remedial Action Objectives and Preliminary Remediation Goals

Present the basis and rationale for remedial action objectives (RAOs) & preliminary remediation goals (PRGs) (e.g., current and reasonably anticipated future land use and potential beneficial groundwater use)


Describe how the RAOs & PRGs address risks identified in the risk assessment (e.g., how will the risks driving the need for action be addressed by the response action?)


Identify any key ARARs that are driving the remedy selection


Where ecological risks drive the remedy, provide the range of protective cleanup levels and their basis.


Explain how cleanup levels are developed from these goals considering the remedy
selection criteria.


Explain the role ofbackground in the evaluation of cleanup levels.

8) Description of Alternatives:
• Provide a bulleted list and appropriate figures of the major components of each alternative. The package should include the following: -Treatment technologies and materials they will address (e.g., source materials constituting principal threats)
-Containment components ofremedy (e.g., engineering controls, cap, hydraulic barriers) and materials they will address (e.g., low concentration source materials, treatment residuals)
– Description of institutional controls and how they will be implemented and maintained and the duration -For alternatives that depend upon monitored natural attenuation, demonstrate compliance with EPA policy

Provide the total estimated capital, annual operation and maintenance (O&M), and total present worth costs, discount rate, and the number ofyears over which the remedy cost estimates are projected


Summarize the capital and annual O&M costs associated with each of the major
components of each alternative

9) Comparative Analysis of Alternatives
Provide a summary table and discussion comparing alternatives that pass the threshold criteria against the nine criteria.
1 0) Principal Threat Waste Clearly identify how source materials constituting principal threats are addressed or provide an explanation ofwhy the site does not have principal threat waste (refer to A Guide to Principal Threat and LoH’ Level Threat Wastes-OSWER 9380.3-06FS, November 1991).
11) Preferred Alternative

Clearly describe the preferred alternative and how, if appropriate, it is different from the alternatives evaluated


Describe the key factor(s) that led to selecting the preferred alternative (i.e., describe how the remedy provides the best balance oftradeoffs with respect to the balancing and modifying criteria, highlighting criteria key to the decision)

12) Applicable or Relevant and Appropriate Requirements2

List the principal ARARs for the preferred alternative


Describe the ARARs that are drivers for the remedy


For each driver, explain why it is an ARAR (versus a “to be considered”)


Where actual language of the regulation is key to the Board review, include a copy of the relevant section in an appendix to the package

13) Technical & Policy Issues
Include a discussion of technical or policy issues that require further discussion prior to implementation of the preferred alternative (data gathering, ARARs, treatability studies, modeling.
14) Cost Information4

Include sufficient information to provide an estimate of total resource costs over time

(i.e., life cycle costs) for all alternatives including (ROD Guidance Highlight 6-29) -Capital costs -Annual operations and maintenance costs -Net present value of capital and O&M costs


Cost estimate summaries should address the following: -The key cost components/elements for both Remedial Action and O&M activities -The major sources of uncertainty in the cost estimate

2 The site information package should include a synopsis of this infonnation. Detailed information may be provided by posting documents to the Board’s Quickr site or by providing the Superfund Document Management System document identification number.
– The discount rate used
-The time expected to achieve RAOs and remedial goals Periodic capital and/or O&M costs anticipated in future years ofthe project (e.g., remedy replacement or rebuild)
-The methods and resources used for preparing the cost estimate (e.g., estimating guides, vendor quotes, computer cost models)

For contingency remedy decisions, the total project costs for implementing the contingency should be provided in addition to the costs for the conditional action. This estimate should include treatability study costs, if applicable.


The assumptions used to develop the cost estimate should be consistent with the stated RAOs and remedial goals (e.g., duration of the cost estimate should match time to achieve cleanup objectives).

15) Letters from Stakeholders and State
Include in the package any technical comments provided by the state or other stakeholders.
Appendix B
SAMPLE AGENDA FOR THE BOARD MEETING

Sample NRRB Meeting Agenda
8:30-8:45 Introductions
8:45-9:45 Site Presentations (1 0-15 minutes additional time for state/tribal presentations)
9:45-10:00 BREAK 10:00-11:30 Questions & Answers 11:30-12:30 LUNCH
The following sessions are for EPA staff only 12:30-2:15 Deliberations
2:15-2:30 BREAK
2:30-3:00 Board Business (not site-specific)
3:00-5:00 Write and Review Board Recommendations
5:00 ADJOURN
Appendix C
RECOMMENDED OUTLINE
FOR THE BOARD PRESENTATION

Recommended Outline for the Board Presentation
The main emphasis of the presentation, which typically runs one hour in length, should be on the preferred alternative. Hard copies ofthe presentation should be provided for all Board members at the meeting (preferably two slides per page).
Although not reconunended for the presentation, site managers should have key figures available (electronically ifpossible) from the RJJFS and site infonnation package in case of questions during the discussions.
The following suggested times should be used as a guide but are not mandatory:

Site Summary & Risk Summary-I 0


RAO & Description ofAlternatives-I5


Preferred Alternative-25


Stakeholder Views or Presentation-I 0

I) Site Summary

Orientation to the key features of the site and surrounding area (including maps)


On site and surrounding land use


Brief site contamination history, and facility operational history


Identify media and primary COCs addressed by this proposed action


List the other operable units at the site and the media addressed by each

2) Risk Summary

Identify by medium and operable units, the cumulative risk (if applicable), and land use scenario(s)


Identify by medium and operable units, if applicable, the primary risk drivers

3) Remedial Action Objectives and PRGs

Present the basis and rationale for RAOs and PRGs (e.g., current and reasonably
anticipated future land use and potential beneficial groundwater use)


Describe how the RAOs and PRGs address risks identified in the risk assessment (e.g., how will the risks driving the need for action be addressed by the response action?)


Identify any key ARARs that are driving the remedy selection

4) Description of Alternatives Describe in bullet fonnat the following for each medium and operable unit (if applicable):

Briefly identify key components of all remedial alternatives evaluated and associated costs


Identify risk reduction and expected time to achieve cleanup levels

5) Preferred Alternative

Provide a brief summary table or figure that compares all the alternatives, clearly
illustrating the commonality and differences between each alternative


For the preferred alternative, identify for each medium and operable unit: -The rationale and key factors that led to the selection of the preferred alternative -The remedy and estimated costs ofmajor activities

Expected time to achieve cleanup levels
Major technical and other unresolved issues

6) Stakeholder views .

State’s position on the proposed action


Other stakeholder views

Appendix D

QUESTIONS FREQUENTLY ASKED
BY BOARD MEMBERS

Appendix D -Questions Frequently Asked by the NRRB Members
1) NRRB discussion guide
General Groundwater Soil Sediment
Land/Water Use What are future use assumptions for the site? Are the bases for these assumptions clear? Are these assumptions consistent with state/local designations? Have efforts been made to discuss the future use with site owners, local government representatives, and other stakeholders? . What are future use assumptions for groundwater? What are future use assumptions for land? What are future use assumptions for surface water and flood plains?
Was reuse/beneficial use considered for land, water, or treatment residuals, as appropriate?
Exposure Scenarios/Risk Assumptions Are exposure scenarios and risk assumptions reasonable and consistent with future uses? Have the latest toxicity data been used (e.g., PCBs/dioxin)? What are the risk drivers for the site-media, pathways, contaminants? Is remedial action necessary? Has the groundwater/surface water pathway been adequately considered? Has ecological risk been adequately addressed? Has ecological risk been adequately addressed? Where contaminants are bioaccumulative, were appropriate fish/shellfish consumption rates used for risk analysis and are they reasonable?
Remedial Action Objectives & Cleanup Levels What are the RAOs and cleanup levels and do they adequately address risk drivers? Is it clear how cleanup levels were selected? Are RAOs and cleanup levels reasonable and clearly linked to each other? Is it clear whether the goal is restoration and/or containment? What is the expected time frame to meet cleanup levels for groundwater? How were cleanup levels for biota selected? What is the expected time frame to meet cleanup levels for sediment and RAOs for biota? What level of fish/shellfish consumption is the remedy expected to

achieve, and when?
Appendix D-Questions Frequently Asked by the NRRB Members
General Groundwater Soil Sediment
Were a variety of cleanup levels considered? Are the major ARARs identified and are there any special issues? Have the principal threat wastes been identified and does the proposed remedy anticipate treatment or explain why it is not appropriate? Where RAOs for biota will not be met for a long time, have interim goals or benchmarks been identified as appropriate?
Remedy Effectiveness Is the preferred alternative likely to be effective in meeting cleanup levels and RAOs? Are any existing source control actions effective and have any ongoing sources been appropriately incorporated into decision-making? If treatment is proposed, is a pilot necessary and if so, is it proposed? If institutional controls are necessary, are they likely to be effective? Should a contingency remedy be specified and if so, has it been? Does the proposed remedy include monitoring adequate to evaluate remedy effectiveness? Is DNAPL likely to be present? Ifyes: Do cleanup goals adequatel

Post

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

Page 1 of 1
. ”\ Final Groundwater Monitoring SAP and Responses to Comments
_
;~-} ~:ul Rosasco
Dan Gravatt, ‘Muenks, Shawn’
06/29/20 12 03: 13 PM
Cc:
“‘Merrigan, Jessie”‘, “‘Neitzel, Charlotte”‘, “‘Warren, Victoria”‘, “‘Whitby, Kathleen”‘, “‘Golian,
Steven”‘, “‘Ward Herst”‘, “Bob Jelinek”, “‘L FITZGERALD”‘
Hide Details
From: “Paul Rosasco” Sort List…

To: Dan Gravatt/R7/USEPA/US@EPA, “‘Muenks, Shawn”‘

Cc: “‘Merrigan, Jessie”‘ , “‘Neitzel, Charlotte”‘

, “‘Warren, Victoria”‘ ,

‘”Whitby, Kathleen”‘ , “‘Golian, Steven”‘

, “‘Ward Herst”‘ , “Bob Jelinek”

, “‘L FITZGERALD”‘

2 Attachments
SAP-Additional Groundwater Monitoring REVISED. pdf Responses to comments on Groundwater SAP.pdf
Dan and Shawn,
Enclosed please find a revised Sampling and Analysis Plan (SAP) for the Additional Groundwater Monitoring

activities. The document has been amended to address EPA and MDNR comments received on June 18, 2012. I am
also sending each of you a hard copy of the plan via regular mail.
Also enclosed are responses to the EPA and MDNR comments.
Once we receive your approval of the SAP, we will schedule the additional groundwater monitoring activity.

Please contact me if you have any questions or would like to discuss the additional ground_water’!’onito~ing or any
other aspect of the project.
o7/t.; 11111riifiln1~
Superfund
0/401
file:/ //C:/Users/DGRA VATTIAppData/LocaVTemp/notes6D6848/-web0307 .htm 4/29/2014
ENGINEERING MANAGEMENT SUPPORT INC.

72_20 West Jefferson Ave. Suite 406 Telephone (303) 940-3426 Lakewood, CO 80235 Telecopier (303) 940-3422
June 29, 2012
U.S. Environmental Protection Agency Region 7 SUPR I MOKS 901 N. 51h Street Kansas City, Kansas 66101
ATTENTION: Mr. Dan Gravatt
SUBJECT: Sampling and Analysis Plan -Additional Groundwater Monitoring West Lake Landfill Operable Unit 1, Bridgeton, Missouri Revised June 22, 2012
Dear Dan,
During a May 10, 2012 conference call, the U.S. Environmental Protection Agency (EPA) asked the West Lake Landfill Operable Unit-1 (OU-1) Respondents to perform an additional round ofgroundwater sampling at the West Lake Landfill. Engineering Management Support Inc. (EMSI), on behalf of Cotter Corporation (N.S.L.), Bridgeton Landfill, LLC, Rock Road Industries, Inc., and the United States Department of Energy (the OU-1 Respondents), is providing this letter to serve as the Sampling and Analysis Plan (SAP) for that additional groundwater sampling.
EPA has indicated that additional groundwater monitoring is necessary to verify that current groundwater quality is consistent with that characterized during sampling performed in 1995, 1996, and 1997 as part of the Remedial Investigation and in 2004 as part of the Feasibility Study activities for OU-1. This letter describes the relevant project planning documents, proposed monitoring locations, sample collection procedures, analyte list, laboratory analyses, quality assurance/quality control samples and procedures, investigative-derived waste management, health and safety procedures, data evaluation and management procedures, and tentative schedule for the work.
Relevant Project Documents
Prior project planning documents relevant to the proposed groundwater monitoring activities include the following:
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 2

McLaren Hart, 1994, Sampling and Analysis Plan (including Field Sampling Plan and Quality Assurance Project Plan) included as Appendix A to the EPA.approved RIIFS Work Plan, August, 1994.


EMSI, 1997, Amended Sampling and Analysis Plan, February 1997.


Herst & Associates, 2003, Letter from Ward Herst (Herst & Associates) to Dan Wall EPA re: Proposed Supplemental Groundwater Sampling, West Lake Landfill Operable Unit 2, November 5, 2003,


EMSI, 2004, Letter from Paul V. Rosasco (EMSI) to Dan Wall EPA re:
Additional Groundwater Monitoring, February 2, 2004.

Copies of the relevant Standard Operating Procedures (SOPs) used by Herst & Associates for groundwater monitoring activities are included with this submittal. A Health and Safety Plan addressing the specific tasks associated with the proposed groundwater monitoring activities is being prepared by Herst & Associates for use by the field crews.
Monitoring Locations
EPA requested that all of the available OU-1 and OU-2 monitoring wells be sampled as part of this effort.
EMSI retained Herst & Associates, Inc. (Herst) to ·conduct a site inspection and well inventory to ascertain the current number of wells at the site, conditions affecting access to the wells, the condition of the surface portions (protective casing, locks, etc.) of the wells, and the depth to water, total depth and down hole conditions as best as could be determined during collection of depth to water and total depth measurements. The inspection did not include checking whether a pump or other sampling device could be lowered into the wells. Many of the wells are routinely checked by Herst for water levels as part ofongoing groundwater monitoring associated with post-closure care of the permitted solid waste landfill and thus did not need to be re-inspected as part of this effort.
Review of site documents indicated that approximately 115 wells have previously been present at the West Lake site. Figure 1 displays the locations of the various monitoring wells that historically were present at the West Lake Landfill. Table 1 summarizes the current status of the various monitoring wells at the West Lake Landfill. Sixty-eight wells could be located, accessed and appear to be in a condition that is suitable for sampling. Based on the results ofthe well inspection and review of information obtained during prior sampling activities, it was determined that 35 wells have been abandoned, destroyed, are damaged in a manner that would prevent collection of groundwater samples, or were previously reported as missing. Many (14) of these unavailable wells
Additional Groundwater Sampling West Lake Landfill OU-1
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Page 3
were located on property no longer owned by the landfill and subsequently developed by others. The remaining 21 wells were previously reported to have been abandoned, destroyed or lost. The areas around five of the wells that were previously reported to have been abandoned or destroyed were inspected as part of the development of this SAP; however, these inspections failed to locate these wells or any indication that these wells may still exist. Five of the wells were reported (McLaren Hart, 1994) to have been abandoned in October 1992, prior to performance of the Remedial Investigation/ Feasibility Study for OU-1 and OU-2. The areas around three of these wells were inspected and these inspections confirmed that these wells no longer exist. Eight additional wells were previously reported to have been abandoned or destroyed. The areas around these well locations were not inspected. In conjunction with performance of the groundwater sampling, the areas around these wells, and any other wells that were previously reported to have been abandoned/destroyed that were not previously inspected {Table 2), will be inspected to verify that these wells no longer exist. Three wells that were located (S-75, D-87 and MW-103) were determined to have casings that are damaged or obstructed. These three wells will be re-inspected and to the extent practical will be repaired as part of the groundwater sampling effort. The status of the remaining
12 wells could not be determined because the wells could not be located or their locations could not be accessed due to heavy vegetative growth or fencing that restricted access to offsite properties.
Based on the results of the well inspection, it is anticipated that approximately 80 or more wells (68 wells that were inspected and found to be in a condition potentially suitable for sampling plus the additional 12 wells ofunknown status plus the three wells found to have damaged casings) listed in Table 3 are proposed for additional groundwater sampling. The locations of these wells are shown on Figure 2.
Prior to conducting the groundwater sampling effort, vegetation must be cleared to allow for access to these wells. Vegetation clearing will be conducted using a skid steer with a ‘brush hog” attachment and/or manually using toppers or a chain saw as necessary.
Although this SAP anticipates that up to 83 groundwater monitoring wells may be sampled, it is possible that additional wells may be located. Alternatively, it is likely that some of the wells may not be located or may not be susceptible to sampling because of constrictions in or damage to the monitoring well casing resulting in a lesser number of wells for sampling. If such constrictions or damage are present in the above grade, or shallow, subsurface portions of the casing, an attempt will be made by the field crew to repair such damage so as to allow for collection of groundwater samples. In addition to the 83 wells listed on Table 2 and shown on Figure 2, any additional wells that can be located during the groundwater monitoring activities and that are found to be, or that can be made to be suitable for groundwater sampling will also be sampled. In any case, the field crew will endeavor to locate and sample as many of the site monitoring wells as possible.
Additional Groundwater Sampling West Lake Landfill OU-1
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Page4
Sample Collection
Samples will be collected from as many ofthe 83 wells listed in Table 3 that can be accessed and from which samples can be collected. Prior to sample collection, the depth to water and total depth of each well to be sampled will be measured to calculate the volume of standing water iil the well casings (casing volume).
A dedicated Waterra (or equivalent) inertial pump (http://www.waterra.com/index.html) consisting of a Waterra D-25, 2-inch diameter, acetal theimoplastic, standard flow (flow rate up to 1 gallon per minute) foot valve connected to high-density, polyethylene tubing will be installed in each monitoring well that does not already possess a bladder or other type of sampling pump. A Waterra compatible surge block (e.g., Waterra SBD-25), or equivalent, may be added to the foot valve to assist with re-development ofwells that have not been sampled in many years.
The Waterra pump will be used to purge the standing water from the well prior to sample collection. An automatic actuator may be used to produce the oscillating motion required by the Waterra pump. The volume of water removed from each well will be recorded. Purge water will be containerized at each well during well development activities and subsequently transported to and placed into a polyethylene tank(s).
Field parameters including, at a minimum, temperature, pH, and specific conductance, will be monitored using an in-line flow-through chamber during well purging at a minimum of intervals equivalent to one-half of a well casing volume. Well purging will continue until three successive sets of field parameter readings, obtained at intervals equivalent to successive one-half of a well casing volume, indicate stable water quality: specifically three successive temperature readings within 1 degree C, three successive pH readings within 0.2 pH unit, and three successive specific conductance readings within 10% of each other. A sample for laboratory analysis will then be collected regardless of the number of casing volumes removed. In the event that well stabilization cannot be achieved through continued well purging (e.g., field parameters have not stabilized after removal of five casing volumes), a field decision will be made regarding the need for continued well purging versus collection of a sample.
In the case ofmonitoring wells, if any, that are dewatered during well purging, the water level in the subject well will be allowed to recover for 24 hours at which time a sample will be collected. In the event that the water level in a well does not recover sufficiently within 24 hours, the well will continue to be checked periodically during the groundwater sampling activities for the presence of water. If the water level recovers sufficiently to allow for sample collection prior to completion of the groundwater monitoring activities, a sample will be collected from that well. In order to insure that the most important sample fractions are obtained, the order of sample fraction collection will be prioritized as follows: total radio-isotopes sample containers first, dissolved radio-isotopes sample containers second, volatile organic compound (VOC) sample containers third, total trace
Additional Groundwater Sampling West Lake Landfill OU-1
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Page 5
metal sample containers fourth, and dissolved metal sample containers fifth. In the event that a low producing well is selected by EPA and/or MDNR for collection of split samples, the same priority for sample fraction collection will be used with the additional criteria that the radio-isotope sample bottles for the investigative samples to be obtained by Herst & Associates on behalf of EMSI will be filled first followed by the radio-isotope bottles for the split samples to be obtained by EPA or MDNR. Collection of samples for additional analytical fractions (e.g., VOCs) will subsequently be conducted using the same prioritization.
Upon completion of sample collection, the well tubing will be pushed down inside the well and trimmed as necessary to allow for placement of the well cap and securing of the protective casing. If necessary to facilitate subsequent access to the pump tubing, a short length of rope may be secured to the top of the pump tubing with the other end of the rope secured around the inner casing, to the well cap or to the outer casing as determined by the field crew.
Groundwater samples collected for laboratory analysis will placed in the appropriate pre.preserved bottles provided by the analytical laboratories. Samples to be analyzed for dissolved trace metals and radionuclides will be subjected to field filtering prior to placement in the pre-preserved sample bottles.
Chain-of-custody forms will be completed in the field by the sampling crew to document the names of the samplers, the actual samples collected by the sampling crew, the date and time of sample collection, the number and types of sample containers obtained from each well sampled, the type ofpreservation performed on each sample container, and the requested laboratory analyses. Chain-of-custody forms will be completed for each analytical laboratory used for the groundwater monitoring effort.
Laboratory Analyses
The collected samples will be analyzed for uranium (U-238, U-235 and U-234), radium (Ra-226 and Ra-228) and thorium (Th-232, Th-230 and Th-228) isotopes, EPA Target Compund List (TCL) trace metals, TCL volatile organic compounds (VOCs), and TCL semivolatile organic compounds (SVOCs) (please see http://www.epa.gov/superfund/programs/clp/target.htm for a list ofTCL parameters). Radionuclide and trace metal samples will be analyzed for both dissolved (field filtered samples) and total (unfiltered samples) concentrations.
Radio nuclide analyses will be performed by Eberline Laboratory of Oak Ridge, Tennessee. All other analyses will be performed by Test America, either at its Earth City, Missouri laboratory or one of the other Test America laboratories depending upon laboratory capabilities and schedules at the time of sample delivery. Samples to be analyzed by Eberline will be shipped via overnight courier to the Eberline Laboratory in Oak Ridge, Tennessee. Samples to be analyzed by Test America will be delivered
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 6
directly to Test America’s Earth City laboratory for analysis there or shipment via overnight courier to another Test America laboratory, if necessary.
The samples will be analyzed using the following laboratory methods:
Analytes
Thorium isotopes
Uranium isotopes
Radium-226
Radium-228
Trace metals
Volatile organic compounds
Semi-volatile organic compounds
Quality Assurance/Quality Control Analytical Method EML Th-01 EML U-02 EPA 903.0 (Modified to Alpha
Spectroscopy) EPA 904.0 SW-846 6020 SW-846 8260B SW-846 8270C
The following quality assurance/quality control samples will be obtained in the field:

Field duplicate samples -one duplicate sample per every ten investigative samples (duplicate samples will include duplicate sample bottles for all sample analytical fractions);


VQC trip blanks-one sample per every sample container (e.g., cooler) delivered to the laboratory that contains samples for VOC analyses; and


VOC, SVOC and trace metal matrix spike and matrix spike duplicate samples.one of each for every twenty investigative samples.

Additional quality assurance/quality control samples such as method blank samples, laboratory duplicate samples, laboratory control samples, surrogate spike samples, matrix spike and matrix spike duplicate samples will be prepared and analyzed by the analytical laboratories in accordance with the requirements of the analytical methods listed above and the laboratory’s standard operating procedures.
Investigative Derived Materials
Purge water from each monitoring well will be containerized and subsequently transported to and placed into a polyethylene tank(s). Upon completion of the
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 7
groundwater sampling activities, a sample(s) will be obtained from the tank(s) and analyzed for the same analyses as used for the investigative samples plus any additional parameters required by the anticipated disposal facility(ies). It is anticipated that subject to the results of the analyses, the purge water will be collected and disposed by Heritage Environmental Services and/or discharge to the sewer system if approved by the Metropolitan Sewer District (MSD).
Solid waste generated during the sampling activities, including but not limited to well tubing remnants, paper towels, and used gloves will be disposed of at the solid waste transfer facility on site.
Health and Safety
Brush clearing and groundwater sampling activities will be performed by Herst & Associates personnel that have been trained in health and safety procedures for Hazardous Waste Operations and Emergency Response (HAZWOPER). Herst & Associates will prepare a Health and Safety Plan (HSP) that addresses the specific activities to be conducted in conjunction with the groundwater monitoring effort. A copy of the HSP will be provided for information purposes only to all personnel that are present on site in conjunction with the groundwater sampling activities; however, each organization will be responsible for developing and implementing the health and safety procedures necessary for its own personnel. Herst & Associates and EMSI will not be responsible for the health and safety of any personnel other than their own employees.
Data Evaluation and Management
The analytical data will be subject to data validation in accordance with the requirements of the most recent EPA data validation procedure for each analyte group. All of the data will be subject to a Level III data validation plus checks on the laboratory instrument calibration, continuing calibration verification, and internal standards. Based on the results of the data validation effort, additional data qualifiers beyond those applied by the laboratories may be required for the analytical data. A data validation report will be prepared documenting the results of the data validation effort.
The results of the additional groundwater monitoring will be tabulated separately and in conjunction with the results obtained during the RI sampling conducted in 1995, 1996 and 1997 and the FS sampling conducted in 2004. A brief report describing the sampling activities will be prepared and will include the analytical data summary tables described above, the well sampling and purging forms, chain of custody reports, the analytical laboratory reports, and the data validation reports.
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 8
Anticipated Schedule of Activities
One round of groundwater sampling will be performed. Brush clearing activities to provide physical access to the monitoring wells will be scheduled upon receipt of EPA approval of this SAP. Allowing for scheduling and mobilization of vegetation clearing crew, it is anticipated that it will take one to two weeks to complete the brush clearing activities. Groundwater sampling will be initiated within one week of completion of the brush clearing activities. Based on an assumed sample collection rate of five samples per day, it is anticipated that it will take three to four weeks to collect groundwater samples from the approximately 80 wells to be sampled as part of this effort. It is anticipated that it will take approximately three to four weeks for laboratory analyses of the samples. Data validation will take approximately four weeks and data evaluation and report preparation will take another two weeks. Consequently, the total estimated duration of the activities from EPA approval of this SAP until submittal of a sampling report is estimated to be approximately fourteen to seventeen weeks.
If you have any questions or desire additional information related to this SAP or any other aspect of the project, please do not hesitate to contact me.
Sincerely,
ENGINEERING MANAGEMENT SUPPORT, Inc.

ifg::
Paul V. Rosasco, ..
Attachments:

Table 1 -List of Existing and Abandoned Monitoring Wells Table 2 -Reported Abandoned/Destroyed Monitoring Wells to be Inspected Table 3 -List of Monitoring Wells Potentially Available for Sampling
Figure 1 -Current and Prior Groundwater Monitoring Wells Figure 2-Groundwater Monitoring Wells Potentially Suitable for Additional Groundwater Sampling
Herst & Associates Standard Operating Procedures
Additional Groundwater Sampling West Lake Landfill OU-1 6/29/2012 Page 9
Distribution:

Shawn Muenks-Missouri Department of Natural Resources Jessica Merrigan-Lathrop & Gage Kate Whitby-Spencer Fane Britt & Browne Victoria Warren-Republic Services, Inc. Charlotte Neitzel-Bryan Cave HRO Steve Golian -U. S. Department of Energy Ward Herst-Herst & Associates, Inc.
TABLES

Table 1: List of Existing and Abandoned Monitoring Wells by Well Number, West Lake Landfill OU-1 and OU-2
Well Number General Location
S-1 Radiological Area 2
S-5 Radiological Area 1
S-8 Radiological Area 2
S-10 Radiological Area 2
S-51 Closed Leachate Pond
S-52 Closed Leachate Pond
S-53 Closed Leachate Pond
S-54 Inactive Landfill
S-61 Radiological Area 2
S-75 Inactive Landfill
S-76 Inactive Landfill
S-80 Upgradient
S-82 Radiological Area 2
S-84 Radiological Area 1
S-88 Inactive Landfill
1-2 Radiological Area 2
1-4 Radiological Area 1
1-7 Radiological Area 2
1-9 Radiological Area 2
1-11 Radiological Area 2
1-50 Upgradient
1-56 Inactive Landfill
1-58 Inactive Landfill
1-59 Radiological Area 2
1-62 Radiological Area 2
1-65 Radiological Area 2
1-66 Radiological Area 2
1-67 Closed Demolition Landfill
1-68 Radiological Area 1
1-72 Concrete/ Asphalt Plants
1-73 Concrete/ Asphalt Plants
D-3 Radiological Area 1
D-6 Radiological Area 2
D-12 Radiological Area 2
D-13 Radiological Area 2
D-14 Radiological Area 1
D-81 Inactive Landfill
D-83 Radiological Area 2
D-85 Radiological Area 1
D-87 Closed Demolition Landfill
D-89 Inactive Landfill
D-90 Upgradient
D-91 Upgradient
D-92 Closed Demolition Landfill
D-93 Radiological Area 2

Inspected?
No-area overgrown
Yes
No-area overgrown
Yes
No
No
Np
No
Yes
Yes
No
No
Yes
Yes
Yes
No-area overgrown
Yes
No-area overgrown
Yes
Yes
No
Yes
Yes
Yes
No-area overgrown
No-area overgrown
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No-area overgrown
No-area overgrown
Yes
Yes
No
No
No
Yes
Yes
Condition
Unknown
Okay
Unknown
Okay
Destroyed/Abandoned
Destroyed/Abandoned
Destroyed/ Abandoned
Abandoned 10/92
Okay
Casing damaged/obstructed
Abandoned 10/92
Destroyed/ Abandoned
Okay
Okay
Destroyed/Abandoned
Unknown-unable to locate previously
Okay
Unknown
Okay -may be incorrectly labelled
Okay
Destroyed/ Abandoned
Abandoned 10/92
Abandoned 10/92
Abandoned 10/92
Unknown
Unknown
Okay
Okay
Okay
Destroyed/ Abandoned
Okay
Okay
Okay
Okay
Okay
Destroyed/ Abandoned
Unknown
Unknown
Okay
Casing obstructed
Destroyed/Abandoned
Reported as missing in 1994
Reported as missing in 1994
Destroyed/ Abandoned
Okay-may be incorrectly labelled
Page 1 of 3

Table 1: List of Existing and Abandoned Monitoring Wells by Well Number, West Lake Landfill OU-1 and OU-2
Well Number General Location
D-94 Radiological Area 2
LR-100 Inactive Landfill
LR-101 Inactive Landfill
LR-102 Inactive Landfill
LR-103 Inactive Landfill
LR-104 Concrete/ Asphalt Plants
LR-105 Inactive Landfill
MW-101 Radiological Area 2
MW-102 Radiological Area 2
MW-103 Inactive Landfill
MW-104 Inactive Landfill
MW-105 Earth City
MW-106 Upgradient
MW-107 Upgradient
MW-1204 South Quarry
MW-1205 unknown
MW-1206 unknown
MW-FlD North Quarry
MW-FlS North Quarry
MW-F2 Inactive Landfill
MW-F3 Radiological Area 2
PZ-100-SD* North Quarry
PZ-100-SS* North Quarry
PZ-100-KS North Quarry
PZ-101-SS North Quarry
PZ-102-SS North Quarry
PZ-102R-SS North Quarry
PZ-103-SS South Quarry
PZ-104-SD* South Quarry
PZ-104-SS* South Quarry
PZ-104-KS South Quarry
PZ-105-SS* South Quarry
PZ-106-SD* South Quarry
PZ-106-SS* South Quarry
PZ-106-KS South Quarry
PZ-107-SS Inactive Landfill
PZ-108-SS* South Quarry
PZ-109-SS* South Quarry
PZ-110-SS* North Quarry
PZ-111-SD* North Quarry
PZ-111-KS North Quarry
PZ-112-AS Radiological Area 1
PZ-113-AD Closed Demolition Landfill
PZ-113-AS Closed Demolition Landfill
PZ-113-SS Closed Demolition Landfill

Inspected?
No-area overgrown
Yes
Yes
Yes
Yes
Yes
Yes
No-area overgrown
Yes
Yes
Yes
No
No
No
Yes
No
No
No
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Condition Unknown -previous report-damaged Destroyed/ Abandoned Destroyed/ Abandoned Unknown-beneath soil stockpile Okay Okay Okay Unknown Okay Casing damaged/obstructed Okay Destroyed/ Abandoned
De~royed/Abandoned
Destroyed/ Abandoned Okay Abandoned/decomissioned Abandoned/decomissioned Destroyed/ Abandoned Destroyed/ Abandoned
De~royed/Abandoned
Destroyed/ Abandoned Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay Okay
Page 2 of 3

Table 1: List of Existing and Abandoned Monitoring Wells by Well Number, West Lake Landfill OU-1 and OU-2
Well Number General Location Inspected? Condition
PZ-114-AS* North Quarry Yes Okay
PZ-115-SS* North Quarry Yes Okay
PZ-116-SS South Quarry Yes Okay
PZ-200-SS North Quarry Yes Okay
PZ-201A-SS* South Quarry Yes Okay
PZ-202-SS South Quarry Yes Okay
PZ-203-SS South Quarry Yes Okay
PZ-204-SS South Quarry Yes Okay
PZ-204A-SS South Quarry Yes Okay
PZ-205-AS South Quarry Yes Okay
PZ-205-SS* South Quarry Yes Okay
PZ-206-SS Concrete/Asphalt Plants Yes Okay
PZ-207-AS Closed Demolition Landfill Yes Okay
PZ-208-SS North Quarry Yes Okay
PZ-300-AS Upgradient No Destroyed/Abandoned
PZ-300-AD Upgradient No Destroyed/Abandoned
PZ-300-SS Upgradient No Destroyed/Abandoned
PZ-301-SS Upgradient No Destroyed/Abandoned
PZ-302-AI Inactive Landfill Yes Okay
PZ-302-AS Inactive Landfill Yes Okay
PZ-303-AS Inactive Landfill Yes Okay
PZ-304-AI Inactive Landfill Yes Okay
PZ-304-AS Inactive Landfill Yes Okay
PZ-305-AI Concrete/Asphalt Plants Yes Okay
PZ-1201-SS South Quarry Yes Unknown-location buried beneath soil
* Included in monitoring program for the permitted solid waste landfill.

Page 3 of 3

Table 2: Reported Abandoned/Destroyed Monitoring Wells to be Inspected, West Lake Landfill OU-1 and OU-2
Well Number General Location
S-1 Radiological Area 2
S-51 Closed Leachate Pond
S-52 Closed Leachate Pond
S-53 Closed Leachate Pond
S-54 Inactive Landfill
S-76 Inactive Landfill
S-8 Radiological Area 2
S-80 Upgradient
S-88 Inactive Landfill
1-2 Radiological Area 2
1-50 Upgradient
1-56 Inactive Landfill
1-58 Inactive Landfill
1-59 Radiological Area 2
1-62 Radiological Area 2
1-65 Radiological Area 2
1-7 Radiological Area 2
1-72 Concrete/ Asphalt Plants
D-14 Radiological Area 1
D-81 Inactive La!’ldfill
D-83 Radiological Area 2
D-89 Inactive Landfill
D-90 Upgradient
D-91 Upgradient
D-92 Closed Demolition Landfill
D-94 Radiological Area 2
LR-100 Inactive Landfill
LR-101 Inactive Landfill
LR-102 Inactive Landfill
MW-101 Radiological Area 2
MW-105 Earth City
MW-106 Upgradient
MW-107 Upgradient
MW-1205 unknown
MW-1206 unknown
MW-FlD North Quarry
MW-FlS North Quarry
MW-F2 Inactive Landfill
MW-F3 Radiological Area 2
PZ-1201-SS South Quarry
PZ-300-AD Upgradient
PZ-300-AS Upgradient
PZ-300-SS Upgradient
PZ-301-SS Upgradient

Inspected?
No-area overgrown
No
No
No
No
No
No-area overgrown
No
Yes No-area overgrown No
Yes
Yes
Yes No-area overgrown No-area overgrown
No-area overgrown
No
No
No-area overgrown
No-area overgrown
No
No
No
Yes
No-area overgrown
Yes
Yes
Yes
No-area overgrown
No
No
No
No
No
No
No
Yes
No
Yes
No
No
No
No

Condition Unknown-need to clear vegetation Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Abandoned 10/92 Abandoned 10/92 Unknown-need to clear vegetation Destroyed/ Abandoned Destroyed/Abandoned Unknown-unable to locate previously Destroyed/ Abandoned Abandoned 10/92 Abandoned 10/92 Abandoned 10/92 Unknown-need to clear vegetation Unknown-need to clear vegetation Unknown-need to clear vegetation Destroyed/Abandoned Destroyed/ Abandoned Unknown-need to clear vegetation Unknown-need to clear vegetation Destroyed/ Abandoned Reported as missing in 1994 Reported as missing in 1994 Destroyed/ Abandoned Unknown-previous report-damaged Destroyed/ Abandoned Destroyed/ Abandoned Unknown-beneath soil stockpile Unknown-need to clear vegetation Destroyed/Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Abandoned/decomissioned Abandoned/decomissioned Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Unknown-location buried beneath soil Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned Destroyed/ Abandoned
Page 1 of 1

Table 3: List of Monitoring Wells Potentially Available for Sampling, West Lake Landfill OU-1 and OU-2
Well Number General Location
D-12 Radiological Area 2
D-13 Radiological Area 2
D-3 Radiological Area 1
D-6 Radiological Area 2
D-85 Radiological Area 1
1-11 Radiological Area 2
1-4 Radiological Area 1
1-66 Radiological Area 2
1-67 Closed Demolition Landfill
1-68 Radiological Area 1
1-73 Concrete/Asphalt Plants
LR-103 Inactive Landfill
LR-104 Concrete/Asphalt Plants
LR-105 Inactive Landfill
MW-102 Radiological Area 2
MW-104 Inactive Landfill
MW-1204 South Quarry
PZ-100-KS North Quarry
PZ-100-SD* North Quarry
PZ-100-SS* North Quarry
PZ-101-SS North Quarry
PZ-102R-SS North Quarry
PZ-102-SS North Quarry
PZ-103-SS South Quarry
PZ-104-KS South Quarry
PZ-104-SD* South Quarry
PZ-104-SS* South Quarry
PZ-105-SS* South Quarry
PZ-106-KS South Quarry
PZ-106-SD* South Quarry
PZ-106-SS* South Quarry
PZ-107-SS Inactive Landfill
PZ-108-SS* South Quarry
PZ-109-SS* South Quarry
PZ-110-SS* North Quarry
PZ-111-KS North Quarry
PZ-111-SD* North Quarry
PZ-112-AS Radiological Area 1
PZ-113-AD Closed Demolition Landfill
PZ-113-AS Closed Demolition Landfill
PZ-113-SS Closed Demolition Landfill
PZ-114-AS* North Quarry
PZ-115-SS* North Quarry
PZ-116-SS South Quarry
PZ-200-SS North Quarry

Inspected?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Condition
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay

Page 1 of 2

Table 3: List of Monitoring Wells Potentially Available for Sampling, West Lake Landfill OU-1 and OU-2
Well Number General Location
PZ-201A-SS* South Quarry
PZ-202-SS South Quarry
PZ-203-SS South Quarry
PZ-204A-SS South Quarry
PZ-204-SS South Quarry
PZ-205-AS. South Quarry
PZ-205-SS* South Quarry
PZ-206-SS Concrete/ Asphalt Plants
PZ-207-AS Closed Demolition Landfill
PZ-208-SS North Quarry
PZ-302-AI Inactive Landfill
PZ-302-AS Inactive Landfill
PZ-303-AS Inactive Landfill
PZ-304-AI Inactive Landfill
PZ-304-AS Inactive Landfill
PZ-305-AI Concrete/Asphalt Plants
S-10 Radiological Area 2
S-5 Radiological Area 1
S-61 Radiological Area 2
S-82 Radiological Area 2
S-84 Radiological Area 1
D-93 Radiological Area 2
1-9 Radiological Area 2
D-81 Inactive Landfill
D-83 Radiological Area 2
1-62 Radiological Area 2
1-65 Radiological Area 2
1-7 Radiological Area 2
MW-101 Radiological Area 2
S-1 Radiological Area 2
S-8 Radiological Area 2
LR-102 Inactive Landfill
PZ-1201-SS South Quarry
D-94 Radiological Area 2
1-2 Radiological Area 2
S-75 Inactive Landfill
D-87 Closed Demolition Landfill
MW-103 Inactive Landfill

Inspected?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No-area overgrown
No -area overgrown
No-area overgrown
No-area overgrown
No-area overgrown
No-area overgrown
No-area overgrown
No-area overgrown
Yes
Yes
No -area overgrown
No -area overgrown
Yes
Yes
Yes
Condition
Okay
Okay
Okay
Okay
Okay
Okay

Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay
Okay -may be incorrectly labelled
Okay -may be incorrectly labelled
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown
Unknown-beneath soil stockpile
Unknown-buried beneath soil
Unknown-previous report-damaged
Unknown-unable to locate previously
Casing damaged/obstructed
Casing obstructed
Casing damaged/obstructed
* Included in monitoring program for the permitted solid waste landfill.
Page 2 of 2

FIGURES

STANDARD OPERATING PROCEDURES

Standard Operating
Procedures for Groundwater
Sample Collection

Herst & Associates, Inc.
SOP-GW
Revision 4.2

Revised
June 25, 2012

/_ c-[v

~ERST & ASSOCIATES, INC.·l!’
‘.

4631 North St. Peters Parkway St. Charles, Missouri 63304 Telephone: (636) 939-9111 Facsimile: (636) 939-9757
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25.2012 Paqei
TABLE OF CONTENTS

1.0 INTRODUCTION ……………………………………………………………………………………………….. 1

2.0 STATIC GROUNDWATER LEVEL, MONITORING WELL DEPTH, AND MONITORING WELL VOLUME 1
I I I I I I I I!!!!!!!!! I I I I I I I I !IllIll I I I I I I I I I I I I I !Ill I I I I I I I I I IIIII I I I I I I I I I I I II !Ill I I I I I I
2.1 Facility-Wide Depth to Groundwater Measurements …………………………………………… 1

2.2 Monitoring Well Casing Volume Determination ………………………………………………….. 2

3.0 MONITORING WELL PURGING …………………………………………………………………………. 2

3.1 Low Flow Purging ……………………………………………………………………………………………. 3

3.2 Pump Purging …………………………………………………………………………………………………. 3

3.3 Bailer Purging …………………………………………………………………………………………………. 3

4.0 GROUNDWATER SAMPLE COLLECTION …………………………………………………………. 4

5.0 EQUIPMENT CLEANING …………………………………………………………………………………… 5

5.1 Electronic Water Level Indicator Decontamination ……………………………………………… 5

5.2 Non-Dedicated Submersible Impeller Pump Decontamination …………………………….. 5

5.3 Non-Dedicated Submersible Bladder Pump Decontamination …………………………….. 5

6.0 SAMPLE HANDLING …………………………………………………………………………………………. 6

7.0 SAMPLE DOCUMENTATION AND CHAIN-OF-CUSTODY ………………………………….. 6

8.0 FIELD QUALITY CONTROL (QC) SAMPLES ………………………………………………………. 7

8.1 Trip Blank Samples …………………………………………………………………………………………. 7

8.2 Field Blank Samples ………………………………………………………………………………………… 7

8.3 Equipment Blank Samples ……………………………………………………………………………….. 7

8.4 Field Duplicate Samples ………………………………………………………………………………….. 7

8.5 Matrix Spike I Matrix Spike Duplicate Samples …………………………………………………… 8

9.0 FIELD SHEETS I FIELD LOG BOOKS ………………………………………………………………… 8

LIST OF APPENDICES
Appendix A Example Groundwater Elevation Measurements Form Appendix B Example Monitoring Well Condition Report Appendix C Example Field Information Log
Standard Operating Procedures for Groundwater Sample Collection Herst &Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Page1

1.0 INTRODUCTION

The following guidelines describe groundwater sample collection and handling procedures for the Herst & Associates, Inc. personnel. The intent of the Standard Operating Procedures described herein is to provide procedures designed to yield representative and comparable analytical data from each site during each sampiing event.
There are three (3) principal steps in collecting groundwater samples from monitoring wells:
.,. Measuring static groundwater levels;
.,. Evacuating or purging well casings; and
;.. Collecting and preserving samples.
These steps are discussed more completely below.

2.0 STATIC GROUNDWATER LEVEL, MONITORING WELL DEPTH, AND MONITORING WELL VOLUME
2.1 Facility-Wide Depth to Groundwater Measurements
Static depths to groundwater and total depths will be measured at applicable facility monitoring wells and piezometers on the same day, if possible, and prior to purging and sampling of monitoring wells during each monitoring event. Depths to static groundwater levels will be measured from the surveyed mark at the top of the inner casing of each monitoring well. If there is no surveyed mark available at the top of the inner casing, the measurement will be performed on the same side as of the well as the lock on the exterior protective casing. Measurements of depth to groundwater and measurements of total monitoring well depth will be performed with an electronic water level indicator that is graduated in increments of one one-hundredth (1/100) of a foot and provides an audible and visual indication of water contact. Each measurement for depth to groundwater and each measurement for total depth will be performed twice (double-checked) to minimize the potential for false readings. Parts of water level measuring devices that contact groundwater will be thoroughly washed with a non-phosphate detergent (e.g. LiquiNox® or equivalent) followed by a rinse with deionized water or distilled water immediately after each use to minimize the potential for cross-contamination of monitoring wells.
Results of the facility-wide measurements of depth to groundwater will subsequently be used for generation of a potentiometric surface map for the monitoring event. The groundwater elevation in each monitoring well will be determined by subtracting the measured depth to groundwater from the top-of-inner-casing elevation. Appendix A presents an example Groundwater Elevation Measurements form. Additionally, while measuring facility-wide static groundwater depths, Herst & Associates, Inc. personnel will perform an evaluation of each monitoring well and piezometer and record the results of each evaluation on a Monitoring Well Condition Report. Appendix B presents an example Monitoring Well Condition Report.
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Paqe2

2.2 Monitoring Well Casing Volume Determination
The depth to groundwater will be measured immediately prior to monitoring well purging in order to calculate each well’s initial groundwater volume. The difference between the measured total monitoring well depth and depth to static groundwater level is the stabilized height of the groundwater column in the monitoring well. These measurements, taken from the same location on the inner casing described in Section 2.1 during each sampling event, will be used to determine the static monitoring well volume (in gallons) of groundwater in each well per the two (2)-step method described below.
1) The height (H) of the groundwater column is determined by measuring the total depth (TD) of the well and subtracting the measured depth to static water level (MSD).
H (feet) = TD (feet)-MSD (feet)
2) Use the following formula to calculate the static well volume of groundwater:
V =5.875 X 02 X H
Where:
V =Well volume (gallons);
D = Inside well diameter (feet); and
H = Height of groundwater column (feet).

3.0 MONITORING WELL PURGING

Purging monitoring wells prior to sample collection is necessary to remove stagnant groundwater, which may not be representative of in-situ conditions.
Purge parameters including pH, temperature, and specific conductance are monitored I recorded via either flow through cell or via field meters while purging. These purge parameters are measured periodically until purge parameter stabilization is attained according to the following guidelines:
Purge Parameter Stabilization Criteria
pH ± 0.2 standard pH units for 3 successive readings
Specific Conductance + 1 0% for 3 successive readings
Temperature ± 1.0 degree Celsius for 3 successive readings

Additionally, field turbidity will be measured during purging for informational purposes. If non.dedicated pumping equipment is used, the non-dedicated equipment will be cleaned (see Section 5.0, Equipment Cleaning) between use at each monitoring well.
In the event low-flow purging is impractical (limited availability of equipment, etc.), three (3) to five (5) well casing volumes will be purged (if possible) using either pumps or disposable
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Page3
bailers per the procedures described below. Purge parameters will be monitored I recorded similarty to the method described previously. If a monitoring well purges to a point precluding practical sampling (little or no available groundwater), the monitoring well will be completely evacuated of groundwater and allowed to recover for up to twenty-four (24) hours prior to sampling.
If containerization of purged groundwater is not required, then purged groundwater will be discharged to the ground at least fifteen (15) feet away and downslope of the monitoring well. If containerization of purged groundwater is required, then purged groundwater and spent equipment decontamination water (Section 5.0) will be containerized for disposal.
3.1 Low Flow Purging

Low-flow purging (also known as micropurging) is a purging method that has become widely utilized and may be applicable to purging of monitoring wells. This method involves using a pneumatic pump capable of low pumping rates (approximately one (1) liter per minute or less). Low flow purging eliminates the requirement for multiple well casing volume evacuation. Pump discharge rates are regulated and I or controlled to prevent turbulent flow (sample aeration), prevent damage to monitoring well components, and to minimize introduction of sediments into the monitoring well. Monitoring wells purged using low flow purging techniques will be purged as follows:
)or Record pH, specific conductance, and temperature.
)or Periodically monitor the change in groundwater depth in the well and maintain I adjust the pumping rate to minimize drawdown in the well, to the extent practical.
)or Continue pumping at a rate of approximately one ( 1) liter per minute or less until field parameters have stabilized as described in Section 3.0.

3.2 Pump Purging

When a non-dedicated pump is used to either purge three (3) to five (5) well casing volumes from a well or to evacuate the well of groundwater prior to sampling, purging with non.dedicated pumps will proceed as follows:
~ Continue purging groundwater from the well until a minimum of three (3) well casing volumes have been removed and field parameters stabilize.
~ Record the actual volume of groundwater removed.
~ Continue pumping low-recharge wells until at least one (1) well casing volume has been removed and field parameters have stabilized as described in Section 3.0, or until the well is dry.

3.3 Bailer Purging

When a bailer is used to purge a well, disposable polyethylene bailers will be used along with clean rope (nylon I polyester blend or equivalent). Wells will be purged with bailers as follows:
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Page 4
~ Slowly lower the bailer through the water column until the top of the bailer is below the groundwater surface.
).> Retrieve the bailer slowly up the water column and out of the well.
~ Continue removing groundwater from the well until a minimum of three (3) well casing volumes are purged and field parameters stabilize.
~ Record the actual volume of groundwater removed.
).-Continue bailing low-recharge wells until at least one well ( 1) casing volume has been removed and field parameters have stabilized as described in Section 3.0, or until the well is dry.
~ If bailing is selected as the purging and sampling method, one (1) disposable bailer will be used per monitoring well.
4.0 GROUNDWATER SAMPLE COLLECTION

Groundwater monitoring wells will be purged and sampled during each monitoring event by purging and sampling the least impacted well first, followed by the next least impacted well, and proceeding until the most impacted well is sampled last. Determination of which monitoring wells are impacted will be based upon recent historical analytical results for each monitoring well and will be performed prior to Herst &Associates, Inc. mobilization to the site.
For low-flow sampling, samples will be collected after achieving stabilization. For pump sampling and bailer sampling, samples will be collected at monitoring wells that yield three (3) to five (5) casing volumes after achieving stabilization. For a monitoring well that purges dry, samples will be collected as soon as the monitoring well has recharged sufficiently and within 24 hours after the monitoring well has been purged. Regardless of sampling methodology employed (bailers or pumps), care will be taken to avoid sample disturbance and to minimize aeration of samples or groundwater in the wellbore (casing and annulus). Bailers will be retrieved slowly through the water column and carefully emptied directly into the appropriate sample container(s).
Entrained air in sample containers or vials will be eliminated when collecting samples for analyses of Volatile Organic Compounds (VOCs).
Samples are collected in pre-preserved containers provided by the analytical laboratory in order of decreasing sensitivity of each analyte to volatilization. The recommended order of sample collection is listed below.
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Paqe5
Relative Sensitivity
Of Typical Groundwater Quality Constituents

Sample Container Preparation Example Analytes
Hydrochloric Acid Preserved* Decreasing sensitivity VOCs
Nitric Acid Preserved Metals
Sulfuric Acid Preserved 1 Chemical Oxygen Demand
Non-preserved Nutrients

* Samples to be analyzed for VOCs can be collected in unpreserved containers, but doing so reduces the laboratory holding time from fourteen (14) days to seven (7) days.
Collected samples will be immediately placed in insulated coolers with ice. Samples will be maintained with ice until delivered to the analytical laboratory.
5.0 EQUIPMENT CLEANING

The electronic water level indicator will be decontaminated between each monitoring well. Additionally, if utilized, non-dedicated, non-disposable purging and sampling equipment, including bailers and pumps, will be cleaned between wells.
5.1 Electronic Water Level Indicator Decontamination
The electronic water level indicator described in Section 2.0 will be decontaminated between monitoring wells by thoroughly wiping the graduated tape and water-sensing probe tip with a paper towel wetted with a solution of deionized or distilled water mixed with LiquiNox® (or equivalent) followed by thoroughly wiping the graduated tape and water-sensing probe tip with a paper towel wetted with deionized or distilled water. Wiping the water level indicator will be accomplished during removal of the graduated tape and probe tip assembly from the monitoring well.

5.2 Non-Dedicated Submersible Impeller Pump Decontamination
If a non-dedicated submersible impeller-style pump (e.g. Grundfos Redi-flo 2 or equivalent) is used for purging and sampling, the pump body, pump support cable, and sealed electrical wiring will be decontaminated using a three (3) step wash. The first wash will consist of a vessel containing a solution of deionized or distilled water mixed with LiquiNox® (or equivalent). The second and third washes will consist of vessels containing only deionized or distilled water (e.g. first rinse and second rinse). New, disposable polyethylene groundwater discharge tubing for the impeller-style pump will be used to purge and sample each monitoring well. Groundwater discharge tubing will not be decontaminated or reused.

5.3 Non-Dedicated Submersible Bladder Pump Decontamination
If a non-dedicated submersible bladder pump is used for purging and sampling, the pump body and pump support cable will be decontaminated using a three (3) step wash as
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Page6
described above. A new, disposable polyethylene bladder, downhole compressed air conveyance tubing, and groundwater discharge tubing will be used to purge and sample each monitoring well. Disposable bladders, downhole compressed air conveyance tubing, and groundwater discharge tubing will not be decontaminated or reused.

6.0 SAMPLE HANDLING

Sample handling and preservation techniques depend on the parameters to be analyzed. Groundwater samples will be collected, preserved and containerized in their order of sensitivity to volatilization (most sensitive to least sensitive). The purpose of sample preservation is to stabilize parameters of concern by retarding chemical or biological changes. Methods of preservation are generally limited to pH adjustment, chemical addition, and cooling. The order of sample collection is as follows: Volatile Organic Compounds (VOCs), samples preserved with nitric acid (metals), samples preserved with sulfuric acid (Chemical Oxygen Demand) and non-preserved samples (nutrients). Proper preservation will help ensure that samples are representative of the groundwater conditions. Field measurements for indicator parameters (pH, temperature, and specific conductance) will be performed on a portion of the sample that has been placed in a separate container, and not submitted for analyses of other parameters. This procedure avoids cross-contamination of laboratory samples by field instrumentation.
Collected groundwater samples will be maintained on ice in insulated coolers until shipment via courier (e.g. Federal Express) or until direct delivery to the laboratory. Chain-of-custody documentation (described in Section 7.0) will be shipped inside a cooler (if multiple coolers are shipped) to the laboratory. Each cooler shipped or directly delivered to the laboratory will be sealed with a Custody Seal (to verify no sample tampering has occurred) over the cooler opening and enclosed by clear packing tape wrapped several times around the cooler.
7.0 SAMPLE DOCUMENTATION AND CHAIN-OF-CUSTODY
Documentation that accompanies groundwater samples to the analytical laboratory generally includes the following:
~ Chain-of-Custodv lCOC) Records: COC records document in a legally defensible.
manner the history of collection, transport, and transfer of each sample. The
individual who is responsible for the samples from the time of collection to the time of
sample receipt by the laboratory will be documented in the Chain-of-Custody record.
Chain-of-Custody records allow documented tracing of the possession and handling
of individual samples from the time of field collection through laboratory analysis.
Chain-of-Custody documentation will present collected samples in chronological
order.
~ Sample Labels -Prevent misidentification of samples. Sample labels will include the
site name, sampler’s name, well designation, date and time of sample collection,
preservative added, and analysis requested.

In addition, field sheets and/or a field log book are used to document information concerning the collection of each sample from each monitoring point in the groundwater monitoring program. Information in the field sheets and/or field log book, described in Section 9.0,
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 Paqe7
include dates and times of sample collection, well development methods used, weather conditions at the time of sample collection, condition of the wells, and remarks noting any unusual circumstances encountered.
8.0 FIELD QUALITY CONTROL (QC) SAMPLES

Field Quality Control (QC) samples will be collected to verify that sample collection and handling procedures were properly performed and that the procedures have not affected the quality of the groundwater samples. Field QC samples will consist of Trip Blank samples, Field (atmospheric) Blank samples, Equipment Blank samples, Field Duplicate samples, and potentially Matrix Spike I Matrix Spike Duplicate samples.
8.1 Trip Blank Samples

Trip blanks will be analyzed for VOCs only and consist of deionized water samples prepared in appropriate containers by the laboratory and received prior to mobilizing to the site. The trip blank samples then accompany the groundwater samples back to the laboratory for analysis. Preparation and analysis of trip blanks for VOCs indicates if site samples have been affected by transport-induced contamination, and can also be used to assess potential laboratory contamination. One ( 1) trip blank will be included for analysis with each sample shipment containing samples for VOC analysis during each monitoring event.
8.2 Field Blank Samples

Field (atmospheric) blank samples consist of deionized water samples collected in containers at the site during the sampling event and under the same environmental conditions as the monitoring well samples. The analysis of field blank samples can detect the influence of ambient site conditions that may bias the sample suite. One ( 1) field blank sample will be collected per twenty (20) or fewer collected groundwater samples (minimum 5% sample coverage) during each monitoring event.
8.3 Equipment Blank Samples

If non-dedicated, non-disposable purging and sampling equipment is used, the effectiveness of cleaning and decontamination procedures will be verified by the collection and analysis of equipment blank samples. After equipment decontamination is performed, an equipment blank sample is prepared by filling the purging and sampling device(s) with deionized water, followed by collection of the water into sample containers. Equipment blanks will be handled and analyzed in the same manner as collected groundwater samples. Equipment blank samples are not required if either dedicated purging and sampling equipment is used or disposable equipment (e.g. disposable bailers) is used. If non-dedicated purging and sampling equipment (e.g. non-dedicated pump) is used, one (1) equipment blank will be collected per twenty (20) or fewer collected groundwater samples (minimum 5% sample coverage) during each monitoring event.
8.4 Field Duplicate Samples

A field duplicate sample is collected from a monitoring well concurrently with collection of the primary groundwater sample from that well, and in an identical fashion. Analysis of field
Standard Operating Procedures for Groundwater Sample Collection Herst & Associates. Inc. SOP-GW Rev. 4.2 Revised June 25. 2012 PageS
duplicate samples provides an indication of the variability in analytical results associated with sample collection procedures and laboratory procedures. One ( 1 ) field duplicate sample will be collected per twenty (20) or fewer collected groundwater samples (minimum 5% sample coverage) during each monitoring event:
8.5 Matrix Spike I Matrix Spike Duplicate Samples
Matrix Spike I Matrix Spike Duplicate (MS I MSD) samples are collected from a monitoring well concurrently with collection of the primary groundwater sample from that well, and in an identical fashion. Alternatively, the analytical laboratory may elect to split a received primary groundwater sample into multiple portions and perform MS I MSD analysis on a separate portion of the sample. Once received by the analytical laboratory, a known quantity of target analyte is added to the MS I MSD samples by the laboratory analyst prior to analysis. Analysis of MS I MSD samples provides an indication of the effects of the groundwater matrix on analytical results. One (1) MS I MSD sample pair will be collected per twenty (20) or fewer collected groundwater samples (minimum 5% sample coverage) during each monitoring event.

9.0 FIELD SHEETS I FIELD LOG BOOKS

Field sheets (also called Field Information Logs) and I or field log books will be maintained during each groundwater sampling event. Field Information Logs I field log books will include field observations and well developing, well purging, and well sampling details. Additionally, the following information will be documented on Field Information Logs I field log books:
.,. Site name;
);. Site well designation;
, Sample collector’s name and affiliation (i.e., landfill, laboratory, or contract personnel);
J;> Weather conditions encountered during sampling (such as rain) that could affect
sample quality;
.,_ Pre-purging depth to water, measured from top of inner casing;
.,_ Total depth of well installation, measured from top of inner casing;
J;> Wetted casing or borehole volume;
);. Starting and ending times for well purging;
};> Purging rate (if low-flow purging or pump purging);
.,_ Depth to water measurement after sample collection; and,
.,_ Sample collection date and time.

A blank example field sheet is provided as Appendix C.

Global Presence Personal Attention
·~RST & ASSOCIATES, INC.
GROUNDWATER ELEVATION MEASUREMENTS
Site:
Personnel:

Page of
Herst & Associates, Inc. 4630 South Highway 94 -North Outer Road, St. Charles, MO 63304 (636) 939-9111 (636) 939-9757 fax

Global Presence
Personal Attention

#,_RST & ASSOCIATES, INC.’

GROUND WATER MONITORING WELL CONDITION REPORT

Field Certification:_….,…—-“~–:———-“””””:;~——-‘———-=–:——-.Signed Title Date
Herst & Associates, Inc. 4630 South Highway 94-North Outer Road, St. Char1es, MO 63304 (636) 939-9111 (636) 939-9757 fax

Global Presence Personal Attention
~RST& ASSOCIATES, INC’

FIELD INFORMATION LOG Part 1
Sample Point ID:
Facility: —————-.Location: Sampler(s): Sample Matrix: Top of Casing (ft, msl)
PURGE INFORMATION:
Method of Well Purge: Dedicated Equipment: Yes ___ No ___
DatefTime Initiated: Casing Diameter (inches):
Initial Water Level (feet): One Casing Volume (gal):
Initial Water Level Previous Event (feet): _______ One Casing Volume Previous Event (gal):
Ground Water Elevation (ft, msl): Total Yolume Purged (mL):
Ground Water Elevation Previous Event (ft, msl): —-Purged Dry?: Yes ___ No
Well Total Depth (feet): Water Level after Purge (feet):
Well Total Depth Previous Event (feet): DatefTime Completed:
PURGE DATA:
Time !-‘urge Kate (Hz/gpm) cumu1at1ve Volume (!lall Temp c·c> pH (std units) conductlvJty

Post

2012-07-10 – Monthly Status Report – June 2012 West Lake Landfill Operable Unit 1, Bridgeton, Missouri

ENGINEERING MANAGEMENT SUPPORT INC.

7220 West Jefferson Avenue, Suite 406 Telephone (303)940-3426
Lal

Post

2012-07-13 – Comments on Draft Gamma-Scanning QAPP review

Re: West Lake Landfill: Draft gamma-scanning QAPP for review CharlesA Hooper to: Dan Gravatt 07/13/2012 03:33PM
Dan,
Here are some things to consider, and I’ve got the track changes on to see the changes I had to the QAPP:
Looks like you’ve got a good number of background wells-good. But I see there’s no groundwater sampling?
Also, On the surface scan you might add traversing one way at a certain distance along parallel lines, and then traverse at a 90 degree angle to that so you get a more complete scan. There’s also probably areas that someone will have to walk amongst thick brush,etc. In those areas you might not get a good gps read, but that’s to be expected in the brush.
Consider sending the QAPP to Gregg Dempsey (ORIA-Las Vegas) and Stuart Walker before its final, it might be a good idea to touch base with them before the field work. Gregg may even have some staff that can participate. There cost is usually only travel.
Is there going to be a water level measurement? I’m not sure if the water level will impact the count rate, it shouldn’t, but I just don’t know.
Are there any known or anticipated contaminants in these wells of a chemical or toxic nature from the old landfill that would warrant using any additional ppe or decon methods? E.g., is there a need to check PID readings at wells, etc?
I’ve noted on page 7 to take a 6-sec counts for each 1-foot measurement. That way the measurement is 1/1 Oth of a 1-min count. Just something to consider, it might be easier to do that instead of waiting for a number on the meter to stop jumping around.
Hope this is helpful, -Chuck
~
West Lake Gamma Scan QAPP _CH.doc
Chuck Hooper Radiation Safety Officer US EPA, Region 7 901 North 5th Street Kansas City, Kansas 66101
(913) 551-7271 office Hooper.CharlesA@epa.gov
—————··-· -· -··–.
Dan Grav!’!_t!_______ ·-·-···–Diar1e, Chuck,_DeAndre, Att_<3~he_d)? adraftQA... o7t11t?o1?_o:3:33:1 oPM From: Dan GravatUR7/USEPA/US To: Dianee Harris/R7/USEPAIUS@EPA, CharlesA Hooper/R7/USEPAIUS@EPA, DeAndre Singletary/SUPR/R7/USEPAIUS@EPA Date: 0711112012 03:33 PM Subject: West Lake Landfill: Draft gamma-scanning QAPP for review 071 tt 11~~~~~ii~m1 Superfund Diane, Chuck, DeAndre, Attached is a draft QAPP to cover the upcoming in-house gamma scanning fieldwork at West Lake. Please review and comment. Sincerely, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063 Principles and integrity are expensive, but they are among the very few things worth having. [attachment "West Lake Gamma Scan QAPP.doc" deleted by CharlesA Hooper/R7/USEPAIUS] Al -Title and Approval Quality Assurance Project Plan Surface Gamma Scans and Down-hole Gamma Logs West Lake Landfill OUl Bridgeton, Missouri July, 2012 Diane Harris Date: Quality Assurance Manager DeAndre Singletary, Chief Date: MOKS Branch SUPR Division, EPA Region 7 Dan Gravatt, RPM Date: MOKS Branch SUPR Division, EPA Region 7 A2 -Table of Contents A 1. Title and Approval A2. Table of Contents A. Project Management .................................................................................................................. 3 A3. Distribution List ......................................................................................................•.... 3 A4. Project/Task Organization ............................................................................................ 3 AS. Problem Definition/Background .................................................................................. 3 A6. Project/Task Description ............................................................................................. .4 A7. Quality Objectives and Criteria for Measurement Data ............................................... 5 AS. Special Training Requirements/Certification ............................................................... 6 A9. Documentation and Records ........................................................................................ 6 B. Measurement/Data Acquisition .................................................................................................. 6 B1. Sampling Process Design ............................................................................................. 6 B2. Sampling Methods Requirements ................................................................................ 7 B3. Description ofDecontamination Procedures for Sampling Equipment.. ..................... 7 B4. Sample Handling and Custody Requirements .............................................................. 7 B5. Analytical Methods Requirements ............................................................................... 7 B6. Quality Control Requirements ...................................................................................... 8 B7. Instrument/Equipment Testing, Inspection, and Maintenance Requirements .............. 8 BS. Instrument Calibration and Frequency ......................................................................... 8 B9. Inspection/Acceptance Requirements for Supplies and Consumables ........................ 8 BlO. Data Acquisition Requirements ................................................................................. 8 B11. Data Management ...................................................................................................... 8 C. Assessment/Oversight ................................................................................................................ 8 C1. Assessments and Response Actions ............................................................................. 8 C2. Reports to Management ............................................................................................... 9 D. Data Validation and Usability ...................................................................... : ............................. 9 Dl. Data Review, Validation, and Verification Requirements ........................................... 9 D2. Validation and Verification Methods ........................................................................... 9 D3. Reconciliation with User Requirements ......................................................9 Abbreviations and Acronyms Figure 1: OU1 Extents and Monitoring Well Locations Appendix A Field SOPs A. Project Management A3. Distribution List This quality assurance project plan (QAPP) is prepared for the West Lake Landfill site in Bridgeton, Missouri, and is submitted as documentation of the protocols and procedures to be followed during collection of surface and down-hole gamma scans at the site. Distribution of this plan will be as follows: Dan Gravatt, RPM, MOKS/SUPR, U.S. EPA Region 7 Diane Harris, RQAM/ENSV, U.S. EPA Region 7 A4. Project/Task Organization This project is being managed and administered by EPA Region 7 according to the responsibilities described below: Dan Gravatt, RPM Project Manager MOKS Branch/SUPR Division (913) 551-7324 Responsibilities: Project Management; Field Team Leader; Field Data Collection Project Design and Implementation OSCs (to be determined) ERNB and/or ERSB branches Responsibilities: Field data collection AS. Problem Definition/Background The purpose of this QAPP is to support the collection of surface and down-hole gamma scans. The objective of this work is to collect additional data on the distribution ofradionuclides within Operable Unit 1 (OU1). Surface gamma scans and down-hole gamma scans ofboreholes were conducted as part of the Remedial Investigation (RI) for the site in the late 1990s, and the data was summarized in the RI Report (EMSI, April 2000). Work under this QAPP will re-scan the surfaces ofboth areas of OU 1 for gamma emissions, as well as scanning all accessible monitoring wells at the site for gamma emissions. Some ofthe monitoring wells were previously scanned (as boreholes, prior to their completion as wells) during the RI, and some have never been scanned. Gamma scanning field work will be performed by the RPM and OSCs using field.portable scanning instruments. No samples of any media will be collected. A6. Project/Task Description The objective of this study is to collect additional data on the distribution ofradionuclides within OUl. This QAPP addresses field procedures to collect the surface and down-hole gamma scan data. The measurement and data acquisition methods specified below have been selected to meet this objective. Figure 1 illustrates the site layout and monitoring well locations for down.hole scans. The data from this study will be assembled and provided to Dan Gravatt, RPM, MOKS/SUPR Division, U.S. EPA Region 7. A6.1 Work to be performed The scope offield activities to be performed for these gamma scans includes the following: • Scanning the surface ofOUl with a Ludlum Model2241-3 and Nal Tl detector; and • Scanning all accessible and intact monitoring wells associated with OU1 and OU2 with a Ludlum Model2241-3 and Ludlum 44-62 Nal probe to the maximum depth of the well or 150 feet, whichever is lessgreater. (1) Measurements (a) Areas and monitoring wells to be sampled All accessible portions of the surface ofOUl will be scanned with the Ludlum Model 2241-3 and its Nal Tl detector. It is anticipated that vegetation or rubble piles may prevent scanning of portions of Area 2 of OU1. All accessible and intact monitoring wells on-site capable ofpassing the Ludlum 44-62 Nal down-hole probe will be scanned. (b) Analyses Both the Ludlum Model2241-3 with Nal Tl detector and the Ludlum 2241-3 with 44-62 Nal probe will collect real-time data on gamma intensity. No laboratory samples will be collected or analyzed. (2) Standards/Criteria As gamma scanning is a semi-quantitative data collection technique that does not yield specific concentrations of any radioisotopes in environmental media, there are no applicable thresholds or criteria for determining whether a particular gamma count value is acceptable or unacceptable. This data will be used to qualitatively update EPA's knowledge of the distribution of radionuclides at the site. (3) Personnel/Equipment Requirements All personnel performing activities covered by this QAPP shall comply with the Occupational Safety and Health Act, as well as EPA regulations for worker health and safety. Personnel requirements are discussed in Section A8. Level D PPE consisting of steel-toed boots, appropriate gloves, long pants and long-sleeved shirt at a minimum will be required for field personnel. Additional PPE for operating EPA's utility terrain vehicles will include full-face helmets and eye protection. (4) Assessment Techniques Field instrumentation will be calibrated and demonstrated to be working properly as described in B.7 below. (5) Project Schedule The anticipated schedule for this sampling effort will consist ofone field scanning mobilization in August, 2012. The field work is anticipated to take one week. (6) Documentation Data collection activities will be documented with the following (more detailed descriptions of the documentation is provided in Sections A9, B 10, and C2 of this QAPP): Field records; Data Summary tables; and Data Summary figures. A7. Quality Objectives and Criteria for Measurement Data The purpose of this investigation is to obtain additional gamma scans of the surface and down-hole gamma logs of accessible monitoring wells. No samples of any media will be collected. As gamma scanning is a semi-quantitative data collection technique that does not yield specific concentrations of any radioisotopes in environmental media, the following quality objectives are generally in a narrative form. Representativeness will be addressed by proper calibration and use of the gamma scan probes for the surface and down-hole measurements, so that the instrument .readings correlate to the distribution of gamma-emitting radionuclides at the site. Comparability expresses the confidence with which one set of analytical data may be compared with another. Comparability will be qualitatively addressed by comparing the results of the surface gamma scan with the results ofthe previous RI surface gamma scan; however, due to differences in the methodologies used, differences in the two scan results will not necessarily indicate any change in conditions at the site~ Completeness is a measure of the amount of valid data obtained from a measurement system compared to the amount that was expected to be obtained under nonnal conditions. Field completeness is a measure of the amount ofvalid measurements obtained from the measurement taken in the project. The field completeness objective for this project will be 80%. 100% completeness is not required for the data to be useable for its intended purpose. Accuracy and precision will be addressed by proper calibration and use of the gamma scan probes for the surface and down-hole measurements, so that the instrument readings accurately measure gamma emission rates at the site. A8. Special Training Requirements/Certification All personnel who will be on-site performing field activities associated with this investigation must have successfully completed an initial 40-hour hazardous waste operations training course and, thereafter, an annual 8-hour refresher course. The training must comply with Occupational Safety and Health Administration (OSHA) regulations found in 29 Code of Federal Regulations (CFR) 1910.120(e). Personnel must also have had advanced radiation safety training, and will be required to wear a thennoluminescent dosimeter and electronic personal dosimeter while on-site. Personnel must be trained and certified to operate EPA's utility terrain vehicles, which will be used for the surface gamma scan. A9. Documentation and Records The project manager will be responsible for ensuring the most current version of the QAPP is available and distributed to all involved parties, and that data collected during this field work is properly stored and reported to stakeholders. B. Measurement/Data Acquisition B1. Sampling Process Design The surface gamma scan will be conducted with a Ludlum Model2241-3, with a 3-by 3.inch Nal Tl scintillator probe. The scan will be conducted in a serpentine pattern across each area of OU1, with a-spacing between scan lines of 30 feet. Less spacing is appropriate in elevated areas in order to provide detail along contour lines (the RI QAPP specified a 30' grid). The detector will be held approximately twelve inches above the ground surface while the surveyor moves the detector at a constant speed approximating walking pace, and the system will collect a reading every two seconds. Global Positioning System (GPS) data will be simultaneously collected, and the resulting gamma results will be mapped. Prior to scanning the site, background gamma levels will be established at a nearby uncontaminated area (the RI QAPP specified "Local background will be established by taking a measurement off-site on the open field east of the site and east of the St. Charles Rock Road entrance to the site"). The down-hole gamma scan will be conducted with a Ludlum Model 2241-3, with a 44.62 detector. The detector will be lowered to the bottom of each accessible well or to a maximum depth of 150 feet, whichever is lessgreater. The detector will then be raised in one-foot increments, and measurements will be recorded at each interval using the scaler set for a 6.second countas soon as the reading on the instrument appears stable. Wells PZ-103SS,PZ-104SS, PZ-105SS, PZ-108SS, PZ-111 SD and PZ-116SS are designated as background wells to represent naturally-occurring gamma emissions in the subsurface geologic materials. These wells were selected for their depth ( 150 feet or more), their distance from the OU 1 cells, and their lack of any historical detections of radionuclides in groundwater above applicable standards. B2. Sampling Methods Requirements Standard operating procedures for the gamma scanning instrument and detectors will be followed. These SOPs are included in Appendix A. The utility terrain vehicle will be driven at a speed appropriate to generate a thorough density of data points and to prevent the generation ofdust. The EPA field team leader will determine the need for any change in sampling method or locations, if field personnel note difficult site conditions. Any corrective actions required during the implementation of field sampling activities will be documented by the field team leader. B3. Description of Decontamination Procedures for Sampling Equipment The down-hole gamma probe shall be decontaminated prior to logging the first well and between each well by washing with a soap solution (such as Alconox) and rinsing with potable water. The rinse water will be poured onto the ground away from the well after use. The surface gamma scan instrument does not contact the land surface and does not require decontamination. The utility terrain vehicles, field personnel boots, and any other equipment potentially contaminated by soil will be decontaminated by dry brushing to remove the material. Equipment will then be scanned with a Ludlum Model44-9 Geiger-Muller "pancake probe" to ensure that any radioactive contamination has been removed down to a level ofthree times the background count rate with the pancake probe. Any solid investigation-derived waste such as gloves or paper towels will be bagged and surveyed prior to disposal disposed of at the solid waste transfer facility on-site. B4. Sample Handling and Custody Requirements No samples of any media will be collected during this work. B5. Analytical Methods Requirements No analytical methods will be used for this work. B6. Quality Control Requirements Quality control will be maintained during the field work by operating the instruments in accordance with the manufacturer's instructions and EPA's SOPs. B7. Instrument/Equipment Testing, Inspection, and Maintenance Requirements The field equipment testing, inspection, and maintenance will be performed in accordance with the manufacturer's recommendations. B8. Instrument Calibration and Frequency Field equipment calibrations will be performed in accordance with the manufacturer's recommendations prior to mobilization and as needed while on-site. B9. Inspection/Acceptance Requirements for Supplies and Consumables No supplies or consumables will be required for this work. B 10. Data Acquisition Requirements Data acquired from the surface gamma scan instrument and its GPS tracker will be downloaded to EPA computer systems and mapped as necessary to support program goals. Data from the down-hole gamma scanner will be recorded by hand in field logbooks and transcribed into an EPA computer system, or entered directly into an EPA l~ptop in the field in real time. B11. Data Management Data will be stored and backed up on EPA computer systems, filed in the Records Center, and distributed to stakeholders as needed. C. Assessment/Oversight 0. C1. Assessments and Response Actions The EPA QA manager or their designee may conduct an audit of the field activities for this project if requested by the EPA project manager. The EPA QA manager will have the authority to issue a stop work order upon finding a significant condition that would adversely affect the quality and usability ofthe data. The EPA project manger will have the responsibility for initiating and implementing response actions associated with findings identified during the on-site audit. Once the response actions have been implemented, the EPA QA manger will perform a follow-up audit to verify and document that the response actions were implemented effectively. C2. Reports to Management A report of the field work and analytical results will be prepared by the project manager and copies shared with the state and other stakeholders. This report will also include information on any performance evaluations, audits, and significant QA problems, as applicable. D. Data Validation and Usability Dl. Data Review, Validation, and Verification Requirements The EPA Project manager will be responsible for overall validation and final approval of the data in accordance with project purpose and us~ ofthe data. D2. Validation and Verification Methods As the data collected by the planned field work is semi-quantitative, no additional data validation or verification methods are planned. D3. Reconciliation with User Requirements Once the data results are compiled, the EPA project manager will review the data results to determine ifthey fall within the acceptance limits as defined in this QAPP. Completeness will be evaluated to determine if the completeness goal for this project has been met. If the completeness objective has not been met, the EPA project manager will determine an appropriate course of action. Failure to meet the completeness objective will not necessarily require re.sampling. Upon compilation of the data, the RPM will review the data in relation to the quality objectives and criteria for measurement, to identify any limitations on the use ofthe data. The RPM will evaluate data to ensure the information sufficiently characterizes the distribution of gamma-emitting radionuclides at the site, and assess the degree to which the Quality Objectives in A. 7 and the Quality Control measures in 8.6 have been met. If the RPM determines data quality indicators do not meet the project requirements, then the data may have to be discarded and re-sampling may be required. CFR EPA GPS osc OSHA ou PPE QA QAPP QC RI RPM RQAM SOP sow Abbreviations and Acronyms Code ofFederal Regulations U.S. Environmental Protection Agency Global Positioning System On-scene commander Occupational Safety and Health Administration operable unit personal protective equipment quality assurance quality assurance project plan quality control remedial investigation Remedial project manager regional quality assurance manager standard operating procedure statement of work

Post

2012-07-06 – Senator McCaskill inquiry for a status update on West Lake Landfill

Re: ACTION REQUIRED: Sen. McCaskill inquiry for a status update on West Lake Landfill Dan Gravatt to: LaTonya Sanders 07/06/2012 01 :26PM
Cc: Audrey Asher, Debbie Kring
LaTonya,
The summary document you attached on West Lake is somewhat out of date now. Rather than updating it, I suggest you coordinate with Debbie Kring to use the Fact Sheet she’s been developing for the site. Both Audrey and I reviewed and commented on Debbie’s draft fact sheet just last week. It is my understanding that Karl wanted OPA to develop this fact sheet for his use in briefing the congressionals , so it would probably be better if they all got the same message at the same time.
Sincerely, Daniel R. Gravatt, PG US EPA Region 7 SUPR I MOKS 901 North 5th Street, Kansas City, KS 66101 Phone (913) 551-7324 Fax (913) 551-7063
Principles and integrity are expensive , but they are among the very few things worth having.
LaTonya Sanders Hi Dan, I received a call today from Sen. McCas … 07/06/2012 12:53:25 PM
From: LaTonya Sanders/R7/USEPNUS To: Dan Gravatt/R7/USEPNUS@EPA Cc: Audrey Asher/R7/USEPNUS@EPA Date: 07/06/2012 12:53 PM Subject: ACTION REQUIRED: Sen. McCaskill inquiry for a status update on West Lake Landfill
Hi Dan,
I received a call today from Sen. McCaskill’s DC office, requesting a status update on West Lake Landfill.
Attached is an update I shared with congressional staff when I performed courtesy visits in May.
Is this update still current to share with Sen . McCaskill? Is there new or additional information to share?
Please advise.
Thanks.

[attachment “Westlake Landfill Update.docx” deleted by Dan Gravatt!R7/USEPA/US]

~T~E..~
U.S. Environmental Protection Agency, Region 7 Office of the Regional Administrator Office of Public Affairs 901 N. 5th Street Kansas City, KS 66101
PH: 913-551-7555 FX: 913-551-7066 EM: sanders.latonya@epa.gov

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Get -tips -to prO”teC”t Children’s heal-th a-t http:lfwww.epa.gov/region7/Ci-tizens/childrens_heal-th.h”trn

Post

2012-07-09 – Revised West Lake Landfill Update Fact Sheet

IMPORTANT: Revised Westlake Landfill Update Fact Sheet-Please Review as soon as possible Debbie Kring to: Dan Gravatt, Audrey Asher, DeAndre Singletary 07/09/2012 06:19PM Cc: Rich Hood, Hattie Thomas, Christopher Whitley
History: This message has been replied to.
I am attaching the revised Westlake Fact Sheet that you have each weighed in on. I have made most of the changes you recommended, but updated to reflect your preferences, using some slight modifications, i.e., in one paragraph, you want the statement, “the decision selected ….. “-decisions don’t select, people do -so that’s an example of something that keeps the same reference context, but modifies the grammatical tone.
I would like to put this through concurrence in the next day, and I know LaTonya would like to use in her call to Sen. McCaskill’s office tomorrow, so please look over. I am not tied to anything in particular, but want to keep the tone consistent with the use of verbs 🙂
Thanks.
Debbie
lt~•.•…J.•. WestlakelandfiiiUpdateFSJuly2012 .doex
Debra L. Kring Public Affairs Specialist/Local Elected Officials Liaison EPA-Region 7, Office of Public Affairs 901 North 5th Street Kansas City, Kansas 66101 (913).551-7725 or toll-free@ 1-800-223-0425
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Superfund
DIAD!

Region 7 Fact Sheet
Iowa
Kansas
Missouri
Nebraska

Nine Tribal Nations July 2012
Update on Activities Supporting the Record of Decision (ROD)
Amendment for the Westlake Landfill Superfund Site
Bridgeton, Missouri

INTRODUCTION
The U.S. Environmental Protection Agency (EPA) Region 7 has been working in the Bridgeton community to address environmental issues at the Westlake Landfill over a multi-year period. The Westlake Landfill is comprised of two (2) operable units (OUs). OU-1 contains a mixture of radiologically-contaminated soils, municipal refuse and construction/demolition debris. OU-2 includes several sanitary landfill cells containing municipal refuse and construction/demolition debris.
After conducting extensive investigations, holding numerous public forums, and responding in detail to public comments, EPA signed a Record of Decision (ROD) for QU-lin May 2008. This decision document outlined the selected remedy, which included the placement of an engineered cover system over the radiologically-contaminated areas, long-term groundwater monitoring, and the adoption of institutional controls to restrict access.
After the ROD was signed, EPA continued to receive public comments about the selected remedy. In response to those comments, EPA tasked the potentially-responsible parties (PRPs) to conduct a Supplemental Feasibility Study (SFS) for OU-1 that further evaluated the ROD-selected remedy, as well as full-scale excavation of the radiologically.contaminated landfill material and disposal either at a permitted off-site facility or in a new, on-site engineered disposal cell.
The SFS Work Plan was released to the public in June 2010. After reviewing several draft versions of the document, EPA approved and released the SFS Report to the public in December 2011. The estimated costs defined for each alternative in the SFS Report exceeded the threshold, which triggered a formal review and evaluation by EPA’s National Remedy Review Board (NRRB). Between January 2012 and the present time, the NRRB has weighed in with numerous draft comments and recommendations on the SFS Report. The NRRB recommended that EPA, Region 7: evaluate additional groundwater sampling to refresh the data; conduct a more detailed study of the partial excavation alternative; and conduct a more detailed analysis of potential treatment technologies for the radiologically.contaminated landfill material. EPA, Region 7, then tasked the PRPs to conduct some ofthis work as an amendment to its original Consent Order.
In response to more general NRRB recommendations, EPA, Region 7 also decided to update gamma scans ofthe surface ofOU-1 and conduct vertical gamma scans ofmonitoring wells at the site. EPA, Region 7 will perform the gamma scans.
The work will be conducted by PRPs under EPA
oversight, with the following proposed 2012/2013
schedule:
July ’12 -Groundwater sampling (PRPs to conduct, EPA & MDNR will take splits);
August’ 12-Gamma scan evaluation to further rtrfine distribution of radiologically-impacted wastes (EPA staffto conduct);
Summer ’12-’13 -Additional studies to address the NRRB draft comments. (PRPs to perform).
In coordination with its stakeholders, EPA will host a public availability session near the end of2012 in Bridgeton to: convey updated data results; discuss the scope ofthe PRP additional studies; and take questions about the next steps in the ROD.Amendment process.
Communications about the Westlake Landfill
Superfund Site will be addressed through a combination of venues, including, but not limited to: ads in the local newspaper; fact sheets; EPA’s website; and local and regional records centers. Community members and other interested persons, can also contact EPA’s Community Involvement Coordinator, Debbie Kring, via telephone or e-mail as listed below.

AVAILABILITY OF DOCUMENTS
The SFS Report is available online at: http://www.epa.gov/region7/cleanup/npl_files/west_l ake landfill/index.htm
The administrative record, and other site-related documents for the Westlake Landfill Superfund Site are available for review at the following locations:
The Bridgeton Trails Branch of the St. Louis County Library 3455 McKelvey Road Bridgeton, Missouri
AND . EPA Region 7 Records Center

901 North 51h Street
Kansas City, Kansas
1-800-223-0425

ADDITIONAL INFORMATION
If you have questions about this Fact Sheet, or need additional infonnation about the Westlake Landfill Superfund Site, please contact:

Debbie Kring
Community Involvement Coordinator
Office of Public Affairs

U.S. EPA-Region 7
901 North 51h Street
Kansas City, Kansas 66101

(913) 551-7725 or toll-free
1-800-223-0425
kring.debbie@epa. gov

2

Post

2011-12-28 – Supplemental Feasibility Study Radiological-Impacted Material Excavation Alternatives Analysis West Lake Landfill Operable Unit-1

Supplemental Feasibility Study
Radiological-Impacted Material Excavation Alternatives Analysis 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
September 30, 2011 Revised December 16, 2011 Final December 28, 2011

Table of Contents
1 Introduction …………………………………………………………………………………………………………….. 1

1.1
Scope of the SFS ………………………………………………………………………………. 1

1.2
SFS Approach ………………………………………………………………………………….. 3

1.3
Report Organization …………………………………………………………………………..

2 Site Conditions………………………………………………………………………………………………………… 7

2.1
Site Location and Surrounding Area……………………………………………………. 7

2.1.1
Historic Landfill Operations and Disposal Areas ………………………………….. 8

2.1.2
Superfund Operable Units………………………………………………………………….. 9

2.1.3
Current Site Uses……………………………………………………………………………..

2.1.4
Site Zoning, Use Restrictions, and Easements…………………………………….. 11

2.1.5
Surrounding Land Uses……………………………………………………………………. 12

2.1.6
Missouri River Floodplain ……………………………………………………………….. 12

2.2
Nature and Extent of Radionuclide and Chemical Occurrences in OU-1… 14
2.2.1
Source of the Radionuclides………………………………………………………………

2.2.2
General Locations and Lateral Extent of RIM Occurrences in Areas 1 and 2 ……………………………………………………………………………………………………… 16
2.2.3
Vertical Extent of RIM Occurrences in Areas 1 and 2 …………………………. 17

2.2.4
Estimated Volume of RIM……………………………………………………………….. 17

2.2.5
Radiological Occurrences on the Buffer Zone and Crossroad Property….. 19
2.2.6
Radiological Characterization of the RIM …………………………………………..

2.2.7
Radionuclide Decay and Ingrowth…………………………………………………….. 22

2.2.8
Principal Threat Wastes …………………………………………………………………… 22

2.2.9
Occurrences of Non-Radiological Chemical Constituents in Soil/Waste… 22
2.2.9.1.1 Trace Metal Occurrences in Soil……………………………………………………….. 23

2.2.9.1.2 Total Petroleum Hydrocarbons in Soil……………………………………………….. 23

2.2.9.1.3 Volatile Organic Compounds in Soil …………………………………………………. 23

2.2.9.1.4 Semi-Volatile Organic Compounds in Soil…………………………………………. 24

2.2.9.1.5 Pesticides and Polychlorinated Biphenyls in Soil………………………………… 24

2.2.9.1.6 Potential for Occurrences of Hazardous Wastes…………………………………..

2.2.9.1.7 Asbestos Containing Materials in Soil/Waste……………………………………… 25

2.3
Radionuclide Occurrences in Air………………………………………………………. 26

2.4
Groundwater Conditions ………………………………………………………………….. 26

2.4.1
Geology…………………………………………………………………………………………. 27

2.4.2
Hydrogeology…………………………………………………………………………………. 27

2.4.3
Occurrences of Radionuclides in Groundwater …………………………………… 29

2.4.4
Occurrences of Chemical Constituents in Groundwater………………………..

2.5
Baseline Risk Assessment………………………………………………………………… 31

2.5.1
Human Health Risk Assessment ……………………………………………………….. 31

2.5.2
Ecological Risk Assessment …………………………………………………………….. 33

3 Potential ARARs and Remedial action Objectives………………………………………………………

3.1
Potential Applicable or Relevant and Appropriate Requirements ………….. 35

3.1.1
Potential Chemical-Specific ARARs …………………………………………………. 35

i

Table of Contents (continued)

3.1.1.1
Health and Environmental Protection Standards for Uranium and Thorium Mill Tailings…………………………………………………………………………………… 35
3.1.1.2
Standards for Cleanup of Contaminated Land – 40 CFR 192.12(a)……….. 36

3.1.1.3
Radon Emissions Standards – 40 CFR 192.02(b)………………………………… 38

3.1.1.4
Groundwater Protection Standards – 40 CFR 192 Subparts A and B……… 39

3.1.1.5
Other Potential Chemical-Specific ARARs ………………………………………… 40

3.1.1.6
National Emissions Standards for Hazardous Air Pollutants…………………. 40

3.1.1.7
Missouri Radiation Regulations for Protection Against Ionizing Radiation ……………………………………………………………………………………………………… 40
3.1.1.8
Missouri Maximum Contaminant Levels……………………………………………. 41

3.1.2 Potential Location-Specific ARARs ………………………………………………….. 41

3.1.2.1 Floodplain Management…………………………………………………………………… 42

3.1.2.2 Missouri Solid Waste Management Regulations – Site Selection………….. 43

3.1.2.3 Missouri Solid Waste Regulations – Airport Safety…………………………….. 44

3.1.2.4 Missouri Solid Waste Management Regulations – Floodplains …………….. 45

3.1.2.5 Missouri Solid Waste Management Regulations – Wetlands………………… 45

3.1.2.6 Missouri Solid Waste Management Regulations – Seismic Impact Zones. 45
3.1.2.7 Missouri Solid Waste Management Regulations – Unstable Areas………… 46

3.1.2.8 Missouri Solid Waste Management Regulations – Plans ……………………… 46

3.1.2.9
Missouri Solid Waste Management Regulations – Base of Landfill ………. 47

3.1.2.10
FAA Guidance ……………………………………………………………………………….. 47

3.1.2.11
Airport Negative Easement and Restrictive Covenants………………………… 49

3.1.3 Potential Action-Specific ARARs……………………………………………………… 51

3.1.3.1
Health and Environmental Protection Standards for Uranium and Thorium Mill Tailings…………………………………………………………………………………… 52
3.1.3.2
Missouri Solid Waste Management Regulations …………………………………. 52

3.1.4 RCRA Subtitle C Regulations…………………………………………………………… 54

3.2
Additional Requirements Associated with Off-site Disposal ………………… 55

3.2.1 CERCLA Off-site Rule……………………………………………………………………. 55

3.2.2 Off-site Transportation Requirements………………………………………………… 56

3.2.3 Waste Acceptance Criteria for Off-site Disposal…………………………………. 57

3.2.3.1
U.S. Ecology, Grandview, Idaho ………………………………………………………. 57

3.2.3.2
Clean Harbors, Deer Trail, Colorado …………………………………………………. 58

3.2.3.3
EnergySolutions, Clive Utah…………………………………………………………….. 59

3.2.3.4
Other Off-site Disposal Facilities………………………………………………………. 60

3.3
Remedial Action Objectives …………………………………………………………….. 60

3.4
Cleanup Levels……………………………………………………………………………….. 61

4 Technology Screening ……………………………………………………………………………………………. 66

4.1
Technologies Evaluated in the FS Report…………………………………………… 67

4.2
Additional Technology Evaluations/Revisit Previously Eliminated Technologies ………………………………………………………………………………….. 69
4.3
Descriptions of Additional Technologies……………………………………………. 71

4.3.1 Monitoring……………………………………………………………………………………… 71

ii

Table of Contents (continued)

4.3.1.1 Long-term Performance Monitoring………………………………………………….. 71

4.3.1.2 Short-term Monitoring During Construction ………………………………………. 71

4.3.2 Containment …………………………………………………………………………………… 72

4.3.2.1 Capping and Covers ………………………………………………………………………… 73

4.3.2.2 Land Encapsulation…………………………………………………………………………. 73

4.3.2.2.1 On-Site: New Cell…………………………………………………………………………… 73

4.3.2.2.2 Off-Site Licensed Facility………………………………………………………………… 73

4.3.2.3
Cryogenic Barriers ………………………………………………………………………….. 76

4.3.2.4
Vertical Barriers ……………………………………………………………………………… 77

4.3.2.4.1 Slurry Wall…………………………………………………………………………………….. 77

4.3.2.4.2 Grout Curtain …………………………………………………………………………………. 77

4.3.2.4.3 Sheet Pile Cutoff Wall …………………………………………………………………….. 77

4.3.3 Physical/Chemical Treatment …………………………………………………………… 78

4.3.3.1 Solidification/Stabilization……………………………………………………………….. 78

4.3.3.2 Chemical Separation ……………………………………………………………………….. 79

4.3.3.3 Physical Separation …………………………………………………………………………. 80

4.3.3.3.1 Dry Soil Separation…………………………………………………………………………. 80

4.3.3.3.2 Soil Washing ………………………………………………………………………………….. 82

4.3.3.3.3 Flotation ………………………………………………………………………………………… 82

4.3.3.4
Vitrification……………………………………………………………………………………. 83

4.3.4 Biological Treatment……………………………………………………………………….. 84

4.3.5 Removal ………………………………………………………………………………………… 84

4.3.5.1
Excavation……………………………………………………………………………………… 85

4.3.5.2
Storm Water Management ……………………………………………………………….. 85

4.3.5.3
Bird Nuisance Mitigation…………………………………………………………………. 86

4.3.6 Transportation ………………………………………………………………………………… 87

4.3.6.1
Hauling of Wastes and Construction Materials – On-site, Off-road and Off-site, On-road Trucks………………………………………………………………………… 87
4.3.6.2
Hauling of Waste Material -Rail ………………………………………………………. 88

4.4
Implementability Screening of Remediation Technologies and Process Options ………………………………………………………………………………………….. 89
4.4.1 Dry Soil Separation…………………………………………………………………………. 89

4.4.2 Temporary Structure to Enclose an Excavation…………………………………… 91

4.5
Evaluation of Remediation Technologies and Process Options …………….. 92

5 Remedial Action Alternatives………………………………………………………………………………….. 93

5.1
Remedial Alternatives Evaluated in FS ……………………………………………… 93

5.2
ROD-Selected Remedy ……………………………………………………………………. 94

5.2.1 Engineering Components of the ROD-Selected Remedy ……………………… 97

5.2.1.1
Regrading of the Landfill Surface for the ROD-Selected Remedy…………. 98

5.2.1.2
Removal of Radiologically-Impacted Soil from the Buffer Zone/Crossroad Property……………………………………………………………………………………….. 102
5.2.1.3
Engineered Landfill Cover for the ROD-Selected Remedy…………………. 103

5.2.1.4
Rock Armoring/Flood Protection of the Toe of the Landfill ……………….. 104

iii

Table of Contents (continued)

5.2.1.5 Stormwater Management/Surface Water Runoff Control……………………. 105

5.2.1.6 Landfill Gas Monitoring and Control ………………………………………………. 107

5.2.1.7 Management of Subsurface Liquids During Construction …………………… 108

5.2.1.8 Regulated Materials Management During Construction……………………… 108

5.2.1.9 Long-Term Operations and Maintenance for the ROD-Selected Remedy109
5.2.1.10 Environmental Monitoring for the ROD-Selected Remedy…………………. 110

5.2.2 Non-Engineered Components of the ROD-Selected Remedy ……………… 111

5.2.2.1
Institutional Controls Included in the ROD-Selected Remedy…………….. 111

5.2.2.2
Five Year Reviews ………………………………………………………………………… 112

5.3
Additional “Complete Rad Removal” Remedial Action Alternatives…… 113
5.3.1 RIM Occurrences, Extents and Volumes………………………………………….. 113

5.3.2 RIM Excavation and Associated Activities ………………………………………. 114

5.3.2.1 RIM Excavation Procedure and Sequencing……………………………………… 115

5.3.2.2 Material Handling …………………………………………………………………………. 116

5.3.2.3 Material Stockpiling………………………………………………………………………. 117

5.3.2.4
Radiological Surveys during RIM Excavation ………………………………….. 119

5.3.2.5
Application of Daily Soil Cover ……………………………………………………… 120

5.3.2.6
Removal of Radiologically-Impacted Soil from the Buffer Zone/Crossroad Property……………………………………………………………………………………….. 121
5.3.2.7
Management of Subsurface Liquids During RIM Excavation ……………… 121

5.3.2.8
Regulated Materials Management During RIM Excavation………………… 121

5.3.2.9
Radiological Surveys after RIM Excavation……………………………………… 122

5.3.2.10
Stormwater and Landfill Gas Monitoring and Control……………………….. 122

5.3.2.11
Baseline Monitoring for “Complete Rad Removal” Alternatives…………. 123

5.3.2.12
Long-Term Operations, Maintenance and Monitoring and Non-Engineered Components………………………………………………………………………………….. 123
5.3.3 “Complete Rad Removal” with Off-site Disposal Alternative …………….. 124

5.3.4 “Complete Rad Removal” with On-site Disposal Alternative……………… 128

5.3.4.1 Siting of On-site Cell …………………………………………………………………….. 129

5.3.4.2
General Configuration of On-site Cell……………………………………………… 131

5.3.4.3
Liner Construction – On-site Cell……………………………………………………. 133

5.3.4.4
Filling of On-site Cell with RIM……………………………………………………… 135

5.3.4.5
Cover Construction – On-site Cell…………………………………………………… 136

5.3.4.6
OM&M Components – On-site Disposal in Engineered Cell Alternative 137

5.3.5 Closure Construction -Remaining Solid Waste Areas of Areas 1 and 2.. 138
6 Detailed Analysis of Alternatives …………………………………………………………………………… 139

6.1
Description of Evaluation Criteria …………………………………………………… 140

6.1.1 Overall Protection of Human Health and the Environment …………………. 140

6.1.2 Compliance with ARARs……………………………………………………………….. 140

6.1.3 Long-Term Effectiveness and Permanence ………………………………………. 141

6.1.4 Reduction of Toxicity, Mobility or Volume through Treatment ………….. 142

6.1.5 Short-Term Effectiveness……………………………………………………………….. 143

6.1.6 Implementability …………………………………………………………………………… 144

iv

Table of Contents (continued)

6.1.7 Cost …………………………………………………………………………………………….. 145

6.1.7.1 Capital and Operation, Maintenance, and Monitoring Costs……………….. 146

6.1.7.2 Contingency Costs ………………………………………………………………………… 148

6.1.7.3 Present Worth and Non-discounted Constant Dollar Costs …………………. 151

6.1.8
State Acceptance …………………………………………………………………………… 151

6.1.9
Community Acceptance …………………………………………………………………. 152

Detailed Analysis of Alternatives ……………………………………………………. 152

6.2.1
Regrading and Enhanced Capping (ROD-Selected Remedy)………………. 152

6.2.1.1 Overall Protection of Human Health and the Environment …………………. 154

6.2.1.2 Compliance with ARARs……………………………………………………………….. 155

6.2.1.2.1
Missouri Solid Waste Rules for Sanitary Landfills…………………………….. 155

6.2.1.2.2
Environmental Protection Standards for Uranium and Thorium Mill Tailings………………………………………………………………………………………… 156
6.2.1.2.3
National Emissions Standards for Hazardous Air Pollutants (NESHAPs)158
6.2.1.2.4
Clean Water Act……………………………………………………………………………. 158

6.2.1.2.5
Safe Drinking Water Act………………………………………………………………… 158

6.2.1.2.6
Missouri Radiation Regulations for Protection Against Ionizing Radiation ……………………………………………………………………………………………………. 158
6.2.1.2.7
Missouri Well Construction Code……………………………………………………. 158

6.2.1.2.8
Missouri Storm Water Regulations………………………………………………….. 159

6.2.1.3 Long-Term Effectiveness and Permanence ………………………………………. 159

6.2.1.3.1 Magnitude of Residual Risks ………………………………………………………….. 159

6.2.1.3.2 Adequacy and Reliability of Controls………………………………………………. 160

6.2.1.4 Reduction of Toxicity, Mobility or Volume through Treatment ………….. 161

6.2.1.5 Short-Term Effectiveness……………………………………………………………….. 162

6.2.1.5.1 Protectiveness of the Community During Remedial Actions ………………. 162

6.2.1.5.2 Protectiveness of Workers During Remedial Actions ………………………… 163

6.2.1.5.3 Environmental Impacts ………………………………………………………………….. 163

6.2.1.5.4 Ability to Monitor Effectiveness……………………………………………………… 164

6.2.1.5.5 Time Until Remedial Action Objectives are Achieved……………………….. 164

6.2.1.6 Implementability …………………………………………………………………………… 164

6.2.1.6.1 Ability to Construct and Operate the Technology ……………………………… 165

6.2.1.6.2 Reliability of the Technology………………………………………………………….. 165

6.2.1.6.3 Ease of Undertaking Additional Remedial Actions, if Necessary ………… 166

6.2.1.6.4
Ability to Monitor Effectiveness of Remedy…………………………………….. 167

6.2.1.6.5
Ability to Obtain Approvals from Other Agencies …………………………….. 167

6.2.1.6.6
Coordination with Other Agencies…………………………………………………… 167

6.2.1.6.7
Availability of Off-site Treatment, Storage and Disposal Services and Capacity……………………………………………………………………………………….. 169
6.2.1.6.8
Availability of Necessary Equipment and Specialists ………………………… 169

6.2.1.6.9
Availability of Prospective Technologies …………………………………………. 169

6.2.1.7 Cost …………………………………………………………………………………………….. 169

6.2.2 “Complete Rad Removal” with Off-site Disposal Alternative …………….. 170

6.2.2.1 Overall Protection of Human Health and the Environment …………………. 172

v

Table of Contents (continued)

6.2.2.2 Compliance with ARARs……………………………………………………………….. 173

6.2.2.2.1 CERCLA Off-site Rule………………………………………………………………….. 173

6.2.2.2.2 Off-site Transportation Requirements………………………………………………. 173

6.2.2.2.3 Waste Acceptance Criteria (WAC) for Off-site Disposal……………………. 174

6.2.2.2.4 Missouri Solid Waste Rules for Sanitary Landfills…………………………….. 174

6.2.2.2.5
Clean Water Act……………………………………………………………………………. 175

6.2.2.2.6
Safe Drinking Water Act………………………………………………………………… 175

6.2.2.2.7
Missouri Radiation Regulations for Protection Against Ionizing Radiation ……………………………………………………………………………………………………. 175
6.2.2.2.8
Missouri Well Construction Code……………………………………………………. 175

6.2.2.2.9
Missouri Storm Water Regulations………………………………………………….. 175

6.2.2.3 Long-Term Effectiveness and Permanence ………………………………………. 176

6.2.2.3.1 Magnitude of residual risk ……………………………………………………………… 176

6.2.2.3.2 Adequacy and reliability of controls………………………………………………… 177

6.2.2.4 Reduction of Toxicity, Mobility or Volume through Treatment ………….. 178

6.2.2.5 Short-Term Effectiveness……………………………………………………………….. 180

6.2.2.5.1 Protection of the Community During Remedial Actions…………………….. 180

6.2.2.5.2 Protection of Workers During Remedial Actions ………………………………. 182

6.2.2.5.3 Environmental Impacts ………………………………………………………………….. 183

6.2.2.5.4 Ability to Monitor Effectiveness……………………………………………………… 183

6.2.2.5.5 Time Until Remedial Action Objectives are Achieved……………………….. 184

6.2.2.6 Implementability …………………………………………………………………………… 185

6.2.2.6.1 Ability to Construct and Operate the Technology ……………………………… 186

6.2.2.6.2 Reliability of the Technology………………………………………………………….. 188

6.2.2.6.3 Ease of Undertaking Additional Remedial Actions, if Necessary ………… 189

6.2.2.6.4 Ability to Monitor Effectiveness of Remedy…………………………………….. 190

6.2.2.6.5 Ability to Obtain Approvals from Other Agencies …………………………….. 190

6.2.2.6.6 Coordination with Other Agencies…………………………………………………… 192

6.2.2.6.7 Availability of Off-site Treatment, Storage and Disposal Services and … 194
6.2.2.6.8 Availability of Necessary Equipment and Specialists ………………………… 195

6.2.2.6.9 Availability of Prospective Technologies …………………………………………. 195

6.2.2.7 Cost …………………………………………………………………………………………….. 196

6.2.3 “Complete Rad Removal” with On-site Disposal Alternative……………… 197

6.2.3.1 Overall Protection of Human Health and the Environment …………………. 199

6.2.3.2 Compliance with ARARs……………………………………………………………….. 199

6.2.3.3 Long-Term Effectiveness and Permanence ………………………………………. 200

6.2.3.3.1 Magnitude of residual risk ……………………………………………………………… 200

6.2.3.3.2 Adequacy and reliability of controls………………………………………………… 201

6.2.3.4 Reduction of Toxicity, Mobility or Volume through Treatment ………….. 202

6.2.3.5 Short-Term Effectiveness……………………………………………………………….. 203

6.2.3.5.1 Protection of the Community During Remedial Actions…………………….. 203

6.2.3.5.2 Protection of Workers During Remedial Actions ………………………………. 205

6.2.3.5.3 Environmental Impacts ………………………………………………………………….. 205

6.2.3.5.4 Ability to Monitor Effectiveness……………………………………………………… 206

vi

Table of Contents (continued)
6.2.3.5.5
Time Until Remedial Action Objectives are Achieved……………………….. 206

6.2.3.6 Implementability …………………………………………………………………………… 207

6.2.3.6.1
Ability to Construct and Operate the Technology ……………………………… 209

6.2.3.6.2
Reliability of the Technology………………………………………………………….. 212

6.2.3.6.3
Ease of Undertaking Additional Remedial Actions, if Necessary ………… 213

6.2.3.6.4
Ability to Monitor Effectiveness of Remedy…………………………………….. 214

6.2.3.6.5
Ability to Obtain Approvals from Other Agencies …………………………….. 214

6.2.3.6.6
Coordination with Other Agencies…………………………………………………… 216

6.2.3.6.7
Availability of Off-site Treatment, Storage and Disposal Services and Capacity……………………………………………………………………………………….. 218
6.2.3.6.8
Availability of Necessary Equipment and Specialists ………………………… 218

6.2.3.6.9
Availability of Prospective Technologies …………………………………………. 219

6.2.3.7 Cost …………………………………………………………………………………………….. 219

7 Comparative Analysis of Alternatives…………………………………………………………………….. 221

7.1
Threshold Criteria …………………………………………………………………………. 221

7.1.1 Overall Protection of Human Health and the Environment …………………. 221

7.1.2 Compliance with ARARs……………………………………………………………….. 222

7.1.2.1 Chemical-Specific ARARs. ……………………………………………………………. 222

7.1.2.2 Location-Specific ARARs. …………………………………………………………….. 223

7.1.2.3 Action-Specific ARARs…………………………………………………………………. 224

7.1.2.4 Remedy Selection Absent ARAR Compliance………………………………….. 225

7.2
Primary Balancing Criteria …………………………………………………………….. 226

7.2.1 Long-Term Effectiveness and Permanence ………………………………………. 226

7.2.2 Reduction of Toxicity, Mobility or Volume through Treatment ………….. 228

7.2.3 Short-Term Effectiveness……………………………………………………………….. 229

7.2.3.1 Protection of the Community………………………………………………………….. 229

7.2.3.2 Worker Protection …………………………………………………………………………. 231

7.2.3.3 Environmental Impacts ………………………………………………………………….. 231

7.2.3.4 Time to Achieve Remedial Action Objectives (RAOs)………………………. 232

7.2.4 Implementability …………………………………………………………………………… 233

7.2.5 Cost …………………………………………………………………………………………….. 239

7.3
Modifying Criteria ………………………………………………………………………… 242

8 References…………………………………………………………………………………………………………… 243

vii

Table of Contents (continued)
Appendices
A. Existing Institutional Controls, City of St. Louis -Negative Easement and Restrictive Covenant on West Lake Landfill, and FAA ROD, MOU, and Advisories
B. Identification and Quantification of the Volume of RIM above Cleanup Levels
C. Off-site Disposal Facilities – Waste Acceptance Criteria
D. Evaluation of Trench Shoring Applicability
E. Evaluation of Regrading Options for ROD-Selected Remedy
F. Required Cover Thicknesses Calculations
G. Conceptual Environmental Monitoring Plan
H. Evaluation of Potential Risks Associated with the Proposed Remedial Alternatives
I. Estimated Greenhouse Gas Emissions Associated with the Alternatives
J. Estimated Project Schedules for the Remedial Alternatives
K. Estimated Costs for the Remedial Alternatives
List of Tables
1.
Summary Comparison of Results from Proximately Located RI and NRC Soil Borings

2.
Summary of Thorium-230 Decay and Radium-226 In-Growth Over Time

3.
Summary Comparison of Soil Sample Results to RCRA Toxicity Characteristic Regulatory Levels

4.
Summary of Calculated Risks for Current and Future Potential Receptors

5.
Preliminary Identification of Potential Chemical-Specific ARARs and TBC Criteria

6.
Preliminary Identification of Potential Location-Specific ARARs and TBC Criteria

7.
Preliminary Identification of Potential Action-Specific ARARs and TBC Criteria

8.
Comparison of USEI Waste Acceptance Criteria (WAC) to Projected OU-1 RIM Concentrations

9.
Summary of Estimated Costs

10.
Comparative Analysis of Alternatives

List of Figures
1.
General Location Map

2.
Site Area

3.
Site Features

4.
Site Topography

5.
Site and Adjacent Property Ownership

6.
Landfill and Adjacent Property Zoning

7.
Existing Environmental Easements and Land-Use Covenants

8.
Setback from Airport Runway

9.
Geologic Map

10.
Extent of Geomorphic Flood Plain

11.
Extent of Radiologically-Impacted Materials

viii

Table of Contents (continued)
List of Figures (cont.)
12.
Comparison of Areal Extent of RIM from NRC, RI and SFS Studies

13.
Locations of NRC and RI Soil Borings

14.
Buffer Zone/Crossroad Property Sampling Locations

15.
Ingrowth of Radium Over Time

16.
Groundwater and Surface Water Dissolved Radium Results

17.
Groundwater and Surface Water Total Radium Results

18.
Groundwater and Surface Water Dissolved Arsenic Results

19.
Groundwater and Surface Water Total Arsenic Results

20.
Groundwater and Surface Water Dissolved Lead Results

21.
Groundwater and Surface Water Total Lead Results

22.
Groundwater and Surface Water Benzene Results

23.
Groundwater and Surface Water Total Chlorobenzene Results

24.
Technology Implementability Screening of Remediation Technologies and Process Options

25.
Locations of Potential Off-Site Disposal Facilities and Rail Points

26.
Waste Volume/Size Reduction and Separation Equipment

27.
Evaluation of Remediation Technologies and Process Options

28.
Conceptual Cross-section of the ROD Remedy

29.
Potential Material Stockpile Areas

30.
On-Site Treatment of Contact Stormwater and Leachate

31.
RIM Excavation Sequencing

32.
Conceptual Alignment of On-Site Rail Spur

33.
Proposed Location New On-Site Cell

34.
Profile of On-site Disposal Cell Liner and Cover

35.
Final Closed Topography Areas 1 and 2

36.
Area 2 Waste Excavation Intersection with OU-2 Boundaries

37.
Profile of Area 2 Waste Excavation Intersection with OU-2 Boundaries

ix

List of Acronyms

AC Advisory Circular
ACM asbestos containing materials
AEC Atomic Energy Commission
amsl above mean sea level
AOA air operations area
AOC Administrative Order on Consent
ARAR Applicable or Relevant and Appropriate Requirements
ARRA American Recovery and Reinvestment Act
ASTM American Society of Testing Materials
bcy bank cubic yard
BDAT Best Demonstrated Available Technology
bgs below ground surface
Bi Bismuth
BMP Best Management Practices
BRA Baseline Risk Assessment
C&D Construction and demolition
CERCLA Comprehensive Environmental Recovery, Compensation, and Liability Act
cf cubic feet
CFR Code of Federal Regulations
cm centimeter
CM Construction Manager
cm/sec centimeter per second
COCs Chemicals of concern
COD Chemical Oxygen Demand
CoPC constituent of potential concern
CQA construction quality assurance
CSR Code of State Regulations
cy, or cu yd cubic yard
DAF Dilution-Attenuation Factor
DCGL Derived concentration guideline
DOD Department of Defense
DOE United States Department of Energy
DOT United States Department of Transportation
DQO data quality objective
dtrs daughters
ea each
ecy embankment cubic yards
EDTA ethylenediaminetetraacetic acid
EMSI Engineering Management Support, Inc.
ENR CCI Engineering News Record Construction Cost Index
EPA United States Environmental Protection Agency
EPC Exposure point concentration
ERA Ecological Risk Assessment
x

List of Acronyms (continued)

FAA Federal Aviation Administration FEMA Federal Emergency Management Agency FIRM Flood Insurance Rate Map FRTR Federal Remediation Technologies Roundtable FS Feasibility Study FUSRAP Formerly Utilized Sites Remedial Action Program ft feet gm, or g gram GM Geiger Mueller gpm gallons per minute GRA General Response Action HAZMAT hazardous materials HDPE high density polyethylene HHRA Human Health Risk Assessment HI Hazard Index HP health physics hr hour IC Institutional Control IP industrial packaging IRIS Integrated Risk Information System K Potassium kg kilogram L liter LAACC Large Area Activated Charcoal Canisters lbs pounds lcy loose cubic yard LDPE low density polyethylene LDR Land disposal restrictions LEL lower explosive limit lf linear foot LFMR Landfill mining and reclamation Li Lithium LLRW Low level radioactive waste LoMR Letter of Map Revision LPGAC Liquid Phase Granular Activated Carbon LSA low specific activity MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MCA Multi-channel analyzer MCL Maximum contaminant level MCLG Maximum contaminant level goal MDA Minimum detectable activity MDOT Missouri Department of Transportation MDNR Missouri Department of Natural Resources MECA Missouri Environmental Covenants Act
xi

List of Acronyms (continued)

m meter MeV Million electron volts mg milligram mm millimeter mo ` month MOU Memorandum of Understanding mrem millirem msf thousand square feet MSD Metropolitan St. Louis Sewer District MSWLF Municipal Solid Waste Landfill MTG Migration to Groundwater Na Sodium NARM Naturally-Occurring and Accelerator-Produced Radioactive Material NCP National Oil and Hazardous Substance Pollution Contingency Plan NEPA National Environmental Policy Act NESHAPs National Emissions Standards for Hazardous Air Pollutants NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System NRC Nuclear Regulatory Commission NORM Naturally occurring radioactive material NPL National Priorities List O Oxygen O&M operation and maintenance OM&M operation, maintenance, and monitoring OMB Office of Management and Budget OSHA Occupational Safety and Health Administration OSR Off-site Rule OSTRI Office of Superfund Technology Research and Innovation OSWER Office of Solid Waste and Emergency Response OU Operable Unit Pa Protactinium PAH Poly-nuclear aromatic hydrocarbon Pb Lead PCB Poly-chlorinated biphenyl pCi pico Curie PFLT Paint filter liquids test Po Polonium POTW Publicly-Owned Treatment Works PPE personal protective equipment ppm Parts per million PRG Preliminary Remediation Goal PUF Poly-urethane foam R Roentgen RD Remedial design
xii

List of Acronyms (continued)

RA Remedial action
Ra Radium
RACM Regulated asbestos-containing material
RAECOM Radiation Attenuation Effectiveness and Cover Optimization with Moisture Effects computer program
RAO Remedial Action Objective
RCRA Resource Conservation and Recovery Act
RD Remedial Design
RDWP Remedial Design Work Plan
rem roentgen equivalent in man
RESRAD RESRAD – CHEM: A computer code for chemical risk assessment
RI Remedial Investigation
RIM Radiologically Impacted Material
RMC Radiation Management Corporation
RML radioactive material license
ROD Record of Decision
RSMo Revised Statutes of Missouri
SAP Sampling and Analysis Plan
sec, or s second
sf or sq ft square feet
SFS Supplemental Feasibility Study
Si Silocon
SLAPS St. Louis Airport Site
SLDS St. Louis Downtown Site
STLAA St. Louis Airport Authority
SOW Statement of Work
SVOC Semi-Volatile Organic Compound
SWMP Solid Waste Management Program
SWPP Stormwater Pollution Prevention Plan
t ton
TBC To Be Considered
TCLP Toxicity Characteristic Leaching Procedure
TENORM Technologically Enhanced Naturally Occurring Radioactive Materials
Th Thorium
TS Transfer Station
TSDF Treatment, storage, and disposal facility
TSS Total Dissolved Solids
U Uranium
ug microgram
UMTRCA Uranium Mill Tailings Radiation Control Act
uR microRoentgen
U.S.C. United States Code USACOE United States Army Corps of Engineers USCS Unified Soil Classification System
xiii

List of Acronyms (continued)
USDA United States Department of Agriculture USEI US Ecology Idaho UTS Universal treatment standards VOCs Volatile Organic Compounds VCA Verification of current acceptability WAC Waste Acceptance Criteria WL Working Level yr Year
xiv

1 INTRODUCTION
As a result of internal deliberations by the United States Environmental Protection Agency (EPA) and its further consideration of certain comments provided by interested community members, EPA determined that a Supplemental Feasibility Study (SFS) is warranted. This SFS will be added to the Administrative Record for this Site.
1.1 Scope of the SFS
This SFS has been performed to provide additional evaluation of a select group of potential remedial alternatives for Operable Unit 1 (OU-1) at the West Lake Landfill Site. EPA determined that additional work was necessary to accomplish the objectives of the RI/FS for OU.
1. Specifically, EPA requested the OU-1 Respondents to perform an SFS consisting of an engineering and cost analysis of the ROD-selected remedy, and two remedial alternatives that would remove all material containing radionuclides at levels greater than those that would allow for unrestricted use (relative to the presence of radionuclides) of the radiologically-contaminated areas (Areas 1 and 2 and the Buffer Zone/Crossroad properties) in OU-1; referred to by EPA as “complete rad removal”.
The ROD-selected containment remedy for OU-1 would protect human health and the environment by providing source control and institutional controls for the landfilled waste materials. A description of and reasons for selection of this remedy are presented in EPA’s Record of Decision (ROD) for OU-1 (EPA, 2008a). The source control and institutional control methods prevent human receptors from contacting the waste material. The source control method mitigates contaminant migration to air and restricts infiltration of precipitation into the landfill, which contributes to protection of groundwater quality. The description and basis for the selected remedy was documented in the ROD. The components of the ROD-selected remedy include the following:
1.
Install landfill cover meeting the Missouri closure and post-closure care requirements for sanitary landfills, including enhancements consistent with the standards for uranium mill tailing sites, i.e., armoring layer and radon barrier;

2.
Consolidation of radiologically contaminated surface soil from the Buffer Zone/Crossroad Property to the containment area;.

3.
Apply groundwater monitoring and protection standards consistent with requirements for uranium mill tailing sites and sanitary landfills;.

4.
Surface water runoff control;

5.
Gas monitoring and control including radon and decomposition gas as necessary;

6.
Institutional controls to prevent land and resource uses that are inconsistent with a closed sanitary landfill site containing long-lived redionuclides; and

7.
Long-term surveillance and maintenance of the remedy.

Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 1
Performance standards for each of the remedy components are specified in the ROD. As a result of subsequent discussions between EPA Region 7 and EPA’s Office of Superfund Remediation and Technology Innovation (OSRTI), the following additional performance standards were identified for the ROD-selected remedy:

The proposed cap should meet UMTRCA guidance for a 1,000-year design period
including an additional thickness to prevent radiation emissions.


Air monitoring stations for radioactive materials should be installed at both on-site and off-site locations.


Groundwater monitoring should be implemented at the waste management unit boundary and also at off-site locations. The groundwater monitoring program needs to be designed so that it can be determined whether contaminants from the landfill have migrated across the waste management unit boundary in concentrations that exceed drinking water Maximum Contaminant Levels. The groundwater monitoring program needs to measure for both contaminants that have historically been detected in concentrations above MCLs (e.g., benzene, chlorobenzene, dissolved lead, total lead, dissolved arsenic, total arsenic, dissolved radium and total radium) and broader indicators of contamination (e.g., redox potential, alkalinity, carbonates, pH and sulfates/sulfides).


Flood control measures at the site should meet or exceed design standards for a 500-year storm event under the assumption that the existing levee system is breached.

This SFS analysis incorporates those additional performance standards and refines the description and evaluation of the containment remedy that was selected in the ROD.
In a January 11, 2010, letter (EPA, 2010a) and Statement of Work (SOW) (EPA, 2010b) requesting that the Respondents perform this SFS, EPA identified the two “complete rad removal” alternatives that EPA directed be developed and evaluated in addition to the ROD-selected remedy:
1.
Excavation of radioactive materials with off-site commercial disposal of the excavated materials (referred to as “complete rad removal” with off-site disposal alternative in this SFS); and

2.
Excavation of radioactive materials with on-site disposal of the excavated materials in an on-site engineered disposal cell with a liner and cap if a suitable location outside the geomorphic flood plain can be identified (referred to as “complete rad removal” with on-site disposal alternative in this SFS).

EPA indicated (EPA, 2010a) that “complete rad removal” was defined to mean attainment of risk-based radiological cleanup levels specified in OSWER Directives 9200.4-25 and 9200.4-18. Although these new alternatives have been termed “complete rad removal,” it must be
Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 2
recognized that implementation of either of these alternatives would not result in complete removal of all radionuclides from the landfill, but instead would remove radionuclides from Areas 1 and 2 to the degree feasible such that additional engineering and institutional controls would not be required based on the radiological content of these areas. Because these areas would still contain solid wastes after removal of the radiologically-impacted materials, regrading, capping and establishment of institutional controls related to the presence of solid wastes would still be required.
As described in the SOW (EPA, 2010b), EPA required the two “complete rad removal” alternatives to be evaluated along with the ROD-selected remedy. The two “complete rad removal” alternatives along with the ROD-selected remedy were evaluated using the threshold and primary balancing criteria set forth in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR § 300.430 (EPA, 2009a). These criteria include the following:

Threshold Criteria: -Overall Protection of Human Health and the Environment; -Compliance with applicable or relevant and appropriate requirements of other

regulations (ARARs).


Primary Balancing Criteria:
-Long-term Effectiveness and Permanence;
-Reduction of Toxicity, Mobility, or Volume through Treatment;
-Short-term Effectiveness;
-Implementability; and
-Cost.

Additional descriptions of these criteria are presented in Section 6 of this SFS.
The NCP also requires remedial alternatives to be evaluated in terms of Modifying Criteria which include State and community acceptance. State and community acceptance will be evaluated by EPA as part of any decision process that may be undertaken by EPA after completion of the SFS and are not considered in this document.
1.2 SFS Approach
This SFS has been developed pursuant to a January 11, 2010, letter from EPA to the OU-1 Respondents (EPA, 2010a), an EPA-developed Statement of Work (SOW) (EPA SOW, 2010b) attached to the January 11 letter, and the EPA-approved Work Plan for the Supplemental Feasibility Study (SFS Work Plan) (EMSI, 2010a).
The engineering and cost analyses of the “complete rad removal” alternatives and the ROD-selected remedy performed for this SFS are based primarily on existing information provided in the Remedial Investigation (RI) (EMSI, 2000), Baseline Risk Assessment (BRA) (Auxier, 2000), Feasibility Study (FS) (EMSI, 2006), and the ROD for OU-1. These analyses also consider the
Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 3
results of a supplemental evaluation prepared by EPA subsequent to the ROD (TetraTech, 2009). Additionally, information was obtained from representatives of the United States Army Corps of Engineers (USACE), the United States Department of Energy (DOE), and various vendors of equipment, materials and services as necessary to develop and evaluate the potential effectiveness, implementability and cost of the “complete rad removal” alternatives. Additional field investigations or laboratory testing were not included in the scope of this effort and were not performed.
This report has been prepared to address the requirements of the SOW, EPA-approved Work Plan, and the NCP, in accordance with EPA’s Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (EPA, 1988a) and other EPA FS-related guidance documents (e.g., EPA, 1991a; EPA, 2000). This SFS:

provides a summary discussion of site conditions and other information presented in the RI for OU-1 (EMSI, 2000);


addresses findings in United States Nuclear Regulatory Commission (NRC) reports that evaluated the radiological disposal areas at the West Lake Landfill site;


provides additional characterization of the dimensions of radiologically impacted materials in the two radiological disposal areas;


summarizes the characterization of potential site risks presented in the BRA for OU-1 (Auxier, 2000);


provides further information and evaluation pertaining to a negative easement on the property held by the City of St. Louis, and its potential impacts on remedy implementation for OU-1;


provides additional information about environmental monitoring during remedy implementation and long-term maintenance and operations;


evaluates potential treatment technologies for the radiologically impacted materials; and


evaluates potential ARARs and remedial technologies, and descriptions of the remedial alternatives previously presented and evaluated in the site FS (EMSI, 2006).

Where necessary for the evaluation of the “complete rad removal” alternatives, or as otherwise
appropriate for completion of the SFS, brief summaries or tabulations of the results of prior site
evaluations are provided; however, the prior reports should be reviewed or consulted for
additional details and specific information relative to those evaluations.
Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 4
1.3 Report Organization
This report is organized as follows:
Section 1: Introduction – Presents information regarding the scope and approach used to complete the SFS.
Section 2: Site Conditions – Summarizes information regarding site conditions as they relate to the alternatives evaluated in the SFS. Detailed information about site conditions was presented in the RI report for OU-1 (EMSI, 2000) and a summary discussion of site conditions related to the development and evaluation of remedial alternatives was presented in the FS report for OU-1 (EMSI, 2006). This section provides a description of occurrences of radionuclides in soil/waste, air and groundwater at the site. In addition, this section describes the nature, general locations, and overall lateral and vertical extent of Radiologically-Impacted Materials (RIM). This section also provides a summary of the occurrences of chemical constituents in soil/waste and groundwater. Lastly, this section provides a brief summary of the results of the Baseline Risk Assessment (Auxier, 2000).
Section 3: ARARs – Summarizes information regarding potential ARARs and remedial action objectives (RAOs) as they relate to the additional alternatives evaluated in the SFS. Additional, detailed information about potential ARARs and RAOs was presented in the FS report for OU-1 (EMSI, 2006).
Section 4: Remedial Technologies – Summarizes information regarding additional remedial technologies that may be potentially applicable to the “Complete Rad Removal” alternatives evaluated in the SFS. Additional, detailed information about potentially applicable technologies was presented in the FS report for OU-1 (EMSI, 2006).
Section 5: Remedial Alternatives – Provides descriptions of the ROD-selected remedy and the “complete rad removal” alternatives that are the subject of the detailed evaluations presented in Sections 6 and 7. Descriptions of other remedial alternatives previously developed and evaluated for OU-1 were presented in the FS report for OU-1 (EMSI, 2006) and are not repeated in this SFS report.
Section 6: Detailed Analysis of Alternatives – Presents a detailed analysis of the ROD-selected remedy and the “complete rad removal” alternatives relative to the threshold and balancing criteria defined by the NCP.
Section 7: Comparative Analysis of Alternatives – Presents a summary comparison of the ROD-selected remedy and the two “complete rad removal” alternatives in terms of the threshold and balancing criteria defined by the NCP.
Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 5
Section 8: References – Provides a list of references cited in this report.
This SFS also includes the following appendices:
Appendix A: Existing Institutional Controls affecting the Site, the City of St. Louis Negative Easement and Restrictive Covenant on West Lake Landfill, and FAA ROD, MOU and Advisory Circulars
Appendix B: Identification and Quantification of the Volume of RIM above
Cleanup Levels Appendix C: Off-site Disposal Facilities – Waste Acceptance Criteria Appendix D: Evaluation of Potential Application of Shoring Technology Appendix E: Evaluation of Area 1 and 2 Regrading Options Appendix F: Required Cover Thicknesses Calculations Appendix G: Conceptual Environmental Monitoring Plan Appendix H: Evaluation of Potential Risks Associated with the Proposed
Remedial Alternatives
Appendix I: Estimated Greenhouse Gas Emissions Associated with the

Alternatives Appendix J: Estimated Project Schedules for the Remedial Alternatives Appendix K: Estimated Costs for the Remedial Alternatives.
Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 6
2 SITE CONDITIONS
The purpose of this Section 2 is to provide information necessary to support the evaluation of remedial technologies and alternatives presented in Sections 4, 6, and 7. Therefore, this section summarizes certain site-specific information from the existing Administrative Record in order to present a summary of the site conditions at the West Lake Landfill.
This Section 2 is divided into five subsections:

Section 2.1 provides information regarding the West Lake landfill and the surrounding area including discussions and/or descriptions of historical landfill operations and disposal areas; Superfund Operable Units (OUs) on the site; current site uses; site zoning, use restrictions and easements; surrounding land uses; and potential impacts or consequences from the landfill’s proximity to the Missouri River floodplain.


The nature and extent of radionuclide occurrences in OU-1 are discussed in Section 2.2 including the source of the radionuclides; general locations and lateral extent of radiologically-impacted materials (RIM); vertical extent of RIM occurrences in Areas 1 and 2; estimated volume of RIM; radiological occurrences on the Buffer Zone and Crossroad Property; radiological characterization of the RIM in Areas 1 and 2; projected radionuclide decay and ingrowth of the RIM; and the evaluation of principal threat wastes. Section 2.2 also includes information regarding the occurrence of non-radiological hazardous substances (trace metals, petroleum hydrocarbons, volatile and semi-volatile organics, pesticides and PCBs) in soil samples collected from Areas 1 and 2 as well as discussions regarding the potential for occurrences of hazardous wastes and asbestos-containing materials in the landfill matrix.


The presence of radionuclides in air is discussed in Section 2.3.


Brief descriptions of the site geology and hydrogeology and the nature and extent of radionuclide and chemical occurrences in groundwater near Areas 1 and 2 are provided in Section 2.4.


Finally, Section 2.5 includes summaries and conclusions from the baseline human health and screening-level ecological risk assessments.

2.1 Site Location and Surrounding Area
The West Lake Landfill is located within the western portion of the St. Louis metropolitan area on the east side of the Missouri River floodplain approximately two miles east of the river (Figure 1). The landfill is located approximately one mile north of the intersection of Interstate 70 and Interstate 270 within the city limits of the City of Bridgeton in northwestern St. Louis County.
Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 7
The site is bounded to the east and northeast by St. Charles Rock Road (State Highway 115) (Figure 2). Commercial and industrial properties bound the site immediately to the north, across St. Charles Rock Road to the north and east, and to the south. The site is bounded on the west by Old St. Charles Rock Road (vacated) and the Earth City Industrial Park (Earth City) stormwater/flood control pond. The Earth City commercial and industrial complex continues to the west and north of the stormwater/flood control pond and extends from the site to the Missouri River. Earth City is separated from the river by an engineered levee system owned and maintained by the Earth City Flood Control District.
2.1.1 Historic Landfill Operations and Disposal Areas
The West Lake Landfill is an approximately 200-acre parcel containing multiple areas of past operations. 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, the North Quarry Pit and the South Quarry Pit (Figure 3), which were excavated to maximum depth of 240 feet below ground surface (bgs) (Herst & Associates, 2005).
The West Lake Landfill is the site of several areas where solid wastes have been disposed. Beginning in the early 1950s or perhaps the later 1940s, portions of the quarried areas and adjacent areas were used for landfilling municipal refuse, industrial solid wastes, and construction/demolition debris. These operations predated state laws and regulations governing such operations. Landfill activities conducted after 1974 within the quarry areas were subject to permits obtained from the Missouri Department of Natural Resources (MDNR). In 1974 landfilling began in the portion of the site described as the North Quarry Pit. Landfilling continued in this area until 1985 when the landfill underwent expansion to the southwest into the area described as the South Quarry Pit (Herst & Associates, 2005). In August 2005, the Bridgeton Sanitary Landfill stopped receiving waste pursuant to an agreement with the City of St. Louis to reduce the potential for birds to interfere with airport operations. The Bridgeton Sanitary Landfill is inactive and closure and post-closure activities are proceeding under MDNR supervision.
In addition to the Bridgeton Sanitary Landfill north and south quarry pits currently in the process of closure/post-closure, the West Lake Landfill property contains four other areas where solid wastes were disposed (Figure 3):

Area 1 where solid wastes and radiologically-impacted materials were disposed;


Area 2 where solid wastes and radiologically-impacted materials were disposed;


A closed demolition landfill; and


An inactive sanitary landfill.

Supplemental Feasibility Study Report West Lake Landfill OU-1 12/16/2011 Page 8
2.1.2 Superfund Operable Units
Superfund-program remedial action at the site is divided into two operable units (OUs). OU-1 is comprised of the solid wastes and RIM disposed in Areas 1 and 2 and portions of an adjacent property, formerly described as the Ford Property and now called the Buffer Zone/Crossroad Property. OU-2 consists of the other landfill areas that are not impacted by radionuclides and includes the inactive sanitary landfill located adjacent to Area 2, the closed demolition landfill, and the Bridgeton Sanitary Landfill located in the North and South Quarry Pits. The closed demolition landfill and the Bridgeton Sanitary Landfill, while designated as part of OU-2, are regulated by the MDNR pursuant to State of Missouri solid waste regulations and are not being actively addressed by the Superfund program. To the extent that the presence of or activities associated with these OU-2 areas potentially impact OU-1 and the remedial alternatives considered by this SFS, those impacts are discussed in the appropriate SFS section.
OU-1 Area 1 is situated on the northern and western slopes of a topographic high within the overall West Lake landfill property. Ground surface elevation in Area 1 varies from 490 feet above mean sea level (AMSL) on the south to 452 feet AMSL at the roadway near the transfer station entrance (Figure 4). OU-1 Area 2 is situated between a topographic high of landfilled materials on the south and east, and the Buffer Zone/Crossroad Property on the west. The highest topographic level in Area 2 is about 500 feet AMSL on the southwest side of Area 2, sloping to approximately 470 feet AMSL near the top of the landfill berm (Figure 4). The upper surface of the berm along the western edge of Area 2 is located approximately 20 to 30 feet above the adjacent Buffer Zone/Crossroad Property and approximately 30 to 40 feet higher than the water surface in the flood control channel located to the south-west of Area 2. A berm on the northern portions of Area 2 controls runoff to the adjacent properties.
No contemporaneous reports, drawings or other records from the former site operators exist regarding the construction of the disposal units or the overall types and amounts of wastes that were disposed in the Area 1 and Area 2 landfills during their operation. Based on the RI investigations, it appears that these areas were filled using an “area-fill” approach whereby waste materials consisting primarily of munic

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