Evaluation of The Epa Selected Remedy For Operable Unit-1 (Ou-1) - Appendix

Senior Scholar
Institute for Policy Studies
Director, Field Operations

Environmental Services
Attachment 1 - EPA ORD ETSC

observations on the EMSI report Evaluation of Possible Impacts of a Potential
Subsurface Smoldering Event on the Record
of Decision
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF RESEARCH AND DEVELOPMENT

NATIONAL RISK MANAGEMENT RESEARCH LABORATORY
ENGINEERING TECHNICAL SUPPORT CENTER
CINCINNATI, OHIO 45268
March 28, 2014

MEMORANDUM
SUBJECT: Observations on the EMSI report: Evaluation of Possible Impacts of a Potential Subsurface
Smoldering Event on the Record of Decision Selected Remedy for Operable Unit-1 at the West Lake Landfill,
Dated January 14, 2014
FROM: John McKernan, ScD, CIH
Director, ORD Engineering Technical Support Center (ETSC)
TO: Dan Gravatt, RPM
U.S. EPA Region 7
This memorandum was prepared in response to your e-mail dated January 14, 2014, that requested the ORD
Engineering Technical Support Center (ETSC) provide scientific observations on the report prepared by Engineering
Management Support, Inc. (EMSI), a contractor for the sites potentially responsible parties (PRPs). In a letter dated
July 3, 2013, the United States Environmental Protection Agency (EPA), Region 7 requested that the PRPs expand
the risk analysis section of the December 2011 Supplemental Feasibility Study (SFS) for the West Lake Landfill,
Operable Unit-1 (OU-1). It was requested that the expanded analysis consider the risk from a subsurface smoldering
event (SSE) originating in the adjacent Bridgeton Landfill, or within OU-1.
ETSC and its contractors prepared this memorandum to provide a summary of our observations on the seven bullet
points listed in EMSIs January 14, 2014 report. The responses in the memorandum are based on the following: 1) a
review of the January 14, 2014, EMSI report, 2) a focused review of the May 2008 Record of Decision (ROD) for OU1 and the 2011 Supplemental Feasibility Study (SFS), 3) our knowledge of the SSE and related data collected at the
Bridgeton Landfill, and 4) our general knowledge of landfill operations and SSEs.
This memorandum is intended to be a high-level summary. We did not comment on the likelihood of a SSE occurring
in or traveling to the OU-1 cell. Each bullet point from the EMSI January 2014 report is presented below in bold type,
and our observations related to these bullet points are presented in normal type.
Thank you for the opportunity to review and provide input on referenced report. Please feel free to contact me with
any questions or comments.
EMSI Executive Summary Bullet Point #1: The radiologically-impacted material (RIM) disposed of in West
Lake Areas 1 and 2 will not become more or less radioactive in the presence of heat. Likewise, the RIM is not
explosive and will not become explosive in the presence of heat.
ETSC Observations: We agree that the RIM in OU-1 is not expected to be more or less radioactive in the presence of
heat. However, we do not have a full accounting of the non-RIM solid waste in OU-1. At this time, we have no
evidence that would indicate that the RIM and non-RIM material known to be in OU-1 will become explosive in the
presence of heat, even at the elevated temperatures observed in the Bridgeton Landfill. It is notable that in the event
of a SSE there could be chemical reactions between the RIM and non-RIM materials in OU-1. These reactions could
cause a rapid buildup of heat or gas and subsequent reactions or reactive conditions in the landfill.
EMSI Executive Summary Bullet Point #2: An SSE does not create conditions that could carry RIM particles
or dust off the site. The heat of an SSE is not high enough to ignite non-RIM wastes or chemical compounds
or to cause them to explode.
ETSC Observations: The temperatures in the SSE at the Bridgeton Landfill are consistent with levels corresponding
to pyrolysisa. If a SSE in OU-1 could reach similar temperatures, we would not expect the non-RIM material to ignite.
However, using the higher temperatures observed in the Bridgeton Landfill as a worse-case scenario, these
*30284983*
a
Nammari, R. (2006). Seasonal and long-Term Storage of Baled Municipal Solid Waste, Lund University, Sweden, ISBN 91-7422118-3.
30284983
temperatures may cause the structural integrity of the cap called for in the 2008 ROD to be adversely affected. This
could potentially include surface cracks and fissures in the cap extending down into the waste material, and
potentially cause permeation of the cover used. Surface cracks and fissures may allow gases (such as radon and
steam) to escape, and potentially create conditions that could allow fine particulates to escape from the landfill. Since
we do not have a full accounting of the material in OU-1, we cannot make a definitive assessment regarding the
potential for chemical reactions between the RIM and non-RIM materials if an SSE were to occur. If these reactions
were to occur, they could cause a rapid buildup of heat or gas, and subsequent reactions or reactive conditions in the
landfill.
EMSI Executive Summary Bullet Point #3: An SSE may allow radon gas to more easily rise through the
ground and reach the surface of the landfill than would otherwise occur, because heat will/would reduce the
amount of moisture in the buried solid waste (trash) thereby increasing the amount of air between the soil
particles and thus limiting the ability of the buried solid waste to retain radon below ground. Any radon gas
that does make it to the surface would dissipate quickly in open air. This potential increase in the rate of
release of radon gas at the surface of the landfill would be limited to the area of the SSE and would stop
when the SSE ends.
ETSC Observations: A SSE in OU-1 would be expected to create increased pressure conditions within the landfill and
force out entrained gases, including radon. Possible damage to the cap called for in the 2008 ROD from the SSE may
allow these gases to escape. Also, a SSE may be present in OU-1 for a long period of time before it is detected,
because the only apparent means to detect a SSE after closure is through annual visual inspections. Given that
measurements of radon in air during the SFS were close to a Uranium Mill Tailings Radiation Control Act (UMTRCA)
standard, there is the potential for radon releases at levels of concern if a SSE occurs in OU-1. This observation does
not consider other environmental conditions that could cause radon and other landfill gas concentrations to increase
at ground level, such as atmospheric inversions.
EMSI Executive Summary Bullet Point #4: An SSE in West Lake Area 1 or 2 would create no long-term
additional risks to people or the environment.
ETSC Observations: We do not support the conclusion that no additional long term risks would be created in the
event of a SSE at OU-1. There are at least two risk pathways that could exist from a SSE. The first is through
increased air exposures to contaminants such as radon. As airborne concentrations of radon increase, so would the
risk to people. The second pathway is increased leachate production that could move contaminants and dissolved
radon gas from OU-1 into the groundwater. Sampling would be needed to monitor whether either of these two
exposure pathways becomes an issue.
EMSI Executive Summary Bullet Point #5: Any short-term risks would be associated with the temporary
increase in radon gas coming from the surface of the landfill if no cap is installed on the landfill, or if the cap
called for by the 2008 ROD was not properly maintained.
ETSC Observations: Short-term effects of a SSE could also include greater amounts of leachate production, which
has been observed at the Bridgeton Landfill from condensation of large amounts of steam. A SSE may result in
increased emissions of radon and other contaminants in the air and groundwater, even with annual inspections and
proper maintenance of designs discussed in the 2008 ROD and 2011 SFS.
EMSI Executive Summary Bullet Point #6: These short-term risks can be addressed by designing, building,
and maintaining the landfill cap called for by the 2008 ROD, and by maintaining the land use restrictions
already in place on the entire West Lake property, which prevent certain site uses.
ETSC Observations: As stated earlier, if a SSE occurs, short-term risks may be present even with proper cap design,
inspection and maintenance.
EMSI Executive Summary Bullet Point #7: There are no additional ARARs associated with an SSE.
ETSC Observations: There do not appear to be additional Applicable or Relevant and Appropriate Requirements
(ARARs) for the site if a SSE were to occur.
Attachment 2 - National Remedy Review

Board Discussions Regarding the Remedy at
the West Lake Landfill Superfund Site,
February 28, 2013
Draft Deliberative Process Privileged Do not cite or quote
Final Draft February 28, 2013
National Remedy Review Board Discussions Regarding the Remedy at the West Lake Landfill
Superfund Site
Purpose
The Board conducted this consultation on February 29, 2012. The review of the West Lake Landfill
operable unit 1 (OU1) potential remedial action was planned to be a full review culminating in a
recommendations memo. After the presentation to the Board and based on feedback from Board
members, the Region concluded that additional work was appropriate and requested an optional early
consultation. Under NRRB guidelines, Regions may request an optional NRRB consultation on remedial
alternatives at any time prior to the draft proposed plan. The discussion captured in this document
reflects basic ideas and general suggestions based on the Boards professional experience and
knowledge of regional practices.
Site Summary
The West Lake Landfill Site (the Site) is on a parcel of approximately 200 acres located in the
northwestern portion of the St. Louis metropolitan area. The Site consists of the 1) Bridgeton Sanitary
Landfill (Former Active Sanitary Landfill), 2) Radiological Area 1, 3) Radiological Area 2, 4) Buffer
Zone/Crossroad Property, and 5) Closed Demolition Landfill. The Site was used agriculturally until a
limestone quarrying and crushing operation began in 1939. The quarrying operation continued until
1988 and resulted in two quarry pits. Beginning in the early 1950s, portions of the quarried areas and
adjacent areas were used for landfilling municipal solid waste (MSW), industrial solid wastes, and
construction/demolition debris. These operations were not subject to state permitting because they
occurred prior to the formation of the Missouri Department of Natural Resources (MDNR) in 1974. Two
landfill areas were radiologically contaminated in 1973 when they received soil mixed with leached
barium sulfate residues.
The barium sulfate residues, containing traces of uranium, thorium, and their long-lived daughter
products, were some of the uranium ore processing residues initially stored by the Atomic Energy
Commission (AEC) on a 21.7-acre tract of land in a then undeveloped area of north St. Louis County,
now known as the St. Louis Airport Site (SLAPS), which is part of the St. Louis Formerly Utilized Sites
Remedial Action Program managed by the U.S. Army Corps of Engineers.
In 1966 and 1967, the remaining residues from SLAPS were purchased by a private company for
mineral recovery and placed in storage at a nearby facility on Latty Avenue under an AEC license. Most
of the residues were shipped to Canon City, Colorado, for reprocessing except for the leached barium
sulfate residues, which were the least valuable in terms of mineral content, i.e., most of the uranium and
radium was removed in previous precipitation steps. Reportedly, 8,700 tons of leached barium sulfate
residues were mixed with approximately 39,000 tons of soil and then transported to the Site. According
to the landfill operator, the soil was used as cover for municipal refuse in routine landfill operations.
The Site has been divided into two OUs. OU 1 consists of Radiological Area 1 and Radiological Area 2
(Areas 1 and 2) and the Buffer Zone/Crossroad Property. OU 2 consists of the other landfill areas that
are not impacted by radionuclides, i.e., the Closed Demolition Landfill, the Inactive Sanitary Landfill,
and the Former Active Sanitary Landfill. OU 1 is the subject of this review.
Comments
Site Characterization
Based on the information presented to the Board, it appeared that there were some samples of site
groundwater that exceed standards considered to be applicable and relevant or appropriate requirements
(ARARs). Also, the package provided to the Board states that the OU1 and OU2 RODs provide the final
remedial actions for both source control and groundwater and complete the CERCLA decision-making
for the Site. In addition, the Region stated that since no discernible plume was identified at this site, the
Regions preferred approach was to take no remedial action at the present time but to continue
monitoring groundwater. The Board notes that under existing Agency guidance, action may be
warranted if a chemical specific standard that defines acceptable risk is violated (Office of Solid Waste
and Emergency Response (OSWER) Directive No. 9355.0-30, April 1991, Role of the Baseline Risk
Assessment in Superfund Remedy Selection Decisions). OSWER Directive No. 9283.1-33, June 2009,
Summary of Key Existing EPA CERCLA Policies for Groundwater Restoration also discusses whether
CERCLA remedial action is warranted under these types of conditions. Since the NCPs expectation in
300.430(a)(1) (iii)(F) states that wherever practicable EPA expects to return usable ground waters to
their beneficial uses, the Board suggests that the Region consider adding wells at the site to better
delineate the vertical and lateral extent of potential site-related contamination previously indentified
from limited sampling in Areas 1 and 2. These additional wells would be instrumental in clarifying the
presence of isolated groundwater contamination versus a groundwater plume in the complex subsurface
geologic setting, and would help inform a decision about whether CERCLA response authority is
warranted to address any additional contamination.
The package provided to the Board at page 22 states that Only four wells exhibited a total radium
concentration above 5 picoCuries per liter (pCi/l). These exceedances ranged from 5.74 pCi/l to 6.33
pCi/l. The slight exceedances are isolated spatially. Two of the four wells with total radium exceedances
are located in areas that are not downgradient of either Radiological Area 1 or Radiological Area 2. The
chart on page 21of the package, however, indicates that there were two wells with exceedances and that
the maximum detected concentration was 8 pCi/l. The Board suggests that the Region reconcile these
discrepancies.
Waste Characterization
Location of Radiologically Impacted Material - The site review package and power point presentation
provided to the Board characterized radiologically impacted material (RIM) at the site to be: 1)
intermixed throughout the landfill matrix, 2) consisting of municipal refuse in Area 1, and mostly
construction and demolition debris in Area 2, 3) dispersed both laterally and vertically at depths up to 15
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feet in Area 1 and 12 feet in Area 2 with some localized occurrences that are deeper , and 4)
representing an amount of hazardous fill equal to 500,000 cubic yards (cy). The Board notes that the
remedial investigation (RI), the 1982 Nuclear Regulatory Commission (NRC) Radiological Survey and
the 1988 NRC report describe the RIM to be in an identifiable and relatively localized area (e.g., a thin
layer in the upper part of the landfill) which is consistent with the short time period that RIM was
brought to the landfill relative to its long operating life. The Board also notes that some of the RI boring
data indicating deeper contamination was footnoted as not credible or representative (i.e., RIM knocked
into the boring holes during drilling or logging activities). The Board is concerned that inconsistencies in
the waste characterization may have led to significant uncertainties in determining the location and
volume of RIM in the landfill.
Volume of RIM - The site review package and power point presentation provided to the Board
indicated an amount of hazardous material to move equal to 500,000 cubic yards (cy). Though using
different reference levels, the Board notes that the RI report estimated the volume of RIM to be about
143,000 cy, which is similar to the amount (approximately 150,000 cy) identified in the 1982 and 1988
NRC reports. The large uncertainty related to the location and volume of RIM could negatively impact
the alternatives evaluation process (including how the cost and feasibility of various implementation
options have been evaluated) and lead to a preferred alternative that may not be protective or cost
effective. Thus, a smaller volume of RIM would make consideration of other alternatives (i.e., an on-site
disposal cell or off-site disposal at a commercial facility) more feasible and realistic.
The Board suggests that the Region carefully examine the data and information contained in the RI and
NRC reports to ensure that the location and volume of RIM is accurately characterized and if necessary
consider conducting further investigations possibly using test trenches. Furthermore, the range of
alternatives should include options for addressing the likely volume and location (including hot spots) of
RIM at the Site.
Future Land Use
The supplemental feasibility study (SFS, page 62) indicates that the cleanup standards to be used for
the development and evaluation of the complete rad removal are background-based standards. The
SFS also appears to have used unrestricted land use in estimating the volume of RIM that would have to
be removed under a complete rad removal scenario. The Region indicated that the West Lake Landfill
property is zoned industrial/commercial and will stay that way. The Board believes that using
background-based standards and unrestricted use may have led to overstating the volume of RIM that
would have to be excavated and possibly treated under a complete rad removal alternative. The Board
suggests that the Region use a more reasonable future use assumption of industrial/commercial and
based on this land use, recalculate the volume of RIM to be removed.
Principal Threat Waste
Based on the documents provided to the Board, it appears that there are potentially significant amounts
of RIM that are highly toxic (e.g., based on NRC estimates in the 1982 and 1988 reports, radium up to
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22,000 picoCuries per gram (pCi/g), bismuth-214 up to 19,000 pCi/g, and average thorium-230
concentrations of 9,000 pCi/gr; the package at page 44 notes that the RI report discussed thorium-230 at
levels as high as 57,300 pCi/gr and that the highest gamma peak intensity readings are at shallow
depths). The FS states (page 84) that most of Area 2 contains RIM at levels above 100 pCi/gr. The NRC
reports also discuss how the toxicity of this RIM will continue to increase over time: Ra-226 activity
will increase in time (for example, over the next 200 years, Ra-226 activity will increase nine-fold over
the present level). This increase in Ra-226 must be considered in evaluating the long-term hazard posed
by this radioactive material. (1988 NRC report, page 14). The SFS also acknowledges this fact. Thus,
based on the data, it appears there is discrete, accessible highly toxic principal threat waste at this site.
OSWER Directive No. 9380.3-06FS, November 1991, A Guide to Principal Threat and Low Level
Threat Wastes, provides guidance on several related issues, including the NCPs expectations for
treatment of principal threats posed by the site, wherever practicable. The Board suggests that the
Region carefully consider the range of alternatives developed for this site and explain in its decision
documents how the preferred alternative, when selected, will be consistent with CERCLA and NCP, or
publish an explanation as to why not. In particular, the Region should more fully explain how its
approach to treatment is consistent with the statute and the NCP, including specifically CERCLA
121(b)(1)s preference for treatment to the maximum extent practicable; CERCLA 121(d)(1)s
requirements regarding protectiveness and applicable or relevant and appropriate requirements; 40 CFR
300.430(a)(1)(iii)(A)s expectation that treatment [be used] to address the principal threats posed by a
site, wherever practicable; and 40 CFR 300.430(f)(1)(ii)(E)s preference for treatment to the
maximum extent practicable while protecting human health and the environment, attaining ARARs
identified in the ROD, and balancing the five primary criteria listed in the NCP.
Remedy Performance
Removal/excavation - In light of the waste characterization (above) and treatment (below) comments,
and data indicating that much of the RIM may be located relatively near the surface; it appears feasible
to remove more highly contaminated material and significantly reduce long-term risk at the site. The
Board is aware of ongoing cleanups in other Regions where the reduction of radiologically-impacted
source material is being safely and efficiently undertaken in a manner that is protective both to the
workers and the community. If the RIM is located near the surface in a discreet layer, it can be sorted
out in the field with instruments that provide instantaneous measurements to ensure that only
contaminated material is retrieved which, in turn, minimizes disposal costs. The Board suggests that the
Region consider developing an alternative that includes sorting and removing the RIM in a precise
manner using performance standards for the excavation process and includes treatment to the maximum
extent practicable. The Board also suggests that cleanup levels reflect the fact that the site is zoned
industrial/commercial and is most likely to stay that way given the reasonably anticipated future land
use.
Treatment - The Board notes that several treatment technologies were evaluated and screened out during
the FS process. The Region did evaluate a complete rad removal approach and indicated that none of
the 13 treatment technologies were able to deal with the extremely heterogeneous mixture of the
radiologically contaminated soil and MSW. Thus, none of the remedies evaluated in the SFS meet the
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preference for treatment. (package, page 34). The Board notes that treatment can include measures
taken to reduce volume. So, regardless of whether the RIM resides in a heterogeneous or a homogeneous
distribution, volume separation techniques (volume reduction) and off-site disposal in a dedicated and
regulated radioactive disposal unit may result in a more permanent remedy if short-term risks are
minimized by engineering controls, personal protection equipment, or administrative controls, as well as
if the radioactive waste is able to be physically sorted from the other waste in the landfill. If some, most
or all of the RIM can be detected, distinguished by emission signals, and resides in distinct
homogeneous layers, field screening techniques or an on-site laboratory can be used for isolation
followed by removal. If the waste resides in a more heterogeneous distribution, commercial sorting
technologies, using multiple scanning spectroscopic techniques (that have been used on federal facility
sites) and/or an on-site laboratory, should be considered and evaluated. This is especially true for the
RIM in Area 2, since it appears that construction fill (as opposed to sanitary fill) was added to cover
the contamination on this portion of the site, and Area 2 contains the majority of the RIM and
overburden. A reduction in volume may make off-site disposal a more cost-effective alternative. These
radioactive signal sorting processes could also be considered if a portion of the surface radioactive waste
is planned to be consolidated under a final cover. The Board suggests that the Region reconsider
treatment alternatives or provide more explanation for ruling out an in-situ or ex-situ
solidification/stabilization process that is specifically designed for both the high sulfate content and
saturated conditions found at this site.
Short-term Effectiveness - The package provided to the Board includes a comparison of the short-term
effectiveness of the three action alternatives. The comparison is presented as risk estimates that are
presumed to potentially occur to nearby residents during remedy implementation. The lowest
carcinogenic risk presented is for the capping alternative, while the risks to residents during remedy
implementation estimated for the two alternatives that include removal of radiation-related material is an
order of magnitude higher. However, all of the short-term risks were within the risk range of 10-4 to 10-6.
The Board notes reduction of rad-impacted source material currently is being undertaken at other sites in
a manner that is protective and without unacceptable short-term impacts, where it has been determined
that eliminating the source is an important objective of the cleanup. Therefore, based on the fact that the
Agency has safely cleaned up numerous hazardous waste sites with radiological contamination across
the country, including many in residential areas, the cleanup work can be done safely without
unacceptable risk in accordance with approved health and safety plans and appropriate engineering
controls as necessary to ensure that any risks to the community are minimized and mitigated. The Board
suggests that the Region re-evaluate the alternatives against the nine criteria, including those listed on
page 32 of the package, pursuant to 40 CFR 300.430(e)(9)(iii).
The short-term effectiveness comparison also includes effects from transportation accidents. Truck and
other industrial injuries/fatalities are not generally environmental risks that should be considered in a
short-term effectiveness analysis, especially for common earthmoving/hauling alternatives such as these.
While an unusually high incidence of accidents may be of concern, potential worker accidents are
typically addressed through project health and safety plans. Consistent with the NCP
(300.430(e)(9)(iii), the Board suggests that the comparison be re-evaluated focusing on the extent to
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which accidents expose workers or the community to possible releases resulting from such accidents,
and considering mitigative measures during implementation.
The short-term effectiveness section described impacts to the community during implementation. The
presentation also included a discussion of potential environmental justice (EJ) issues that may be
encountered if waste is transported off-site. The Board notes that impacts to the community or EJ issues
were not included in the section describing the long-term effects of leaving the waste in place.
Consistent with NCP 300.430(e)(9)(iii), the Board suggests that an analysis of both short-term and
long-term effects on the community (including any sensitive or potentially high-exposure
subpopulations) be included in the detailed analysis in future decision documents.
Also, in the presentation to the Board, one of the Regions points for not carrying forward the
excavation and off-site disposal alternative is the possibility of constrained funding ($10M/year if
cleanup is done as a Fund-lead). The presentation states that it could take from 22-28 years to complete
the work if funded at $10M/year. The Board notes that the short-term effectiveness provision in the NCP
(300.430(e)(9)(iii)(E)) does not include funding as a consideration.
Long-term Effectiveness - The package presented to Board described an alternative as a hybrid
cap/cover design incorporating both Resource Conservation and Recovery Act (RCRA) Subtitle D and
Uranium Mill Tailings Radiation Control Act (UMTRCA) cover design features applied to an existing
unlined landfill. However, the package lacked sufficient information on the long-term protectiveness of
this alternative. Specifically, how the cap/cover remains protective given the increasing daughter
ingrowth concentrations of radium 226/228, radon 222, and the increase in toxicity over time (1,000
years).
Both of these cover designs (RCRA Subtitle D and UMTRCA) have shortcomings for RIM waste itself,
especially in a humid region. A comparison of various landfill capping designs addressing both humid
region conditions and long-term protection from RIM (1,000 years) would be an important concept for
the preferred remedy. However, the package did not appear to include alternative cap designs, i.e., EPA
landfill cap guidance design, existing cap designs for similar RIM at Weldon Springs, or
evapotranspiration cover cap system designs (OSWER Fact Sheets: EPA 542-F11-001, February 2011,
Fact Sheet on Evapotranspiration Cover Systems for Waste Containment). For example, a RCRA
Subtitle C/UMTRCA hybrid may be suitable for both long-term infiltration management and radiation
shielding protection. The Board suggests that the Region include in its remedy selection process
evaluations of cap designs similar to, but not limited to, the above conditions and guidances. The
package also does not address several aspects of the potential for future migration of contamination to
groundwater. The fact that the Region believes there is no discernible plume above MCL levels may not
be a sufficient basis to determine there is little or no potential for groundwater contamination that should
be addressed consistent with the NCPs expectations. Particularly in light of the long-lived toxic nature
of the radioactive contaminants as well as chemical and physical changes over time at the landfill, the
Board suggests that a more rigorous evaluation of potential migration to groundwater be undertaken.
The evaluation should not assume that pumping at the former active sanitary landfill will continue,
unless that is part of this remedy. For these reasons, the Board suggests that the Region consider
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examining additional information on alternative cap designs plus fate and transport of groundwater that
supports long-term protectiveness.
Applicable or Relevant and Appropriate Requirements
UMTRCA - In the package provided to the Board, the ARARs discussion (page 45) states that
UMTRCA is an ARAR for waste that eroded off Area 2, yet only a to-be-considered (TBC) criteria for
the design of the cap over Areas 1 and 2; the reason provided by the Region being that the eroded waste
resembles a mine tailings pile while the MSW landfill areas do not.
The Board suggests that the Region further clarify why UMTRCA is considered an ARAR for purposes
of cleaning up RIM that has eroded from Area 2 onto adjoining land (which does not in fact resemble a
staging pile), but not for purposes of cleaning up RIM that appears to be located in Area 2 at and just
below the surface. Since the RIM on the adjacent property apparently comes from RIM in Area 2 and is
the same material, and the contamination is similarly situated in both Area 2 and the adjacent property
(i.e., at or near the surface), and neither location serves or was intended to serve as a waste pile, the basis
for the distinction being made for ARARs purposes between Area 2 and the adjacent property is not
clear.
The Board agrees that the UMTRCA standards most likely was not written for a situation where
contamination such as the RIM here would be disposed of in an unlined (i.e., no sides and no liner on
the bottom) solid waste disposal unit; however, to the extent UMTRCA is designed to address
contamination somewhat like the RIM at this site (even though those standards appear to be designed for
similar contaminants but at concentrations of only up to 1000 pCi/gr), it provides a useful regulatory
benchmark on how to handle, dispose of, and cap this kind of material. Nonetheless, the UMTRCA
standards would appear potentially relevant and appropriate for ARAR purposes when evaluating factors
like the longevity/integrity of a unit serving as a repository for centuries.
The Board notes that even if UMTRCA standards are considered as an ARAR, meeting those standards
may not ensure protectiveness over the long-term for several reasons, including RIM at levels currently
measured at up to 57,300 pCi/gr of thorium, as well as the increasing daughter ingrowth concentrations
of radium 226/228, radon 222, and the increase in toxicity projected to peak at about 700,000 pCi/gr.
over time (1,000 years). While the package states that consistent with UMTRCA, the cap design will
include a rubble layer and the final caps on Areas 1 and 2 will meet the radon emission standards
provided for in UMTRCA it does not state that the cap design will meet the UMTRCA standards. The
Board suggests that the Region evaluate whether the alternatives under consideration for Area 2 will
meet the UMTRCA standards as ARARs, as well as any NRC standards (and guidance that might serve
as TBCs) that exist for licensed facilities storing or disposing of radiological waste.
RCRA - The package indicates that RCRA subtitle D regulations represent the primary standards for
design and implementation of a containment remedy. The Board notes that OSWER Directive No.
EPA/540/P-91/001, February 1991, Conducting Remedial Investigations/Feasibility Studies for
CERCLA Municipal Landfill Sites does state that RCRA Subtitle D closure requirements are generally
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applicable. However, it is not clear to the Board how a municipal solid waste regulation (e.g., provisions
governing an MSW landfill) could be considered as a controlling ARAR for disposal of non-MSW
material, especially material as hazardous as the RIM at this site (e.g., RIM at levels currently measured
at up to 57,300 pCi/gr,, with increase in toxicity projected to peak at about 700,000 pCi/gr). The Board
notes that Areas 1 and 2 were not permitted as subtitle D landfills or licensed as an NRC facility, and is
not aware of other sites where RCRA Subtitle D standards have been considered as the correct
benchmark for management of waste like the RIM at this site. The Board suggests that the Region
carefully consider the appropriateness of using RCRA Subtitle D regulations for RIM, where radium226 activity will increase by a factor of thirty-five 1,000 years from now, as an ARAR for this site.
Federal Aviation Administration Guidance - With regard to the Federal Aviation Administration (FAA)
Guidance, the Board agrees with the Region that this guidance is not an ARAR, and acknowledges the
importance of ensuring flight safety in the vicinity of the site. The Board notes that all of Area 2 of the
site is more than 10,000 feet from the runway, that it appears that about half of Area 1 is also more than
10,000 feet from the runway, and that for the relatively small portion of Area 1 that is inside the 10,000
foot perimeter, it should be feasible to use netting or other devices (e.g., movable tent or building) for
the short amount of time that would be needed to excavate or treat (e.g., solidification) the RIM material
found at or near the surface of Area 1, if an alternative reflecting that approach were to be selected.
Thus, the FFA guidance may inform, but does not inhibit, actions involving the processing of materials
if an alternative including excavation and hauling is chosen. During the presentation, the Region
mentioned an agreement between the landowner and the FAA addressing property that may be partially
addressed by the FAA guidance. The Board also notes that while important to acknowledge, the
agreement is not an ARAR and does not otherwise limit EPAs broad response authority under
CERCLA.
Executive Orders - Furthermore, the review package indicates in the section discussing ARARs (page
45) that Executive Order 11988 and Missouri Governors Order 82-19 are regulations [that] are remedy
drivers. The Board notes that while executive orders like these are important considerations, neither of
these orders represent the kind of promulgated, enforceable, generally applicable (or waiveable)
regulations or standards that qualify as ARARs. However, to the extent they are considered as remedy
drivers, the Region should evaluate and explain in its future decision documents how these orders
provide for a protective remedy.
List of ARARs - Finally, the Board also notes that some of the citations included in the ARARs tables
provided in the SFS may not be described in enough detail pursuant to EPA/540/G-89/006, August
1988, CERCLA Compliance With Other Laws Manual. The Region should work closely with their
Office of Regional Council to clarify the list of ARARs.
Cost
According to the information presented to the Board, the discount rate used for the net present worth
cost calculations in the SFS was 2.3 percent. However, the Board notes that in accordance with current
EPA guidance, OSWER Directive No. 9355.0-75, July 2000, A Guide to Developing and Documenting
West Lake
Cost Estimates During the Feasibility Study, a discount rate of 7 percent should generally be used for all
non-Federal facility FS present value analyses and, if a different discount rate is selected, a specific
explanation should be provided and/or a sensitivity analysis performed to evaluate the discount rate
impacts. The Region should either: (1) use a discount rate of 7 percent for all present worth calculations
(as was done for the 2008 ROD), or (2) provide an explanation and sensitivity analysis in accordance
with the above-noted 2000 EPA guidance. The Board also suggests that if the 2.3 percent rate is carried
forward that both the 7 and 2.3 percent rates be provided, with appropriate explanation, for comparison
purposes.
In addition, a containment alternative that will require perpetual operation and maintenance to remain
protective was presented to the Board. Based on the information provided in the SFS, the cost estimate
for this alternative does not appear to include all costs that would be necessary to effectively maintain
the remedy in perpetuity and because of this, there may not be an accurate evaluation of costs. The costs
identified only include mowing grass and filling holes that develop over time. The Board suggests that
the Region recalculate (and explain in its decision documents) the cost of this alternative to include all
of the components of the cap, what perpetual operation and maintenance is required for each of these
components (which likely includes repair and replacement), and the costs associated with that work.
West Lake
Attachment 3 - Comments from NRRB

Reviewer John Frisco on PRP Scope of Work
- Alternative Cover Designs and Fate and
Transport Modelling
West Lake Landfill

Scope of Work: Alternative Cover Designs and Fate and Transport Modelling
Alternative Cover Designs
Not sure why an ET Cover is even being considered at the site since its deficiencies have already
been identified (Albright and Benson) .
Disposal of similar waste at Weldon Springs has an established cover design with a proven
performance history that should be considered . While the Weldon springs cover might appear
as over-engineering, components of the system are effective and could reduce cost and material
mass tot eh West Lake cover.
The option of evaluati~g a more protective RCRA cover should be considered . While a RCRA
Subtitle C cover system might be very conservative it does compensate for the lack of a liner
system with leachate collection .
The lack of a cover system that uses a geosynthetic liner is missing. While there are limitations
to solely using a geosynthetic liner, proper engineering allows for effective performance.
Fate and Transport Modeling
The use of the various models should be sufficiently flexible to accommodate the range of
landfill system specifications, identified in the SCOPE and suggested above.
The assumption offuture radium decay needs to be critically evaluated and accounted for.
While the SCOPE discusses simulating future climate conditions and subsequent infiltration, the
inclusion of resident moisture need to accounted for in all simulations.
The incorporation of a colloidal transport simulation should be included since it has been
already identified that the depth of contaminant is selected area was deeper that expected due
to aqueous transport.
The statement indicating that co-precipitation is expected to be a dominant process appears to
be a bit premature and unsupported .
The statement regarding the influence on increasing pH is unusual. While it is recognized that
biodegradation processes will general result in reduced redox and pH; without an alkaline
source, the pH in the aqueous environment will be challenged to increase above neutral pH, and
likely to remain less than neutral.
The "Graded Approach" looks to be a reasonable approach to the addressing he modeling issue.
While this effort is solely identified as modeling, it was be remiss to not include corroboration of
the modeling with supporting groundwater monitoring well data . Just caution on the
elimination of pathways too earnestly. Should establish an " accepted" criteria for discontinuing
model runs.
The most controversial areas at West Lake LF would benefit from the installation of additional
groundwater monitoring wells, especially in the 'washout' area and along Charles Road where
groundwater-surface water interface occurs.
While not adverse to the use of the following models: HELP, HYDRUS and PHREEQC, all well
known to the commenter. It might be constructive to use some other models that are EPA
supported (e.g., MINTEQA2)
Attachment 4 - Internal E-Mail from NRRB

Reviewer John Frisco dated February 15th,
2012
Fw: West Lake Landfill

Craig Smith to: Dan Gravatt
02/15/2012 12:20 PM
Cc: Audrey Asher, DeAndre Singletary
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/USEPA/US on 02/15/2012 12:20 PM----From:
To:
Cc:
Date:
Subject:
John Frisco/R2/USEPA/US
Amy Legare/DC/USEPA/US@EPA
Andy Zownir/ERT/R2/USEPA/US@epa, Cami Grandinetti/R10/USEPA/US@epa, Carlos
Sanchez/R6/USEPA/US@epa, Charles Openchowski/DC/USEPA/US@epa, Christina
Skaar/DC/USEPA/US@epa, Craig Smith/SUPR/R7/USEPA/US@epa, David
Jewett/ADA/USEPA/US@epa, Ed Barth/Cl/USEPA/US@epa, John Chesnutt/R9/USEPA/US@epa,
Linda Dietz/R3/USEPA/US@epa, Lois Gartner/DC/USEPA/US@epa, Mark
Sprenger/ERT/R2/USEPA/US@epa, Michael Sivak/R2/USEPA/US@epa, Mike
Jasinski/R1/USEPA/US@epa, Peter Ludzia/R3/USEPA/US@epa, REBECCA
FREY/R5/USEPA/US@epa, Richard Campbell/R4/USEPA/US@epa, Ron
Wilhelm/DC/USEPA/US@epa, Stanley Christensen/R8/USEPA/US@epa, Timothy
Mott/DC/USEPA/US@epa, Timothy Prendiville/R5/USEPA/US@epa
02/15/2012 08:45 AM
West Lake Landfill
Let's try this again -- I accidentally hit the send button prematurely. As I started to say, I'll be away next
week and will miss the pre-review call and wanted to offer a few thoughts in preparation for the actual
review. To begin with, there is a lot of information on the website -- I've only gotten through a portion of it
so far and am basing my comments on what I have seen. Given the volume of material, it's important that
the board have good understanding ofthe site and what's gone on there over the years which I hope can
be accomplished via a webinar vs a face-to-face meeting (which might have been preferable in this case).
When it comes to possibly removing material from within a landfill, the most important factor is its location
-- do you know where it is and can you safely and efficiently retrieve it? Radiological contamination
remains active for a very long time and would require long-term management wherever it ends up. For
this reason, where possible, we try to send such material to facilities designed specifically for this purpose
(e.g., Idaho, Utah). If one could safely and efficiently extract the radiological waste, that might be an
option worth consideration. Unfortunately, the location of the waste is at issue.
The NRC report identifies a relatively definitive waste location not too deep in the landfill. In contrast, the
RI suggests the radiological contamination is much more wide-spread. According to some documents,
the radiological material was brought to the landfill in one event. This would tend to support the NRC
study results about the location of the radiological waste. If the waste was shipped to the landfill during its
operation over a number of years, one would expect to find it throughout the landfill -- both horizontally
and vertically. One of the key questions for the region is to better explain the RI results given the manner
in which the radiological material arrived at the landfill .
One additional observation -- the removal numbers (volume and cost) may be somewhat high since I
believe they assume transporting all excavated waste to an off-site commercial facility. We have
considerable experience in cleaning up sites with radiological contamination here and have found that
field instruments can quickly and accurately allow for the separation of the radiological materials . This
reduces both the volume and cost of off-site disposal.
Lj
07 /
40451957
vl1-ot
IIHll lllllllllllllllllllllllllllllllllllllllllll
Superfund
Again -- for the webinar, the region should be prepared to describe how the site operated and, in
particular, to reconcile the conflicting results and conclusions of the two investigative efforts. It's possible
that this information is already included among that put up on the website that I have not read yet.
However, since I'm not going to be around, I wanted to highlight this one point for further discussion and
clarification given its importance in this case.
Thanks.
Attachment 5 - Comments from NRRB

Reviewer Charles Openchowski on PRP
Scope of Work for groundwater dated May
14th,2013
I Page 2: [1] Commented
Charles O.
5/14/2013 3:51:00 PM
The Board's draft recommendations from spring of 2012 included other things that are relevant to this SOW for
ground water, including language from the initial draft ("Groundwater:
monitoring wells
placed in perimeter fashion; dated GW data-gather new data now;
wells seem to be clustered-large gaps-need wells in between gaps to
determine if there is, in fact, a plume issue (e.g., predesign installation
of new wells); if we can't fully characterize GW, then we need to have a
sufficient record to substantiate that conclusion"), as well as later
Ve rsi 0 ns Which Sa j d: " Based on the information presented to the Board, it appears that there have
been some samples of groundwater at this site that exceed standards considered as ARARs . The Region also
stated that no discernable plume at this site has been identified, and its preferred approach is to continue
monitoring groundwater. Generally, under existing Agency guidance, exceeding a maximum contaminant level in
groundwater normally would warrant a response action (OSWER Directive 9355.0-30, Role of the Baseline Risk
Assessment in Superfund Remedy Selection Decisions and OSWER Directive 9283.1-33 Summary of Key Existing EPA
CERCLA Policies for Groundwater Restoration). The Board recommends that the Region consider additional wells
at the site to better delineate the vertical and lateral extent of potential site-related contamination previously
indentified from limited sampling in Area 1 and especially Area 2. These additional wells would be instrumental in
clarifying the presence of an isolated groundwater hot-spot versus a groundwater plume in the complex
subsurface geologic setting. In addition, the Region should explain why there are numerous decommissioned wells
on site. Sampling of these wells may have provided a more complete picture of potential groundwater
contamination . The general recommendation is that the additional wells be nested along the western border
(Crossroad property) of Area 2 in the unconsolidated alluvial deposits and the underlying fractured and vuggy,
limestone Keokuk formation . The Board also notes that the Agency's long-standing policy has been that
monitoring by itself is not a CERCLA remedial action, and believes that the information submitted to the Board may
not support a conclusion that monitoring to evaluate effectiveness of the source control remedy (if that approach
is selected) would constitute an effective or final groundwater response action for this site . As such, the Board
recommends that the decision documents clearly explain the role of monitoring in the Region's preferred
approach, and indicate that any potential groundwater cleanup would be addressed in a separate decision
document in the future representing a final ground water remedial action, should one be needed.
In addition, the package at page 22 states that "Only four wells exhibited a total radium concentration
above 5 pCi/I. These exceedances ranged from 5.74 pCi/I to 6.33 pCi/I. The slight exceedances are
isolated spatially. Two of the four wells with total radium exceedances are located in areas that are not
downgradient of either Radiological Area 1 or Radiological Area 2." The chart on page 21, however,
indicates that there were two wells with exceedances and that the maximum detected concentration
was 8 pCi/I. The Board recommends that the Region reconcile these discrepancies.
I Page 3: [2] Commented
Charles
o.
5/16/2013 5:08:00 PM
This appears inconsistent with Board's views expressed during meeting and in spring 2012 draft recommendations
- for example: "Based on the package provided to the Board, it appears that there are potentially
significant amounts of RIM that are highly toxic (e.g., based on NRC estimates in the 1982 and
1988 reports, radium of up to 22,000 pCi/gr, bismuth-214 of up to 19,000 pCi/g, and average
thorium-230 concentrations of 9000 pCi/gr; the package at page 44 notes that the RI report
discussed thorium-230 at levels as high as 57,300 pCi/gr) and that the highest gamma peak
intensity readings are at shallow depths. The FS states (page 84) that most of Area 2 contains
RIM at above 100 pCi/gr. The NRC reports also discuss how the toxicity of this RIM will continue
to increase over time: "Ra-226 activity will increase in time (for example, over the next 200
years, Ra-226 activity will increase nine-fold over the present level). This increase in Ra-226
must be considered in evaluating the long-term hazard posed by this radioactive material."
(1988 NRC report, page 14). The SFS also acknowledges this fact. Thus, based on the data, it
appears there is discrete, accessible highly toxic principal threat waste at this site."
Attachment 6 - Internal Comments by

Charles Openchowski on PRP groundwater
Scope of Work, April 19th, 2013
Scope of Work and Schedule

Fate and Transport Modeling
Introduction
The U.S. EPA's October 12, 2012 ette L( USEPA, 2012) requested that the Respondents perform fate and
Commented [caol]: Not sure what this letter Is hosed on as far

as Board recommendations Is concerned since no final Board memo
had been sent by this date -
transport modeling at the West Lake Landfill (the Site). This Scope of Work (SOW) describes the
modeling approach proposed to estimate potential fluxes of landfill leachate, possible radionuclide
concentrations within the leachate, and the potential for transport of any radionuclide-contaminated
I
1
1
leachate within the subsurface.
Commented [cao2]: Board's dnift recommendations prepared

between February and May 2012 recommended 1therl111
addltional data to -
formatted: Highlight
This SOW first outlines the objectives of the proposed modeling task. This is followed by a discussion of
Commented [cao3]: In several places, language appears

1 inconsistent with Board's spring 2012 draft recommendations. For
the general conceptual site model (CSM). Features of the Site that are expected to be simulated are
11 example. ~ithin the landfill" toacther with "'IS cover for munklp.11
described together with potential events and the physical and chemical transport processes that are
;, refuse Jn the prevk>us sentence, nd statements m11de on paae 4
1 1 below, seems lnconsJstent with the Board's initial
1
envisioned as being incorporated in the modeling analyses. After describing the CSM and defining the
1
11 olloervatioos/comments/recommendations contained which included
1 1
objectives of the modeling calculations - which together define the necessary capabilities of the
1
the followina statements: I) "The Board noces that the 1982 NRC
: ~ RadiolQ&ical Survey states that the rqirescntation of subsurfilce
developed model - the calculation approach and the simulation programs proposed to meet the
t
contamination
based on au.a;er hole measurements in Fiaurcs IS - 19
11
1
of that report "are coos istent with the operating history of the site,
modeling objectives are identified. The final suite of scenarios to be simulated will be determined as
11
' 11
which suaests that the contaminated material was moved onto the
part of the model implementation task.
site within a few days' time and spread as cover over fill material.
II
Thus, one would expect a fairly continuous, thin layer of
cootamination, as indicated by survey results." (p. 16). The Board
It is assumed that modeling calculations will be performed on the basis of xisting site-specific data,
also noces that the most intense gamma peak readinp for RIM in
Area 2are1oc:atcd within three feet ofthesurface(e.g., PVC 7,
augmented where necessary with information and values obtained from technical literature and/or
PVC-10, PVC-I I); see Table 6-9 of RI rq>o<1." 2) "The Board notes
derived from professional experience.
that Table 6-8 in the RI indicates that the estimated average toul
JI
thickness of RIM for Area I is 3.37 fl, and 3.73 for Area 2; this is
further supported by Table S attached to the 1982 NRC rq>o<1. The
Background
RI rcport also indicates that "Based upon the radiological data,
Mclarenllhrt concluded that the zone or radiological impacts in
Area I is gcnenally a thin layer (S-reet thick or less) in the upper pan
West Lake Landfill is located within the western portion of the St. Louis metropolitan area approximately
of the landfill debris" (plae 32) and " Based upon the radiolQ&ical
data, McLan:nlllart concluded that the zone of radiolo&ical impact
two miles east of the Missouri River. Two areas of the Site contain radionuclides as a result of the use of
in Area 2 is generally a thin layer (less than S feet) in the upper part
soils mixed with leached barium sulfate residue .a~ ~o_v~r_fqr_"!U_!l~ip~l .!:~~s~. The Site is divided into
of the landfill debris" (plae 33). This conclusion is similar to the
one made by the NRC in its 1982 RadiolQ&ical Survey that the
two Operable Units (OUs) . OU-1 consists of the two areas1vLt~il} !_h~ !a!'c!f~l1vhere radionuclides are
"'
deposits appear to form "a fairly continuous, thin layer of
1
contamination, as indicated by survey results (pa&e 16) and a
present and the area formerly described as the Ford Property, now called the Buffer Zone/Crossroad
'
contiauous layer" (plae 21), "'fleeted also in Figm-es IO - 19
Property. OU-2 consists of other landfill areas that are not impacted by radionuclides (USEPA, 2008).
\
attached to that rcpon which include a number of aalS-section
1
,,"
,,
"
"
Modeling calculations proposed in this SOW address the potential fate of radionuclides within OU-1. The
nature and extent of radionuclides within OU-1 are discussed in several documents included in the
\ ~=;.,3~~
1~~=0~!'.:,,~;:1ngsta.:~t
laboratory analyses, radiologically impacted materials were
11
11
administrative record for this site. including the Remedial Investigation (EMSI, 2000) and a Supplemental
\\
11
Feasibility Study {SFS) (EMSI, 2011) for OU-1.

frlle selettea remeay fer Obi 1 iireseAtea iA tile Reeera ef EleeisiaA (ROE>) iRehlaes seuree eeRtrel
tllreugll eaRtaiRmeAt sf waste materials aRa iRstitutiaAal eaRtrnls fer tile laAafillea waste materials
generally found at depths ninging between 0 to approximately 6 feet

in the northern portion of Area 2" and " In the southern part of Area
2, radiologically impacted mataiab were identified at depths
'. aenenilly nnaina between oand 6 feet" (RI Pa& 97).
\ Formatted: Highlight
Formatted: Highlight
(blSf;P/\, 2008). CempaAeAts sf tile ROE> seleetea remeEly iAeluae tile fellewiAg~
Commenl8d [cao4]: In llaht of Board's 2012 review (plus

orll:ln1I rHsons for dolrc the SFS), this next para1raph seems out
SOW - Fate & Transport Modeli ng

4/19/2013
Page 1
of place/confuslnc/potenttally mlsleadlnc.
1.
A Rew la Refill eever ever tile e1cistiRg si;rfaee ef Areas 1 aRa 2;
2.
CeRseliaatieR ef raaielegieally eeRtaFRiRatea si;rfaee sail freFR tile Bi;ffer ZeRe/Cressreaa
Commented [caoS]: Board has said In Its memos that

J
Preperty ta tile eeRtaiRFReRt area;
3.
Commented [cao7]: This makes It sound like they have been

r selected as part of the remedy- ROD would do that, not SFS (If the
FRill tailiAg sites aRa saAitary laAafills;

Si;rfaee water ri;Reff eeRtrel;
5.
Gas FReRiteriAg aAa eeRtrel iReli;aiAg raaeR aAa aeeeFRpesitieR gas as Aeeessary;
e.
IRstiti;tieRal eeAtrels; aRa
7.
LeRg terFR ~i;rveillaAet:{aRa FRaiRteRaRee ef tile reFReay.
11
I/
11
I I
,' /I
1
111
1,,
/ I I/
,'
:,
1,' I
II I
1, JI
JI
II
1978 (UMTRCA) guidance for a 1,000-year design period including an additional thickness to
prevent radiation emissions;
~,ir FReRiteriAg statieAs far raaiaactive FRaterials sllai;la Ile iAstallea at lrntll BR site aAa eff site
leeatieA~
~roundwater monitoring ithat would~ be implemented at the waste mana~ement unit
'1
Misseiiri Selia Waste ~iile~~'!_el_t~~ el_e~e!i~t!B.!1 _!1~ t~~ ~0.'.!'~F 3't5~e!'J_i~ ~Ii~ ~QI?: (Y~~'-2~~.JrA
separate task will evaluate potential alternative landfill cover designs other than those discussed in the
2008 ROD, including possible use of an Evapotranspiration (En cover or iAeerperatieR ef a
geomembrane iAta tile aesigA af tile ROD seleeteel laAafill love(~ ]
Modeling Objectives
The proposed fate-and-transport modeling will provide site-specific calculations of the potential for
radionuclides to leach from the landfill, reach the underlying saturated aquifer, and result in
unacceptable concentrations within groundwater or surface water downgradient of the landfill. The
following modeling objectives are proposed :
1.
Calculate the potential for migration of leachate containing radionuclides from waste materials:
a.
Under current conditions, to validate the modeling approach and potentially bound
parameter values for later predictive analyses;
SOW - Fate & Transport Modeling

4/19/2013
Page 2
from spring of 2012 questioned use of state's subtitle 0 regs--
Commented (cao13]: See comment 4

Commented [cao14]: Should explain why this might be
,, I
Commented [cao15]: The Board's draft recommendations
111
'1
J
'"
from spring of 2012 Included other things that are relevant to this
SOW for ground water, lncludln& language from the lnftlal draft
("Groundwater. monitoring wells placed In perimeter fashion;
dated GW data-iiather new data now; wells seem to be
clustered-large gaps-need wells In between gaps to determine If
there Is, In fact, a plume Issue {e.g., predeslgn Installation of new
wells); if we can't fulty characterize GW, then we need to have a
suffklent record to substantiate that conclusion'"), as well as later
versions which said: "Based on the Information presented to the
Board, It appears that there have been some samples of
groundwater at this site th1t exceed standards consk:lered as
ARARs. The Region also stated that no dlscernable plume at this
sfte has been Identified, and Its preferred approach Is to continue
monitoring groundwater . Genera tty, under existing Agency
guktance, exceedln1 a maximum contaminant level In groundwater
normally would warrant a response action (OSWER Dlr&etlve
9355.G-30, Role of the Baselfne Rlslc AssessmMt In Superfund
Rmdy Selectlon Decisions and OSWER Directive 9283.1-33
''"'
"r
'"'
,,.,'"
11,
,,,,1
111
I~
,,,
Jri.s aellAeEl iA tile OIJ 1 ROD, tile Aew la AElli II eever fer Areas 1 aAd 2 wei;lel eeRsist ef tile fellewiAg, freFR
FReisti;re eeAteAt pessesses a eeeffieieAt ef perFReallilitt ef 111 rn+ eFR/see er less; aAel 1 ft ef sail
Commented [cao12]: The Board's draft recommendations
't
Flood control measures at the Site that would~ meet or exceed design standards for a 500-
si;itallle ef siippertiAg vegetative grewtll. These la'(er tllielEResses are llaseel eA re11i;ireFReAts ef tile
by Itself Is not 1 remedy, so not dear what performance standards

{s discussed In the NCP) would be for here --
'1
year storm event under the assumption that the existing levee system is breached.
raAgiAg freFR saAel sizeel i;p te 8 iRelles; 2 ft af eeFRpaeteel ela'( er silt that wile A eeFRpacteel at eptiFRllFR
address air do they?
1 relevant to eround water SOW -J1 I
,,
boundary and at off-site locations; and
lletteFR te tsp: 2 ft ef reel1 eeAsistiAg ef well graeleel pit FllR reek aRd/er eeRerete/aspllaltie ri;llllle
\1 JI
'
Commented [cao10]: How Is this relevant to this SOW for

1round water? Board recommendations on ground water don't
Commented [cao11]: Again, as Board has stated, monitoring
111 I
Pgerformance standards for cleanup of this site . fer tllese reFReaf eeFRpeReRts are aetailea iA tile ROD.
Tile prepese~~ca p that~ would meet the Uranium Mill Tailings Radiation Control Act of
Commented [cao9]: Not sure what this proposed' refers to-
1,'
EMSI reference Is to SFS)
Commented [cao8]: If this Is the SfS, should Identify It as such
I
1
11 1
111/
1
11 I
I
I
A ROD was signed in 2008. In addition. an SFS done in 2011 discussed potentially appropriate
Tile fellewiRg aaaitieRal perferFRaRee staRaaras ~;ere alse iaeRtifiea ~er tile OIJ 1 reFReay {E_M_S~ 2011):
Commented [Cll06]: Not sure what this means --
~rei;Rawater FReRiteriAg~Aa 19retecti0A staAaaras eeAsisteRt witll reeii;ireFReRts fer i;raRillFR
4.
monitoring by Itself Is not a CERCLA remedy (so could not be a

component of the ROD selected remedy"
I;
I;
11
,,
11
1,
,,
'1
11
11
I
SUmmary of Key &/sting EPA CERCLA Pollcles for Groundwotr

Restoration}. The Board rK<>mmends that the Realon consider
1ddiUonal wells at the site to better delineate the vertfcal and
lateral extent of potential sfte-related contamination prevJousty
lndenttfled from limited sampllna In Areal 1nd espedally Area 2.
These additional wells woukt be Instrumental In clarifyina the
presence of an isolated aroundwater hot-spot versus a
groundwater plume In the complex subsurface geologic setting. In
addition, the Region should explain why there are numerous
decommlssloned wells on site. Sampllna of these wells may have
provided a more complete picture of potential eroundwater
contamination. The seneral recommendation Is that the additional
wells be nested a Iona the western border {Crossroad property) of
Area 2 In the unconsolidated alluvJal deposits and the underlyln&
fractured and VUB&Y, limestone Keokuk formation. The Board also
notes that the Agency's lona-standlrc policy has been that
monitoring by Itself Is not a CERCLA remedlll 1ctlon, and believes
that the Information submitted to the Board may not support a
concluskm that monitoring to evaluate effectiveness of the source
control remedy (If that approach Is 1eteci:ed) would constitute an
effectfve or final eroundwater response action for this sfte. As such,
the Soard recommends that the declsfon documents dearly
rm
Com..-ted [cao16]: lhlsseemstOSUB&estthat It's mass that
b. Under future conditions, assuming the emplacement of a new landfill cover for OU-1;
and
c.
2.
Under future conditions, following the period of active maintenance of the new landfill
I
I
I
cover for OU-1.
Calculate the potential for leachate containing radionuclides to migrate vertically through waste
that is uncontaminated by radiological constituents and through native materials beneath the
landfill, and to impact underlying groundwater;
If the prior calculations indicate that a potentially measurable impact to groundwater may occur:
3.
Calculate the likely fate of any radionuclides that reach groundwater, and the potential for the
development of a contaminant plume;
4. Calculate concentrations over time of radionuclides in groundwater at defined locations

including, but not limited to, the property fence line/boundary; and
5.
Evaluate the potential for radionuclides that reach the groundwater to migrate toward, and
discharge to, the Missouri River at levels exceeding standards.
These are the specific objectives of the proposed modeling task . The model may, at some later time, be
used to support other Site objectives such as (a) designing a suitable groundwater monitoring program,
including defining the locations and frequency of sampling to detect any potential off-site migration of
radionuclide constituents and/or (b) evaluating alternative landfill cover designs such as an ET cover or
incorporation of a geomembrane .
Fate and Transport Conceptual Site Model
~ecause the overall mass of radium at the Site is smalll
and f l!.t!:!r!! ln!il!r2~0!1 _!'!r2u_g~
!h~ Ja!'~f~I-
counts, not risk posed by the rad -based on dlscusskms durfna the
February, 2012 Boird meetlna and draft recommendations
prepared by the Board during the spring of 2012, this
statement/approach a ppears Inconsistent with the documents In
the admlnlstrattve record for this site and with the remedial
program's approach at rad sites around the country. For exampJe,
the Board's draft recommendations stated:
Anally, the Board notes that the FS (at page 60) stated that
Excavation of a smaller volume of racHoactivety Impacted material
!than the estimated 2SO,OOO cubic yards of total RIM plus soil and
debris] would not sign~lcantly reduce the threat posed by the
overall site."' The Board Is concerned that this kind of approach Is
lnconslstent with, ind could undermine, ongoing cleanup of rad
sites In several other Regions. Specifically, In Region 2, reduction of
rad-Impacted source material Is being undertaken In a manner that
Is protective and without short-tenn Impacts, where the Reslon
determined that ellmlnatlng the source Is an Important objective of
the cleanup. Regkm 2 has been removing radiolo&k:al
cont.amlnatlon from resklentfal and commercial properties for the
past two deades. That work Is undertaken with appropriate
enalneerlna controls and In accordance with approved health and
safety plans, often with homeowners remaining In their residences
during the deanup effort. These types of cleanups can be safely
and efficiently undertaken. Given the presence of hlahly
radioactive material at this site, and the fact that lb hazardous
nature will oontlnue to Increase over time, the Board believes
excavatin& and/or treatlna any amount of the RIM should lead to
Important risk reduction. Where ft appears that much ff not all of
the RIM fs located near the surface, cleanup at this site appears less
complicated than other sites where, for examp~, burJed drums
containing liquids have been safely excavated. Radlologlcal
material Is also easily sorted out In the field with portable
Instruments tNit provJde Instantaneous measurements to ensure
that onfy contamlnat~ materlal Is retrieved which, In turn,
min imizes disposal costs.
Sayln1 that the overall mass of radium at the Site also could cause
confusion/misunderstand Ina
materials will be less than at present due to the planned emplacement of an additional landfill cover
Commented [cao17]: This Is making an assumption about the
over the existing landfill cover material, t migh! be expected that ~_pnc_e~t!a_!iQ'!_S _of r31~i!:!f!.1 !"ill_
remedy that doesn' t seem to take Into account the Board's

concerns/ recommendations made In draft memos during spring of
2012- the Board didn't make Its recommendations regard ll'l8
1roundwater based on an addltkmal landfill cover; rather, the
recommendations were that there's Insufficient data and more
data/more wells are needed to adequatefy characterize the site
(see comment lS for actual word Inc of Board's sprlna 2012 ldraft
recommendations/comments)
necessarily decline in the future. ~p~~v!!r, ~i~e~ee~ific ~onditions need to be evaluated before reachJng
this conclusion. f or example, uranium and thorium that are present in the waste materials will continue
to decay, and in doing so, generate radium. I n ~ddition, the lan~fill and groundwater geoch~mistry will
'
'
\
change over time due to the eventual exhaustion of readily-biodegradable organic matter in the landfill.
This will in turn affect the stability of some minerals available to sequester radium.
Commented [cao18]: lhls 1ppears Inconsistent with Board's
Selection of an appropriate calculation method, and of a suitable simulation code or suite of codes to
implement the calculations, requires that the modeling requirements are defined. In the context of
radionuclides, the Nuclear Energy Agency Organization for Economic Co-operation and Development
(NEA-OECD, 2000) developed a systematic approach to ~efine relevant scenarios fa! safety i!S~e~sment
studies at radioactive waste management sites. This consists of identifying and prioritizing the Features,
1
Using the arithmetic mean concentrations (reported as pCi/gram) from Appendix A of the RI, as well as an
estimated mass of soils for the Area 1 and 2 surface and subsurface zones at the West Lake site, a
226
preliminary estimate of the amount of 226 Ra at the site indicates that there is less than 40 grams of Ra
within Areas 1 and 2.

4/19/2013
Page 3
views expressed during meetlna and In sprlns 2012 draft

recommendations-for example: eased on the packaae provided
to the Board, it appears that there are potentially slgnfflcint
amounts of RIM that are hlghfy toxJc {e.g., based on NRC estimates
In the 1982 ond 1988 reports, radium of up to 22,000 pCl/gr,
blsmuth-214 of up to 19,000 pCt/g, and overage thorlum-230
concentrations of 9000 pCl/gr; the package at paae 44 notes that
' the RI report discussed thorlum-230 at levels as high as 57,300
I
pCl/ar) and that the hlahest aamma peak Intensity readings are at
shallow depths. The FS states (paae 84) that most of Area 2
', contains RIM at above 100 pCt/1r. lhe NRC reports 1lso dlscCf21
'
'
Commented [cao19]: See comment 17 Coln..-ted [cao20]: Conslstentw~h Board

comments/recommendatJons made at other rad sites (e.g.,
Hanford), CERCIA remedy selection should be done uslna CERCLA
rad 1uklance -
Events, and Processes (FEPs
that potentially affect the fate and transport of radionuclides at a site, and
developing and modeling individual scenarios, each of which consists of a well-defined, connected
sequence of selected FEPs. This SOW identifies principal FEPs for the Site that it is anticipated will
require consideration in the modeling analyses. However, the final site-specific FEPs and the suite of
simulation scenarios will be defined during the implementation phase of the modeling task.
Primarv Site-Specific Features
An overview of the primary features that affect radionuclide fate and transport is provided here. The
source of radionuclides of potential concern is leached barium sulfate residue mixed with soil aRa llSea
~s aailv aRa iAtermeaiate ~e1er fer A'lllAicipal se lia waste aepesitea iA laAafill in Areas 1 and 2.-+llisraaielegically impactea material (RIM) )s EllrreAtly eeYered B'( eld laAdfill eever materia ~ Underlying the
RIM is refuse that does not contain radionuclides, and under that is partially saturated alluvium. Over
time some fraction of radionuclide-bearing water could potentially percolate vertically to reach the
Commented [cao21]: Seo comment 3 above Commented [cao22]: See Board's sprl11112012 draft
recommendaUons/comments describing documents Jn the
admlnlstn1tlve record that describe RIM as at the surface In certain

k>catlons, and between 0 - 6 feet In many others.
water table. According to the RI [EMSI, 2000], the saturated aquifer largely consists of alluvial sand,
underlain by more impervious limestone and dolomite bedrock. The horizontal hydraulic gradient
within the aquifer is relatively flat, which would tend to result in slow advection along a trajectory that
intersects the Missouri River downgradient of the Site. If radionuclide-containing water currently
located within or under OU-1 were to reach the water table beneath the landfill, then 1nixing,
dispersion, and dilution
pf that radionuclide-containing waterJWo_!JI~ occur at the water table beneath
the landfill, within the saturated aquifer, and within the hyporheic zone of the Missouri River.
A dominant feature [which, depending upon the simulation scenario, may also constitute an event] that
must be considered in the modeling calculations, and for which a design is presented in the ROD but for
Commented [cao23]: Should It be and or should It be o r"?

Commented [cao24]: This makes It sounds like a certaintyRon Indica ted at the Board meetlnc and other conversations that It
ml&ht not be so- for enmple, the fact that Knrst ls a bctor, plus
the hits 1bove MO. that have been documented In the
administrative record might not suppart this -
which potential alternatives have since been identified by USEPA for evaluation, )s the new landfill cover
to be installed over the current surface of the old landfill cover.l Modeling calculations proposed under
Commented [cao25]: See comment 17 above
this SOW will only consider the ROD-selected landfill cove~, the design of which is detailed above and
Commented [cao26]: See comment 4 1bove- this approach
within the ROD (USEPA, 2008). However, the developed model could be used at some later time to
appears to tenore Board review process and the sprlna 2012 draft
recommendations/comments
evaluate alternative cover designs such as an ET cap and/or the incorporation of a geomembrane within
the ROD-selected landfill cover.
Primary Site-Specific Events
Several events may affect the landfill water balance, the potential for radionuclide partitioning and
migration, and the potential for radionuclide transport within the partially saturated and saturated
zones at the Site. Example events are summarized in Table 1.
The following definitions apply (Sandia National Laboratories, 2010):

Feature - An object, structure, or condition that has a potential to affect repository system performance.
Event - A natural or human-caused phenomenon that has a potential to affect repository system performance
and that occurs during an interval that is short compared to the period of performance.
Process - A natural or human-caused phenomenon that has a potential to affect repository system performance
and that occurs during all or a significant part of the period of performance.
SOW - Fate & Transport Mode ling
4/ 19/2013
Page 4
Table 1 Primary Events and Processes of Potential Radionuclide Fate and Transport at the Site.
FEP Element
Events:
Description
1. Transition from current cover conditions to final cover under active maintenance:
Cover design (2-ft of well-graded pit run rack and/or concrete/asphaltic rubble; 2-ft
5
of compacted clay or silt with a coefficient of permeability of 1 x 10" cm/sec or less;
and 1-ft of soil suitable of supporting vegetative growth)
Period of active maintenance (30 yr min/200 yr ROD/1000 yr UMTRA-compliant)
2. Transition from active maintenance period to post-active maintenance period:
Intermediate infiltration rates (reduced by grade, vegetation, etc.)
3. [Bio-]degradation of landfill wastes:
Degradation time-frame (rapid versus extended time)
Effects and duration on chemistry (oxidation-reduction [redox], carbonate, C02, pH,
etc.)
4. Flood events:
500 year
Processes:
Commented [Cll02n: See comments 17 and 25
1. Net infiltration:
Commented [Cll028]: ditto
Under current conditions

During period of active cover maintenance (incorporating ET as a process)
Following period of active cover maintenance (reduced by grade, vegetation, etc. )
See Boaird comments that: However, the p.11cbae lacked sufficient

Information
on the Iona term protectlwness of the preferred
re medy. Speclflcally,
how the preferred remedy remolns protectl.le
"' 1twn the lncreuq dauahter
lnl:rowth concentrations of nidlum
2. Ingrowth of radium from uranium and thorium decay:

3. Partitioning of radium, uranium, thorium from soil to water/landfill leachate:
I
I
Decay/ingrowth, sorption/complexation, mineral dissolution/precipitation

4. Transport within the partially-saturated zone:
"
5. Mixing at the water table :
"
Depth of penetration, and dilution

Sorption/complexation, mineral dissolution/precipitation
6. Transport within the saturated aquifer:
Advection, dispersion, decay/ingrowth, sorption/complexation, mineral
dissolution/precipitation
7. Discharge to, and mixing with, Missouri River:
Hyporheic zone chemical process
Sorption/complexation, mineral dissolution/precipitation
Th Uran ium Mill Tailings Rmdiation Program {UMTRA} focused on th design of purpose-built rpositories for uranium
tailings piles; howtvtr, the UMTRA containment dtsign timt-/ramt of 1CXXJ years is a guide for othtr radionuclide wastes.
pne important event is the grading of Areas 1 and 2 and the emplacement of the final landfill cover on
top of the current landfill cover material in these areas. trhJs_n~~ fO_v~r-~l~greatly reduce nfilt~tio!'
and the potential for mass transfer of radionuclides to mobile water for the period of active
maintenance If active maintenance were to cease, over some time the effectiveness of the landfill
cover may decline, potentially resulting in an increased infiltration rate. However, infiltration rates
following cessation of active cover maintenance would be expected to be lower than under current
SOW - Fat & Transport Modeling
4/19/2013
Pase 5
Commented [Cll029]: Does the period of active maintenance
here equal lOOOYears?
,,
I
,,
,,,,
226/228, radon 222. and the lncruse In toxicity CNer time (1000
years).
Both of these landfln deslsns (Subtitle D and UMTRCA), as In the
preferred alternative, Nve shortcomln&s for RIM waste ltseff and
especiolly In a hYmld re1lon. A comparison of v.irloos landfill
capplf'll desflns addressln1 both humid re1lon conditions and lo111
term protection from RIM (1000 yurs) would be an Important
concept for the preferred remedy. However, the pocbse did not
appear to Include alternative cop desl1ns, I.e ., EPA llndfnl cap
1uldance desWn, exlstllll cap des(&ns for slmlllr RIMat Weldon

Spri111s, or ev.ipotransplntlon cover cap system deslsns (OSWER
Foct Sheets: EPA S420F-0Hll5, 2003; EPA 542-FU-001, 2011). For
example; a Subtltled C/UMTRCA hybrid may be sultllble for both
Ions term Infiltration rnanasement and radiation shleldl111
protection, The Board recommends that the reglon fnclude in Its
remedy seiectkm process evaluations of ap de.sllns similar, but not

limited to, the above conditions and 1uldances. The pocka1e also
does not address several aspects of the potential for future

migration of contamination to around water. The current lad of 1
dlscernable plume above MCI. leveb may not be a sufficient basb to
determine there Is little or no potential for there ever to be one.
Particularly In ll1ht of the lonc-llved toxic nature of the radloactlw
cont3mlnants as well as chemkal and physical chanaes overtime at
the landfill, the Board recommenc:b that a more rll:orous evafuation
of potential ml&ratlon to sroundwater be undertaken. The
eV1luation shouki not usume that pumplrc 1t the former active
san itary landml will oontlnue, unless that b port of this remedy. For
these rusons, the Board recommends that the res:km provide

further lnform1Uon on 11ternattve ap des1tns plus fate and
tf'lnsport of 1roundwater that supports the preferred remedy's
Jona term protectfvene.ss.
conditions since the cover design incorporates a grade (whereas, the majority of the current landfill
cover is flat) and other features that would endure for many years following cessation of active
/naintenance~
Commented [cao30]: How does this take Into 1cc0<1nt the

Ingrowth lssue (the RIM will getter hotter over time) that the Board
kfentlfled/discussed during review meeting and In spring 2012 draft
recommendations?
Another important event is the slowing rate of biodegradation of organic materials in the landfill over
time; this will alter the geochemistry within the landfill wastes and impact radionuclide partitioning
between mobile and immobile phases )n the refuse that contains RIM, the underlying refuse that does
not contain RIM, and potentially the underlying alluvial aquifer.
Primary Site-Specific Processes
Commented [cao31]: How much ofthb b there - see

comment 3 above, where Board discussed various documents In
the administrative record indicating that 'Thus, one would expect a
fairly continuous, thin layer of contamination, as indicated by survey
results."
Several processes may affect the potential for radionuclide partitioning and migration, and the potential
for radionuclide transport within the partially saturated and saturated zones at the Site. Example
processes are summarized in Table 1. One important process is the complex interaction of the RIM with
the surrounding pore water, and the role of pore water and soil chemistry on the potential for
radionuclide partitioning and migration. Since radionuclide geochemistry will be an important process
in the modeling scenarios, an overview of relevant radionuclide geochemistry is provided below.
Geochemistry of Radionudide Decay, Ingrowth, Partitioning and Migration
Radium Geochemistry
Radium dominantly occurs within leached barium sulfate residues that were mixed with soil aAel
~sea
as
efaily a Aet jAtermeaiat~ sail ES11er f~r selia waste aisj'lesea ~t Areas! and 2. The co-precipitation of
_ - {COiii"m ented [cao32]: See above comments (e.e., #3)
radium into barium sulfate is a well known process to control radium (Doerner and Hoskins, 1925; Bruno
et al., 2007; Zhu 2004a, 2004b; Mahoney 1998, 2001; Grandia et al., 2008; Bosbach et al., 2010).
Consequently, equilibrium between pore water and the radium component of barium sulfate will define
the initial radium source term leached from the RIM .
Radium may also be attenuated in clean alluvium and groundwater via adsorption onto iron-bearing
minerals, ion exchange on clays, and co-precipitation with other sulfate and carbonate minerals such as
gypsum and calcite. Of these mechanisms, co-precipitation )s expected to ~~ the dqmin~! pr~ce~s close
to the landfill due to the sandy nature of the aquifer and ~xpectedlYi low redox conditions (making iron
oxyhydroxides unstable). Downgradient of the landfill - ~nd
increasi~gly-~thin the 1.;ndtlll-o~;rtim~ -I
more oxidizing conditions may be present, and the abundance of iron-bearing minerals available for
Commented [cao33]: Is this expectation discussed/supported

In the administrative record (FS? SFS?)
Commented [cao34]: ditto

- Commented [cao35]: see comment 31
radium adsorption may increase. Another important consequence of the change in landfill
biogeochemistry over time is the ~ikely increase in pH as readily-biodegradable material is consumed). As
Commented [cao36]: In li&htof Board'ssprlng 2012 draft
pH increases, the amount of calcite that will precipitate will increase, and radium co-precipitation with
recommendations/comments (see #18 and #22 above), Is the

"likely Increase here explained In the FS or SFS?
calcite will be more favored, reducing its mobility.

Uranium Geochemistry
Uranium and thorium are important because they occur within the RIM and they decay over time,
producing additional radium . Under current conditions uranium concentrations ~ re expected to be
controlled by uraninite (U02 ) ~ue to the reducing conditions within the landfil( If oxidizing conditions
4/19/2013
Page 6
Commented [cao37]: See comment 33 above

Commented [cao38]: Is this expectation affected by Board's
spring 2012 draft recommendations/comments?
return, however, then uranium solubility could be controlled by the generally more soluble
u (uranyl)
minerals such as schoepite [U0 2(0H)i2H 20) or less soluble forms such as carnotite (KUONO) and
tyuyamunite [Ca(U0 2h(V04 )i] (Tokunaga et al., 2009). In addition to the oxidation state of uranium,
other factors affecting dissolved concentrations include levels of dissolved carbonate generated by
biodegradation (which increase solubility) and presence of iron oxyhydroxides (which decrease
solubility).
Thorium Geochemistry
Thorium is not redox sensitive and solubility conditions will be controlled by thorianite (Th0 2 ) under all
redox conditions. Complexation reactions that form thorium carbonate complexes are not as significant
as those for uranyl carbonate complexes, but they will play a role in thorianite solubility calculations.
Reductions in carbon dioxide pressures will also reduce thorium concentrations in groundwater.
The long-term in-growth of
226
Ra from 'Th is complicated by the fact that the majority of in-growth
radium will be retained within the crystal structure of the thorianite (Th0 2) . pnly a small fraction of the
radium that is produced from the decay of thorium will have the potential to be released to
groundwater. his fraction is expected to be derived from near the surface of the thorianite crystals.
Calculation Approach
The approach to undertaking modeling calculations will follow the sequence of steps defined below:
Determine and document final FEPs;
Identify simulation scenarios, based on the final FEPs;
Identify parameter ranges and uncertainties;
Develop necessary model(s);
Complete model calculations; and
Present and interpret results.
As the modeling is implemented, there will be some iteration between steps in the sequence. It is
expected that there will be communication and interaction with US EPA to seek input on the FEPs,
simulation scenarios, and parameter ranges and uncertainties identified for inclusion in the modeling
prior to undertaking the model calculations. It is envisioned that communication and interaction will
include the following:
Presentation and discussion of certain detailed or fundamental concepts - such as the CSM,
FEPs and scenarios for inclusion in the modeling;
Discussion of other less critical aspects of the modeling task; and
Presentation of intermediate deliverables for review and discussion .
4/19/2013
Page 7
Commentlld [cao39]: Seo commenu 30-38 on previous P&

-In llcht of Boord's sprlnc 2012 droft recommendtlons/commenu,
Is this conclusion speclflcally dlsamed/supported In the FS or SFS?
Graded Approach
A graded approach is proposed to undertake the modeling analyses (USEPA 2002, 2009). This graded
approach will:
Use relatively simple methods for initial calculations under the premise that the inherent
conservatisms are protective of groundwater and other receptors. Increasing simulation rigor
will only be used, if necessary, if simpler approach(es) yield unreasonable results.
Provide a mechanism to cease model calculations if it becomes evident that no further
calculations are necessary. For example, saturated zone flow and transport calculations will only
be undertaken if geochemical and vadose zone modeling calculations suggest that a potentially
measurable impact to groundwater could occur.
The modeling approach and specific model calculations will be designed to incorporate the principal
FEPs while mitigating the potential for computationally-intensive calculations that prevent a thorough
exploration of parameter variability and scenario uncertainty. Multiple scenarios will be simulated to
evaluate the potential impact of scenario uncertainty on model outcomes, while sensitivity analysis will
be used to evaluate the potential impact of parameter variability on model outcomes.
Modeling analyses will be designed to predict the concentration of radium in groundwater for a period
of 1,000 years. Concentrations will be forecast at defined compliance locations including, but not
limited to, the property fence line/boundary, for the 1,000-year period and will be compared to
regulatory standard~ If regulatory standards are not exceeded then no further analyses will be required .
However, if simulated concentrations exceed regulatory standards, the graded approach will be used to
identify the technical element of the modeling approach that incurs the most inherent conservatism in
the calculations so that element of the modeling approach can be treated more rigorously to reduce
that inherent conservatism (Dixon et al, 2008). If the graded simulation approach has been applied until
all inherent conservatisms have been reduced or eliminated, yet simulated concentrations exceed
regulatory standards, then this will be considered to be a reliable result.
Simulation Code Selection
Table 1 outlines primary events and processes that will be considered in the calculations. The range of
potential outcomes will be evaluated by performing several model simulations that consider reasonable
alternate conceptualizations of subsurface conditions. Since parameterization of the geochemical
component of the model is likely subject to more variability and uncertainty than the groundwater flow
component of the model - given the large number of chemical processes that potentially affect radium
fate and transport - advective-dispersive migration will be simulated as one-dimensional (1-0), coupled
with a rigorous treatment of the complex geochemical processes. The following sequential series of
calculations is proposed to collectively comprise the model [consistent with the graded approach, some
calculations will only be undertaken if necessary based on the results of preceding calculations] :
4/19/2013
Pages
Commeni..d [cao40]: Theadmlnlstrotlve record already

lnch.tdes well Silmples that show MCU ~re exceeded. See comment
IS11xM!.
1. The Hydrologic Evaluation of Landfill Performance (HELP) code will be used to determine the
run-off component of the surface-water balance and remaining water available for infiltration
through cover materials under current conditions, ri nal cover condition
and following the
_ - -{ Commented [cao41]: See co mments 1bove (e.1., #4, #17 etc)
period of active cover maintenance;

2.
HYORUS 1-0 (Simunek et al., 1998) will be used to simulate the water balance in the subsurface
(after run-off has been accounted for) and the migration of infiltrating water;
3. The USGS-supported geochemical simulation software, PHREEQC (Parkhurst and Appelo, 1999),
which is linked to HYORUS through the HPl program (Jacques and Simunek, 2005), will be
executed simultaneously to provide concentrations of radionuclides in the leachate as it moves
within the unsaturated refuse and underlying unsaturated alluvium;
4. The depth of penetration of any leachate that reaches the water table will be calculated using
an established method such as that detailed by US EPA (1996);
5.
PHREEQC, linked with HYORUS, will then be used to calculate the effects of mixing on
geochemistry that occurs between the leachate and groundwater at the water table;
6.
Output from these calculations will provide the time-varying groundwater composition for
simulating 1-0 radionuclide fate and transport within the saturated zone toward the Missouri
River using PHREEQC; and
7.
PHREEQC will be used to represent geochemical processes that may occur within the hyporheic
zone of the Missouri River.
Overview of HELP Calculations

HELP (Schroeder, P.R. et al, 1994a, 1994b; Berger, 2011; Berger and Schroeder, 2012) is a program originally
developed by USEPA to evaluate the effectiveness of landfill cover designs. HELP will first be used to
estimate the typical, quasi-steady-state surface-water balance, emphasizing the run-off rate and the net
water available for infiltration through the current landfill cover. The purpose of these calculations is
solely to support validation of the modeling approach and constrain the values of certain parameters to
be consistent with historical water samples. HELP will then be used to make similar calculations to
estimate run-off and the net water available for infiltration through the liew landfill cover that would be
constructed under the ROD-selected remedy, and to estimate run-qff an~ the net water available for
infiltration through the new cover following the period of active maintenance. Alternate periods of active
maintenance may be considered in alternate simulation scenarios. The HELP model can explicitly account
for rainfall-runoff under alternate cover designs, including alternate slopes (grades).
Overview of HYORUS 1-0 Calculations
HYORUS-10 (Simunek et al., 1998) is a public domain Windows-based modeling environment that
simulates the movement of water, heat, and multiple solutes in variably saturated media . The flow
equation formulation in HYORUS incorporates a sink term to account for water uptake by plant roots, as
well as a dual-porosity type flow capability in which one fraction of the water content is mobile and
another fraction is immobile. The solute transport equations consider advective-dispersive transport in
the liquid phase, as well as diffusion in the gaseous phase. HYORUS 1-0 (Simunek et al., 1998) will be
SOW - Fate & Transport Model ing
4/19/2013
Page 9
_ - -{ Commented [cao42]: See comments 1bove (e-1., #4, #17 etc)
used to simulate the water balance in the subsurface (after run-off has been accounted for), and the
migration of infiltrating water.
HYDRUS 1-D is linked to PHREEQC through the HPl modeling software (Jacques and Simunek, 2005).
This allows simulation of complex bio-geochemical reactions. Consistent with the graded modeling
approach, the initial simulations will assume that radionuclide attenuation in landfill leachate only
occurs in groundwater. However, the HPl software may be used to estimate attenuation in the nonradiologically impacted refuse and unsaturated alluvium underlying Areas 1 and 2 if unreasonable
results are obtained using the more conservative simplifying assumption .
Overview of PHREEQC Calculations
Geochemical modeling will first be completed to estimate the leaching potential of various radionuclides
under current site conditions. The purpose of these calculations is to support validation of the
groundwater modeling approach and constrain the values of certain parameters to be consistent with
historical water samples. Following these calculations, the modeling will be used to evaluate the
leaching potential under long-term future conditions :U nder the ROD-selected remed~.
_ - -{ Commented [cao43]: ditto
Geochemical modeling methods to estimate source term concentrations for the radio-isotopes will
primarily rely upon equilibrium thermodynamics and will be based upon mineral solubility relationships
using current ground water compositions. Calculations will be performed using PHREEQC (Parkhurst and
Apello, 1999). Solubility calculations for end member phases will be used for thorium and uranium.
Radium will be assumed to be present as a solid-solution in barite with a lower thermodynamic activity.
Solubility constants for uranium and thorium will, /Qrt~ ~ l!IC~S! pa_!'t~ be based upon the_,.OEfQ !".'~
compilations (Guillaumont et al., 2003; and Rand et al ., 2008). Other data sources will be used.a_s
needed (Dong and Brooks, 2006, 2008; Duro et al., 2006; Langmuir, 1978; Tokunaga et al ., 2009). The
ingrowth of 226 Ra from 2'Th is a time dependent process and the kinetics capabilities in PHREEQC will be
used to estimate the production of
226
Ra for a period of 1,000 years.
1-D transport modeling will also be performed with PHREEQC. Modeling will simulate a chemical system
that is sufficiently complex to include the effects of landfill and groundwater geochemistry described
above. Site-specific groundwater and soil data for uranium, thorium, and radium will define initial
concentrations for these isotopes. The site analytical results, particularly the groundwater analyses, will
also provide details on the overall geochemical environment of the landfill. The PHREEQC fate and
transport model will include the following features:
The effect of radium in-growth from the decay of thorium over time;
Decreased methane generation and a possible change in site redox conditions from the reducing
conditions currently present at the site to more oxidizing conditions;
Radionuclide precipitation and/or co-precipitation, such as the partitioning of radium into
calcite (Yoshida et al ., 2008) present within the landfill;
Changes in iron stability and potential precipitation of iron-bearing phases for the adsorption of
radionuclides; and
SOW - Fate & Trans port Model ing
4/ 19/2013
Page 10
Adsorption reactions (surface complexation and ion exchange) (Dzombak and Morel, 1990;
Mahoney et al. 2009a, b; Rojo, et al., 2008; Pabalan et al., 1998).
Model Validation and Predictive Sensitivitv Analysis
Historical groundwater data have exhibited rew detections of radionuclides. As such, a rigorous
calibration exercise is not warranted or justifiable. ~ owever, the h1~t2rlc~l_d~t2 !Y.!!l_b!! .!!~ed o validate
the modeling calculations and potentially bound the values of some parameter combinations by
simulating current conditions prior to undertaking predictive calculations. Multiple simulations will be
conducted to evaluate the range of forecasts of possible impacts on groundwater beneath the landfill, at
the property fence line/boundary, within surface water, at any defined receptors, and at any other
Commented [cao44]: Board noted MO. exc:eed1nc:es and t heir

slanlOamce In SUperfund proera m - see comment 15 1bove
' >----
~~~-<
Commented [cao45]: Gist of Bolrd's spring 2012 draft
recommendations/comments ls that more data/wells 1re needed so would so just uslna hlstork:al data address Board's
recommendatlons/ concerns?
locations of interest. Multiple scenarios will be simulated and predictive sensitivity analyses will be used
to evaluate the potential impact of parameter variability on model outcomes at these locations.
Although outside the scope of the proposed modeling task, the results of multiple-scenario and
parameter-/prediction-sensitivity analyses can help guide the sampling frequency for long-term
monitoring programs by providing a range of possible arrival-times and peak-concentrations for
contamination at identified compliance locations such as the property fence line/boundary.
Deliverables
The final deliverable anticipated to be developed from the modeling effort is a Technical Memorandum
documenting the technical approach, assumptions, model development, parameterization, simulated
scenarios, and results obtained . However, it is anticipated that there will be communication and
interaction with USEPA to seek input on the FEPs, simulation scenarios, and parameter ranges and
uncertainties identified for inclusion in the modeling prior to undertaking the model calculations.
Communication and interaction with USEPA will include the following:
Presentation and discussion of certain detailed or fundamental concepts - such as the CSM,
FEPs and scenarios for inclusion in the modeling;
Discussion of other less critical aspects of the modeling ta sk; and
Presentation of intermediate deliverables to USEPA for review and discussion.
~o
revisions to the SFS report are expected o be required as a result of this modeling effort.
__ - -{ Commented [Cll046]: Is this pre matu re conclusion?
Schedule
It is anticipated that the geochemical evaluation of potential leaching of radionuclides, including
preparation and submittal of the Technical Memorandum, will be completed within twelve weeks of the
approval to proceed.
Reference
Berger, K. , 2011. The Hydrologic Evaluation of Landfill Performance {HELP) Model. Engineering
Documentation for HELP 3.90 0 - Enhancements Compared to HELP 3.07. Institute of Soil
Science, University of Hamburg, Germany, 10 pp.
SOW - Fate & Trans port M odelin11
4/19/2013
Page 11
Commented [cao47]: what about EPA's rad and other CERa.A

1uldance documents?
Berger, K. and Schroeder, P., 2012. The Hydrologic Evaluation of Landfill Performance {HELP) Model.
User's Guide for HELP-D (Version 3.9 D). 5th, completely revised edition for HELP 3.9 D. Institute
of Soil Science, University of Hamburg, Germany, 70 pp.
2
Bosbach, D., Bottle, M., and Merz, V., 2010. Experimental study on Ra ' update by barite : Kinetics of
solid solution formation via BaS0 4 dissolution and Ra, Ba 1.,S04 (re) precipitation. Technical
Report TR-10-43. Svensk Karnbranslehantering AB, (SKB), Swedish Nuclear Fuel and Waste
Management Co. Stockholm . 106 pp .
Bruno, J., Bosbach, D., Kulik, D., and Navrotsky, A., 2007. Chemical thermodynamics of solid solutions of
interest in nuclear waste management: A state-of-the-art report. OECD Publication Nuclear
Energy Agency Data Bank, Eds, OECD Publications Paris, France. 266 p.
Dixon, KL., Lee, PL and Flach, GP., 2008. A graded approach to flow and transport modeling to support
decommissioning activities at the Savannah River site . Health Phys 94{5 Suppl 2): S56-61. doi :
10.1097/01. HP.0000300756. 69761. le. May.
Doerner, H.A. and Hoskins, W .M ., 1925. Co-precipitation of radium and barium sulfates. J. Am. Chem.
Soc., 47, 662-675.
Dong, W ., and Brooks, S.C., 2006. Determination of the formation constants of ternary complexes of
2
2
uranyl and carbonate with alkaline earth metals {Mg ', Ca ', Sr", and Bai.) using anion exchange
method. Environ. Sci. Technol. vol. 40, p. 4689-4695.
Dong, W ., and Brooks, S.C., 2008. Formation of aqueous MgU0 2(C0 3) complex and uranium anion
exchange mechanism onto an exchange resin. Environ. Sci. Technol. vol. 42, p. 1979-1983.
Duro, l., Grive, M . Cera, E., and Bruno, J., 2006. Update of a thermodynamic database for radionuclides
to assist solubility limits calculation for performance assessment. Technical Report TR-06-17 .
Svensk Karnbranslehantering AB, (SKB), Swedish Nuclear Fuel and Waste Management Co.
Stockholm. 120 pp.
Dzombak, D.A., and Morel, F.M.M., 1990. Surface complexation modeling - hydrous ferric oxide: New York,
John Wiley and Sons, 393 p.
Engineering Management Support, Inc. {EMSI), 2000. Remedial Investigation Report West Lake Landfill
Operable Unit -1. Prepared for West Lake OU-1 Respondents Group. April 10, 2000.
Engineering Management Support, Inc. (EMSI), 2011. 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 in association with Feezor Engineering, Inc. and Auxier &
Associates, Inc. December 28, 2011.
Grandia, F. Merino, J. and Bruno, J., 2008. Assessment of the radium-barium co-precipitation and its
potential influence on the solubility of Ra in the near-field . Technical Report TR-08-07. Svensk
Karnbranslehantering AB, (SKB), Swedish Nuclear Fuel and Waste Management Co. Stockholm. 48
pp .
Guillaumont, R., Fanghanel, T., Neck, V., Fuger, J., Palmer, D., Grenthe, I., and Rand, M . H., 2003. Update
on the Chemical Thermodynamics of Uranium, Neptunium, Plutonium, Americium and
Technetium; Elsevier B.V. Amsterdam. 960 p.
Jacques, D. and Simunek, J., 2005. User Manual of the Multicomponent Variably-Saturated Flow and
Transport Model HPl. SCK-<:EN Waste and Disposal Department. Belgium, SCK-CEN-BLG-998.
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Page 12
Langmuir, D. 1978. Uranium solution-mineral equilibria at low temperatures with applications to

sedimentary ore deposits. Geochim. Cosmochim. Acta . 42:547-569. Mahoney, J.J., 1998.
Incorporation of coprecipitation reactions in predictive geochemical models: in Proceedings of
Tailings and Mine Waste '98, Fort Collins, Colorado, p.689-697 .
Mahoney, J.J ., 2001. Coprecipitation reactions-verification of computational methods in geochemical
models: in Mining Impacted Pit Lakes 2000 Workshop Proceedings: a Multimedia CD Presentation.
(Workshop held April 4-6, 2000 Reno, NV). United States Environmental Protection Agency Office
of Research and Development. EPA/625/C-00/004.
Mahoney, J.J ., Cadle, 5.A, and Jakubowski, R.T., 2009a. Uranyl adsorption onto hydrous ferric oxide - a
re-evaluation for the diffuse layer model database. Environ. Sci. and Technol. vol. 43, no. 24, p.
9260-9266. DOI 10.1021/es901586w.
Mahoney, J.J., Jakubowski, R.T. and Cadle, S.A., 2009b. Corrections to the diffuse layer model database
for uranyl adsorption onto hydrous ferric oxide - Ramifications for solute transport modeling.
Poster presentation at U2009 Global Uranium Symposium, May 2009 Keystone, Colorado .
Nuclear Energy Agency, Organization of Economic Co-operation and Development (NEA, OECD), 2000.
Features, Events and Processes (FEPs) for Geologic Disposal of Radioactive Waste : An
International Database.
Pabalan, R.T., Turner, D.R., Bertetti, P., and Prikryl, J.D., 1998. Uranium VI sorption onto selected mineral
surfaces. in Adsorption of Metals by Geomedia variables, Mechanisms, and Model Applications.
E. Jenne, Editor, Academic Press, San Diego, pp. 99- 130.
Parkhurst, D.L, and Appelo, C.A.J ., 1999. User's guide to PHREEQE (version 2) - a computer program for
speciation, batch-reaction, one-dimensional transport, and inverse geochemical calculations . U.S.
Geological Survey Water Resources Investigation Report 99-4259, 312 p.
Rand, M ., Fuger, J., Grenthe, I., Neck, V. and Rai, D., 2008. Chemical thermodynamics of thorium . OECD
Nuclear Energy Agency Data Bank, Eds ., OECD Publications, Paris, France. 900 p.
Rojo, I., Seco, F., Roriva, M ., Gimenez, J., Cervantes, G., Marti, V., and de Pablo, J., 2008. Thorium
sorption onto magnetite and ferrihydrite in acidic conditions. Journal of Nuclear Materials, Vol .
383. Issue 2., p 474-478.
Sandia National Laboratories. 2010. Features, Events, and Processes (FEPs) for Nuclear Waste Repository
Systems. Presentation by Geoff Freeze, Sandia National Laboratories, Albuquerque, NM on July
21, 2010. Presentation accessed on following website on 03-11-2013:
http://www.sandia .gov/IAEA/Presentations/2010/G Freeze SAND2010 3348P.pdf.
Schroeder, P. R., Aziz, N. M., Lloyd, C. M . and Zappi, P. A., 1994a. The Hydrologic Evaluation of Landfill
Performance (HELP) Model: User's Guide for Version 3. EPA/600/R-94/168a, September 1994. U.S.
Environmental Protection Agency Office of Research and Development, Washington, DC.
Schroeder, P. R., Dozier, T.S., Zappi, P. A., McEnroe, B. M ., Sjostrom, J.W., and Peyton, R. L., 1994b. The
Hydro logic Evaluation of Landfill Performance (HELP) Model: Engineering Documentation for
Version 3. EPA/600/R-94/168b, September 1994. U.S. Environmental Protection Agency Office of
Research and Development, Washington, DC.
Simunek, J., Sejna, M ., and van Genuchten, m . Th ., 1998. The Hydrus 1-D Software Package for Simulating
the One-Dimensional Movement of Water, Heat, and Multiple Solutes in Variably-Saturated Media
- Version 2.0. U.S. Salinity Laboratory, Riverside, california
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Page 13
Tokunaga, T.K., Kim, Y., and Wan, J., 2009. Potential remediation approach for uranium-contaminated
groundwaters through potassium uranyl vanadate precipitation. Environ . Sci. and Technol. vol. 43,
p. 5467-5471.
United States Environmental Protection Agency (USEPA), 1996. Soil Screening Guidance: Technical
Background Document. EPN540/R95/128, Office of Solid Waste and Emergency Response
(OSWER), Wash ington, D.C., May 1996.
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Plans for Modeling. EPN240/R-02/007. December 2002.
United States Environmental Protection Agency (USEPA). 2008. Record of Decision - West Lake Landfill
Site, Bridgeton, Missouri, Operable Unit 1, May 2008.
United States Environmental Protection Agency (USEPA), 2009. Guidance on the Development,
Evaluation, and Application of Environmental Models. EPA/100/K-09/003. March 2009.
United States Environmental Protection Agency (USEPA), 2012. Personal communication (letter to
William Beck and Jessica Merrigan, Lathrop and Gage LLP, Kansas City, Missouri, dated October
12, 2012, regarding Administrative Order on Consent, EPA Docket No. Vll-93-F-OOOS). United
States Environmental Protection Agency, Region 7, Lenexa, KS .
Yoshida, Y., Yoshikawa, H. and Nakanishi, T., 2008. Partition coefficients of Ra and Ba in calcite.
Geochemical Journal. Vol. 42 pp. 295-304.
Zhu, C., 2004a . Coprecipitation in the barite isostructural family: 1 Binary mixing properties. Geochimica
et Cosmochimica Acta, vol. 68, p. 3327 -3337.
Zhu, C. , 2004b. Coprecipitation in the barite isostructural family: 2 Numerical simulations of reactions
and mass transport. Geochimica et Cosmochimica Acta, vol. 68, p. 3338- 3349.
SOW - Fat e & Trans port Modeli ng

4/19/2013
Page 14
Attachment 7 - EPA review of Isolation

Barrier Alternatives Analysis, West Lake
Superfund Site, Bridgeton, Missouri dated
March 10th, 2015
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 7
11201 Renner Boulevard
Lenexa, Kansas 66219
HAR 1 0 2015
Mr. Joseph Benco, P .E.
Vice President
Republic Services
Engineering and Environmental Management
18500 N. Allied Way
Phoenix, Arizona 85054
Dear Mr. Benco:
The U.S. Environmental Protection Agency has reviewed the document titled "Isolation Barrier
Alternatives Analysis, West Lake Superfund Site, Bridgeton, Missouri" prepared by Feezor
Engineering, Inc. and P. J. Carey & Associates, Auxier and Associates, Inc. and Engineering
Management Support, Inc on behalf of Bridgeton Landfill, LLC. The cover letter on the document was
dated October 10, 2014.
The EPA is providing comments for the reviewed document and also enclosing comments from the U.S.
Army Corps of Engineers, Lambert-St. Louis International Airport, the Missouri Department of Natural
Resources and the Missouri Department of Health and Senior Services. All comments should be directly
addressed through written correspondence to the EPA. The EPA requests a 30 working day response to
all comments, but understands that work plans related to the additional characterization work requested
by EPA on January 15, 2015, and Supplemental Feasibility Study may take priority.
If you have questions, please contact me at (913) 551-7611.
Sincerely,
-v.:L
Remedial Project Manager

Missouri/Kansas Remedial Branch
Superfund Division
Enclosure
cc: Shawn Muenks, MDNR
Paul Rosasco, P.E., EMSI
(/ 11"'
40496585
11~1~ 1~111~Superfund
IllIiI~ ~II~~ I ~ II
l, 0
.,
General Comments:
1. The concept of a heating event within radiological waste combined with its effect on the
radiological conditions, specifically radon flux at the surface is complex. The specific
arguments postulated in this document in relation to the heat's effect on the radiologicallyimpacted material (RIM) and therefore_ radon flu~ in, Attachment A are well thought out and
present plausible scenarios considering' an event occurring is a low probability. That said,
several specific comments are provided below with regards to Attachment A (Radon Flux
Analysis) which warrant consideration and/or addressing in the text of this document.
2. Long-Term O&M and Monitoring. The report did not consider long-term operation and
maintenance (O&M) and monitoring associated with the various alternatives. Alternatives 1,
3, and 4 propose the operation of liqu_id heat extraction systems that may pose several
technical challenges (e.g., moving a large amount of liquid, pumping systems, heat
exchangers, liquid loss, etc.). Additionally, this heat extraction system, if it is deployed, may
require operation for several years, and the durability/longevity of this technology is unclear
since we are not familiar with its use at any landfills in the past. Long-term monitoring (e.g.,
waste temperature, settlement) will also be needed for waste located north of the barrier for
Alignment 1, 3, and 4 (as discussed in Section 2.4, Attachment C of the IB Alternatives
Report). Alignment 2, although considered infeasible in the report by Feezor, is the only
Alignment for which IB-related long long-term monitoring of OU-1 would not be needed.
Please review this information and amend the document accordingly.
3. Technical Feasibility. The EPA considers technical feasibility to mean 'able to be
constructed, and effective for its intended use.' It would logically follow that there would be
little or no purpose in selecting and constructing an IB alternative that could be built, but
isn't proven effective in withstanding or containing an SSE. Both Alignment 1 and 3 entail
installing a 45 ft to > 100 ft deep concrete wall spanning the entire waste depth along the
proposed Alignments. The report stated that "although construction of a concrete barrier is
considered to be feasible, installation of a non-deformable barrier within a matrix of solid
wastes is an application which has not previously been applied or demonstrated in solid
waste, so uncertainty as to the success of such a barrier exists." It is unclear how these
Alignments were determined to be technically feasible despite a lack of previous
documentation or successful demonstration/application. An analysis of the efficacy of
Alignment 4, based on referenced literature and documentation, is needed to determine if it is
technically feasible. The EPA understands that a limited field pilot effort was conducted for a
heat extraction well similar to those proposed in Alignment 4, but the scope and duration of
this effort was limited. Alternative 2 is proven and well documented technology; therefore, it
is the only demonstrated feasible technology option included in the report. Please review this
information and amend the document accordingly.
4. Impact of RIM Excavation and Relocation. Three of the proposed Alignments would entail
excavation and relocation of RIM. The estimated amount and impact of RIM excavation and
relocation on risk/human health should be quantitatively evaluated for the four proposed
Alignments, to the extent possible. Also, the amount of RIM remaining south of the barrier
should be estimated for each Alignment, as recent investigations have demonstrated to the
EPA that the extent of RIM has not yet been fully delineated. Benefits and drawbacks of
RIM relocation off-site may be important to discuss in these Alignments as well, including
any potential special handling, manifesting, and transport needs. Please review this
information and amend the document accordingly.
5. No Action Alternative. In general, more data and information are needed to assess the
likelihood and impact of SSE migration into OU-1. The following comments are provided
that could help to better describe and understand the migration of an SSE.
a. The report states "due to the overall thinner nature of the waste materials in Area 1,
the effective rate of heat dissipation in the vertical direction will be
approximately 25 times greater than the rate observed in the South Quarry area of
the Bridgeton Landfill. It is doubtful that any significant pyrolysis would occur at
these shallow waste depths due to the lack of insulation. Such behavior would be
consistent with observations at other sites that indicated no pyrolysis in waste
depths of less than 60 ft." It is acknowledged that a shallower waste thickness
would likely promote heat dissipation. The basis of the magnitude (25 times) of
increase in heat dissipation could not be assessed due lack of details presented in
the report. Similarly, more details on "observations at other sites" made in the
report are needed to assess the conclusion pertaining to the improbability of
pyrolysis in waste depths of less than 60 ft. We note that elevated temperatures
(greater than 200 F) have been observed at waste depths as shallow as 40 ft. We
reference data from TMP-7R in the Bridgeton South Quarry over its operational
lifetime (ending April 2014) that contradict this statement and merits revision.
b. The presence of large soil berm in the North Quarry should not be relied upon in any
design documents until its presence and details (e.g., dimensions and depth location)
are confirmed.
c. The report states that "review of the temperature profiles from temperature
monitoring probes indicate that in the northern part of the South Quarry, the heat
generating material occurs at elevations of greater than or equal to approximately
360 to 380 ft above mean sea level (amsl) ... The occurrence of heat generating
material at elevation of 360 to 380 ft amsl may reflect the limit of the depth of
reactive waste materials or may reflect thermal constraints associated with the
configuration of the South Quarry (i.e. dissipation of heat through the bottom and
sides of the quarry wall which control the vertical position of the pyrolysis),"
We agree that heat dissipation and/or absence of reactive waste below 360-380 ft
amsl may contribute to a decline in waste temperature below these elevations.
However, it is possible that the presence of water/leachate may also have an
influence on the temperature of waste below these elevations. The leachate level at
LCS-lD, which is located in northern part of the South Quarry has ranged from
390.22 ft to 394.22 ft amsl since July 1, 2014. This corresponds to a liquid height of
138-142 ft above the quarry bottom. The impact of the presence of leachate on
lateral heat migration should be evaluated and considered.
d. A review of the calculations presented in Appendix A suggests that the SSE would
result in a temporary increase in radon emissions by 60 pCi m- 2 s- 1 (associated with

thermal expansion of gases present in the pore space of OU-1 waste) above the
estimated existing level of 13.5 pCi m-2 s- 1 Presumably this would result in total
radon emissions of 73.5 pCi m~2s- 1 for a portion of OU-1 (approximately a 75 m2
area). Although the average emission from OU-1 are estimated to be less than the
NESHAP threshold of 20 pCi m-2s-1, the potential for, and impact of, a localized
and temporary spike in radon emissions should be further evaluated.
e. The impact assessment of the SSE migrating into OU-1 was limited to the
evaluation of the impact due to an increased emission of radon. The presence of
RIM in OU-1 may limit the SSE remedial options in the event an SSE migrates into
OU-1. Consideration of the potential remedial options, and the associated impacts of
these options, should be taken into account for a more comprehensive assessment of
impacts of the "No Action Alternative."
f. Section 3.0 (Page 5, 2nd Paragraph). Additional information on the thermal
modeling described in this section would be helpful to assess the potential of SSE
migration into OU-1.
g. Section 3 .0 (Page 5, 2nd Paragraph). The lack of tracking of material addition (e.g.,
for grading purposes) in the South Quarry cell and Neck area complicate settlement
monitoring. Providing this detail in future settlement monitoring would allow for a
more accurate portrayal of site conditions.
h. Section 3.4 (Page 6, 2nd Paragraph) (and other points throughout the document), it is
stated that "No Action" alternative does not pose any potential for odor emission. We
suggest that this be clarified since odor emissions have occurred and been welldocumented at the site for more than a year. The "No Action" alternative would
likely result in similar odors that are currently emanating from the South Quarry if
the SSE were to migrate into the North Quarry and beyond, and should be discussed.
1. Section 3.6.1 (Page 7, 1st Paragraph) states that "Monitoring of waste and landfill
gas temperatures, landfill gas quality (e.g., carbon monoxide and hydrogen), and
surface settlement all indicate that the SSE occurs only in the Bridgeton South
Quarry area ... " To our knowledge, no routine surveying has been conducted in the
Bridgeton North Quarry cell as has been conducted in the South Quarry and Neck
area, so it is not clear how a statement can be made that a lack of settlement in the
North Quarry cell is evidence that no SSE is occurring there.
J.
Section 3.6.1 (Page 8, 1st Paragraph). Including a review of the referenced Phase 1
Investigation of potential IB alignments would be helpful in comparing the stated
conditions in this report to those described in the referenced report.
k. Section 3.6.1 (Page 8, 1st Paragraph). Information presented in this paragraph

suggests that the extent of RIM has been defined, but past sampling did not identify
a complete delineation of RIM. Additionally, the discussion in the report
indicates that a limited amount of RIM is expected to be present in the southwest
border between the Bridgeton North Quarry and OU-1. The dimensions and
justification for this statement would be helpful, as it appears unusual that a very
small amount of RIM would be present given that the barium sulfate material was
used as a routine operational daily cover at the OU-1 cell.
l.
Section 3.6.2 (Page 10, 2nd bullet of 2nd paragraph) states an increase in the emission of
radon as a result of an increase in gas permeability from soil moisture vaporization.
The increase in gas permeability would also increase the advective radon flux. The
radon emission estimate presented in Attachment A is based on RAECOM, which
appears to only estimate the diffusive flux of radon. The impact resulting from an
increase in the advective radon flux should also be estimated.
Specific Comments:
6. One of the core concerns in regards to the concentrations of radionuclides at the site relates to
the fact that the wastes accepted at the landfill contained an elevated ratio of Th-230 to
uranium and radium. The uranium ore processing residues were the result of a process that
was designed to separate out uranium and radium thereby leaving thorium in the residue
(Sections 2.0 and 5.4.2 of the 2008 ROD). Th-230 is the parent radionuclide for Ra-226. Th230 was found on the surface in Area 1 at a maximum concentration of 57 ,000 pico Curies
per gram (pCi/g), while the maximum surface concentration for Ra-226 was 910 pCi/g
(Table 5-2 of the 2008 Record of Decision [ROD]). The 95% upper confidence limit (UCL)
for Th-230 of the arithmetic mean on the surface was 8,140 pCi/g, while the 95% UCL of the
arithmetic mean for Ra-226 on the surface was 581 pCi/g (Table 7-1 of the 2008 ROD). The
95% UCL for Th-230 of the arithmetic mean at all depths was 1,060 pCi/g, while the 95%
UCL of the arithmetic mean for Ra-226 at all depths was 71.6 pCi/g (Table 7-1 of the 2008
ROD).
In naturally occurring material Ra-226 and Th-230 will be in secular equilibrium with each
other. However, the sampling results combined with the materials history indicate that Ra226 and Th-230 are not in secular equilibrium at Area 1. Due to the relatively "short" halflife of Ra-226 (1,600 years) when compared with the much longer half-life of Th-230
(75,000 years), Ra-226 will effectively reach equilibrium with Th-230 in about 10,000 years.
Because of this, it is important that when assessing the future risk and dose at the landfill the
future concentration of Ra-226 should be considered and discussed.
The ingrowth of Ra-226 from the decay of Th-230 was identified as a concern in Section
7.2.2 of the 2000 Remedial Investigation (RI), and a sample calculation is provided for the
Ra-226 concentration in Area 2 after 1,000 years. Going from the 189 pCi/g value for the
95% UCL for the arithmetic mean for Area 2, to 871 pCi/g after 1,000 years. Additionally, in
Table 7-4 of the ROD the future 95% UCL concentration for Ra-226 in the surface soil and
all depths for Area 1at1,000 years are shown to be 3,224 pCi/g and 417 pCi/g respectively.
Furthermore, Table 2 of the 2011 Supplemental Feasibility study (FS) shows a summary of
the Th-230 decay and Ra-226 ingrowth for Area 2. As can be seen on this table, the peak Ra226 concentration occurs at around 10,000 years. This is further demonstrated in Figure 15 of
the FS. In Appendix F of the Supplemental FS, the cover thickness calculations are verified
by use of the same RAECOM web calculator referenced in Attachment A of the Isolation
Barrier Alternatives Analysis document. Appendix F of the Supplemental FS uses the Ra-226
concentration at 1,000 years for the 95% UCL of all the data for Area 1 (which can also be
found in in Table 7-4 of the ROD) when providing the input for the RAECOM calculator.
One could argue that since the Ra-226 concentration will peak and be closer to the current
Th-230 concentration in 10,000 years, the 10,000 year concentration should be used.
However, radiological risk assessments are generally carried out to 1,000 years.
In all of the scenarios provided in Attachment A of the Isolation Barrier Alternatives
Analysis document, the 95% UCL of the arithmetic mean for Ra-226 at all depths of 71.6
pCi/g for Area 1 (from the 2000 RI) was used without consideration of the ingrowth of Ra226 due to the decay of Th-230. While it may be useful to consider current conditions, future
concentrations of Ra-226 due to the decay of Th-230 should be taken into consideration.
7. RIM was identified within 6 inches of the surface of Area 1 during the RI. The most elevated
sample was identified on the surface. While the area identified with RIM present on the
surface is smaller than that of the subsurface, any overburden thickness would be difficult to
assess and in some portions of the site it is known to be zero. Attachment A assumes that an
overburden exists across the site at 30 centimeters when performing the RAECOM
calculations. However, when performing the calculations for the ROD selected remedy in
Attachment A there is no overburden barrier assumed between the RIM and the remedy
layers. The calculations for the cover thickness in Appendix F of the Supplemental FS do not
calculate baseline conditions but rather mimic the ROD selected remedy calculation in
Attachment A. In Appendix F of the Supplemental FS there is no assumed overburden
between the RIM and the remedy. Calculation of the 95% UCL at all depths appears to
include the surface sample results and is the basis of the RAECOM calculations. Section
2.2.2 of the 2011 Supplemental FS states the following:
"Radionuclides are present in surface soil (0-6 inches in depth) over approximately 50,700
square feet (1.16 acres) of Area 1. Approximately 194,000 square feet (4.45 acres) of Area 1
have radionuclides present in the subsurface at depths ranging up to 7 feet, with localized
intervals present to depths of 15 feet."
Please provide an explanation as to why an overburden soil was assumed to be present for the
baseline scenario and why it wasassumed to be 30 centimeters.
8. In section 2.2 of Attachment A the calculated radon flux from the current configuration of
Area 1 is compared to the average measured value during the 2000 RI. It should be noted that
while the average Radon Flux sample resulted in 13 picocuries per meter squared per second
(pCi/m2/s), 24 samples were collected and the three highest values were 245.9 pCi/m2/s,
22.3 pCi/m2/s and one was 8 pCi/m2/s. The remainder were all below 1.9 pCi/m2/s. The
mode of the data is 0.2 pCi/m2/s and the median is 0.4 pCi/m2/s. With the 245.9 pCi/m2/s
value removed the average becomes 2 pCi/m2/s. Therefor the 13 pCi/m2/s average of the
measured data does not compare well with the remainder of the measured data and warrants
clarification.
9. Ra-226 is a naturally occurring isotope found in varying concentrations throughout the
world. The background soil concentrations determined in the RI are around 1 pCi/g. The
RAECOM calculations in Appendix F of the FS assumed that each remedy layer would
consist of material that contained 1 pCi/g. Background concentrations of Ra-226 in soil can
easily range between 0.5 and 3 pCi/g. It would be difficult to find soils that don't contain Ra226. However, the RAECOM calculations included in Attachment A all assume the
overburden, as well as the remedy layers, contain 0 pCi/g. Please provide an explanation for
assuming the overburden and remedy layers contain no Ra-226 activity.
10. In the Isolation Barrier Alternatives Analysis document, one of the disadvantages of some of
the more intrusive alternatives is testing for thorium, requiring a 24-hour sample turnaround
period. Depending on how plans are developed, standard Ra-226 analysis for soil has a 21day turnaround (due to the in-growth of Bi-214) that could further complicate these
alternatives and merits acknowledgement.
11. Another consideration for alternatives that require excavation into the RIM is that
radiologically-impacted fugitive dust has the possibility of being generated and additional
controls to mitigate this would need to be implemented. This would have an impact on cost,
schedule and provide a potential risk to site workers and merits acknowledgement.
Reference:
Engineering Management Support, Inc. (2000). Remedial Investigation Report - West Lake
Landfill Operable Unit 1. Prepared for West Lake OU-1 Respondents Group, 10 April 2000.
U.S. EPA (2008). Record of Decision, Prepared by USEPA Region 7, 29 May 2008
DEPARTMENT OF THE ARMY

CORPS OF ENGINEERS, KANSAS CITY DISTRICT
635 FEDERAL BUILDING
601E12 STREET
KANSAS CITY MO 64106-2824
March 9, 2015
Mr. Brad Vann, Remedial Project Manager

U.S. Environmental Protection Agency Region 7
Lenexa, KS 66219
Dear Mr. Vann:
Per EPA's request, the U.S. Army Corps of Engineers (USACE) has compiled
information regarding additional data required to adequately evaluate the potential effectiveness
of the heat extraction barrier alternative proposed in the "Isolation Barrier Alternatives Analysis
- West Lake Landfill Superfund Site" report dated October 10, 2014. This information was
originally transmitted to you on December 3, 2014.
Pumose:
One of the Alternatives evaluated in the October 2014 Isolation Barrier Alternatives Analysis
report submitted by Bridgeton Landfill LLC is a heat extraction barrier. However, the
Alternatives Analysis report lacked detailed information necessary for USACE to make an
independent technical evaluation of the potential effectiveness of such a system. It is understood
that Bridgeton Landfill, LLC is proposing to expand on the current test well and perform a pilot
study to obtain information to demonstrate the effectiveness of this proposed alternative and to
obtain data necessary for design of the system.
Additional Data Required for Evaluation:
The information identified below is information USACE will need regarding the preliminary
heat extraction study at GIW-4 and information on the next phase of the study consisting of
retrofitting 6 additional GIW wells with recirculation.coolant tubes, to assess whether adequate
information is being collected to design an effective heat extraction system.
Schematic of the modified GIW-4 used in the preliminary heat extraction study including
depth and construction of the well and all pipe sizes where fluid is flowing
Details of the cooling equipment and/or coolant being used in the pilot study.
The preliminary data collected from the heat extraction study at GIW -4 including inflow and
outflow water temperatures, flow rate, and the temperature within the casing measured at
multiple depths.
Printed o n . Recycled Paper
Additional Data Required for Evaluation of Heat Extraction Barrier

March 9, 2015
Calculations to determine the 25kW extraction rate.

Location of the 6 additional GIW wells to be retrofitted with recirculation coolant tubes
including depth and construction of the wells and all pipe sizes where fluid will flow.
An explanation of how the modified GIW wells are representative of the proposed driven
heat extraction wells and whether or not a pilot study of driven wells of the material proposed
for the full scale system will be tested prior to design and installation of the system.
Plans of the proposed closed loop header system used to convey cooling water to the
mechanical cooler.
Location of current Temperature Monitoring Probes and depths and proposed locations and
depths of temperature measurements when the pilot study is expanded.
Proposed study procedures including assumptions used.
Proposed calculations to determine thermal conductivity and heat storage properties of the
landfill waste. In addition, how is obtaining thermal conductivity and heat storage properties
of the South/North Bridgeton landfill waste representative of these properties in the proposed
location of the heat extraction system in the West Lake Landfill waste?
Results of the assessment of heat front progress to the north and the rate of energy flux to the
north.
Calculations used to predict the amount of heat that could be extracted under steady state
conditions and the results of those calculations.
A plan view of the proposed Temperature Monitoring Points as well as a cross section
showing depth intervals of temperature readings. Attachment C indicates it is envisioned as
one array per 120 feet would be sufficient. Is this 120 ft spacing parallel with the proposed
barrier?
It appears the settling front associated with the SSE would render the heat exchange system
non-functional ifthe system fell with the influence of settlement (similar to the need to set
back Option 3 IB wall). Therefore, it appears the heat exchange system would need to halt
the SSE and settling front some distance south of the barrier to prevent this failure from
occurring. What distance is this and what temperature needs to be attained some distance
from the barrier to prevent this from happening?
Additional Data Required for Evaluation of Heat Extraction Barrier

March 9, 2015
USACE is available to meet with you and/or Bridgeton Landfill, LLC as necessary to discuss the
need for the above-requested data.
Respectfully,
KIEFER.ROBYN.V. :r.'!."::',"'.:!'.!.."':':'~'::;.~
1271182852
~~~==-=c!~1l1WSJ
Robyn V. Kiefer
Project Manager
CC:
Scott Young-CENWK-PM-E
Jason Leibbert-CENWK-ED-E
DEPARTMENT OF THE ARMY

CORPS OF ENGINEERS, KANSAS CITY DISTRICT
635 FEDERAL BUILDING
601 E 12 STREET
KANSAS CITY MO 64106-2824
March 9, 2015
Mr. Brad Vann, Remedial Project Manager

U.S. Environmental Protection Agency Region 7
Lenexa, KS 66219
Dear Mr. Vann:
The U.S. Anny Corps of Engineers (USACE) has completed a review of the "Isolation
Barrier Alternatives Analysis- West Lake Landfill Superfund Site" Report dated October 10,
2014 and prepared by Feezor Engineering of Bridgeton, Missouri, P.J. Carey & Associates of
Sugar Hill, Georgia, Auxier & Associates, Inc. of Knoxville, Tennessee, and Engineering
Management Support, Inc. of Lakewood, Colorado on behalf of Bridgeton Landfill, LLC. Note
that this review was a qualitative analysis as plans and specifications for each alternative was not
provided. These comments were originally transmitted to you on November 6, 2014.
USACE comments are as follows:
1)
Section 3.4. If no action option is implemented and the SSE moved through the north quarry into
Area 1, it is likely that the surface of the north quarry would drop and any leachate collection lines
could potentially be severed due to the drop in landfill surface. If that occurred, would leachate
spills from severed lines cause a potential increase in odors?
2)
Section 3.6. At what depth to surface is there a risk of an SSE igniting a surface fire? If the SSE is
able to migrate vertically it seems that there may be a potential for an SSE to ignite surface material.
3)
Section 3.6. Last sentence - recommend including a reference to the section of the report where the
quantitative evaluation for the No Action Alternative is included.
4)
Section 3.6.1. Descriptions of locations of heat generating material are provided in Paragraph 3;
however, it is difficult to follow the description. Recommend including a figure to help show/clarify
the information trying to be conveyed.
5)
Section 3.6.1. Para 5, 4th sentence. Inclusion of boring log cross sections with nearby temperature
probe data on a figure would help clarify this information and prevent the reader from having to dig
through past reports submitted to EPA and reports submitted to MDNR to confirm the information
presented. Additionally, current boring logs from the most recent sampling event where additional
RIM was found would be beneficial as well.
Printed on.
Recycled Paper
USACE Comments - Bridgeton Landfill Thermal Isolation Barrier

Alternatives Analysis Report
March 9, 2015
6)
Section 3.6.1. Last paragraph - overall claim that it is highly unlikely that the SSE could migrate
laterally - recommend that all the data cited to support this claim be provided with this report and
clearly identified.
7)
Section 3.6.1. Para 4, last sentence - Approximately how many other sites indicate no pyrolysis
occurs in waste depths ofless than 60 feet? Refer to section 4.7, advantages bullet 4, which states
alignment 1 offers the lowest potential for a SSE to original on the north side of the barrier because
the alignment is located along the northern boundary of the North Quarry area. Recommend
consideration that the bullet language be changed to state that it offers the lowest potential for a SSE
due to the alignment and the thickness of waste being less than 60 feet.
8)
Section 3.6.1, 3rd Paragraph. The 10th line states that materials below the 360 to 380 elevation are
undergoing heat loss. Para states that 360 to 380 may be the depth of reactive wastes or may reflect
"thermal restraints". Has the elevation of the groundwater level in this part of the quarry been
considered? Is it such that the groundwater level is serving as a "thermal restraint"?
9)
Section 3.6.1, 3rd Paragraph. The final sentence in this paragraph states that a similar pattern of heat
dissipatiori is seen as the elevation in the landfill approaches the ground surface. The on-going
studies/data that support this assertion and others made within this report should be included in this
report as an attachment so the assertions can be easily verified without having to search through
multiple reports to find supporting data.
10) Section 3.6.1, 4th Paragraph. This paragraph builds on the assertions of the previous paragraph
stating that significant reduction of waste thickness in the north section of the north quarry will
increase heat dissipation and expressed doubt that any significant pyrolysis would occur in wastes of
such a shallow thickness. The paragraph asserts that this is consistent with observed behaviors of
other sites with waste thickness less than 60-feet. Please provide references of the cited landfill
SSEs to facilitate review of the referenced performance.
11) Section 3.6.l, Pg 7, 3rd Paragraph. How is the 25 times greater heat dissipation in Area l over that of
the South Quarry determined?
12) Section 3.6.l, Pg 7, 3rd Paragraph. The statement that "no pyrolysis in waste depths ofless than 60feet should be supported by literature and/or example sites.
13) Section 3.6.l, Pg 8, l 51 Paragraph. It would be helpful to provide a figure (cross section) illustrating
what is being described in this paragraph.
14) Section 3 .6.1, Page 7. Typo in second paragraph " ... indicating they these materials ... "
15) Section 3.6.2. It would assist in evaluation to provide updated figures defining the perimeter of Area
l. Figure 4-14 from the RI shows the locations where flux sampling was conducted. Locations 105,
107, 110, 120, 121, 122, 123 and 124 appear to be outside of the defined Areal boundary and their
use in determining average flux activity may bias the actual flux from Area l low, though Location
105 does appear to have elevated Ra-226.
16) Section 3.6.2. Is Subpart T (Disposal of Uranium Mill Tailings) the cited NESHAP requirement? St.
Louis FUSRAP has evaluated radon releases against the 40 CFR 192.02 (b) alternate criteria of0.5

March 9, 2015
pCi/L, which may be also be an appropriate criteria to evaluate ifUMTRCA is an ARAR. This
would be better criteria to evaluate what exposure there may be to members of the public, if any.
Models such as CAP88, AERMOD, or RESRAD-Offsite may be helpful to demonstrate a lack of
current exposure, or monitoring data taken downwind from the facility could be discussed.
17) Section 3.6.2. It may be helpful to note here that additional radon generation may also be present in
effluent releases from the gas collection system and not solely through radon emanation from the
surface as discussed in Section 4.4 of Appendix A.
18) Section 3.6.2. Bullets - there were a total of 7 conclusions in EMSI's report. 5 of those conclusions
appear to relate to potential impacts if an SSE were to occur of the SSE that, at a minimum, should
be addressed as part of a no action consideration. This report addresses only 3 of the 5 bullets.
Recommend including and addressing bullet 4 from EMSI's report: "An SSE in West Lake Areal
or 2 would create no long-term additional risks to people or the environment." and bullet 5 from
EMSI's report: "Any short-term risks would be associated with the temporary increase in radon gas
coming from the surface of the landfill if no cap is installed on the landfill, or if the cap called for by
the 2008 ROD was not properly maintained."
19) Section 3 .6.2. Para 4. the Flux calculations in Attachment A are compared with surface radiation
measurements from the EMSI RI report in 2000. Recommend including that surface measurements
will be taken to confirm calculated concentrations prior to selection of any no-action approach.
20) Section 2.6.2. Para 6. states that "even if these conditions were to occur, the radon emission rate
from Area l could still be less than the standard .... " then in the last sentence of the paragraph states
the magnitude of radon emissions would still be less than the establishes standard .... " The use of
these two words seems contradictory.
21) Section 3.6.2, p 9, 3rd Paragraph. The discussion regarding leachate generation rates is appears
inconsistent with the June 2013 Contingency Plan which states, "Heating of waste which results in
steam/water vapor front moving out, up, and away from the SSE, which then condenses in the cooler
surrounding waste mass and gas extraction well resulting in higher localized leachate generation."
Please clarify.
22) Section 3.7, Pg 12, 4th bullet. This bullet appears redundant. Recommend removing.
23) Section 3.7. A no action alternative would still require additional monitoring to observe whether
modeled radon flux corresponds to actual radon flux in the event an SSE migrates to/occurs in Area
I.
24) Attachment 1, section 2.2. The RI states that the 95% UCL of the mean for surface radium is 581
pCi/g. Because shallow/surface material will contribute more to radon flux than subsurface material,
it seems like an additional surface layer should be added to the RAECOM model.
25) Attachment 1, section 2.2. Though the reviewer agrees that the average flux calculated over Area 1
is 13 pCi/mA2/s and below the 20 pCifmA2/s standard, Area 1 seems very heterogeneous, with only 1
measurement the same order of magnitude as 13 (location WL-106 at 22.3) Most flux measurements
are well below this, but measurements exist ranging from 0 to as high as 246 pCi/mA2/s. Given that
sample data and flux data is available for most locations it may be helpful to run the model for each

March 9, 2015
location where surface flux and surface/subsurface sample data is available to determine how well
the RAECOM model compares to actual site data.
26) Attachment 1, section 2.2. It would be helpful to justify the use of 0.2 as the radon emanation
fraction, as the RAECOM online instructions recommend a value between 0.2 - 0.3 and 0.2 is the
low end of this value. The RESRAD default value is 0.25, which may be more appropriate.
27) Attachment 1, section 2.2. This analysis seems to imply an SSE is impacting the top 1.7 m of soil.
At what point would risk transition from increased radon release from subsurface soil to release from
a surface fire? If an SSE encounters material in the top 6' of soil it seems like ignition of surface
material may pose a larger risk than increased radon production. A surface fire could potentially
pose greater risk than a SSE (ie. dust kicked up with Th or U).
28)
Attachment 1, section 2.2. Is the cited gas temperature increase to 80" C consistent with current
observations of the SSE and assumptions used for the design and evaluation of alternatives?
Discussion above (Section 6.1) seems to suggest 200"F (-90" C) is a design consideration?
29) Attachment 1, section 2.2. Area 1 should be better defined on a drawing (similar to Figure 4-14 of
the RI) to ensure that "clean" flux measurements are not inadvertently included, see comment #16
30) Attachment 1, section 4.5. Though a comparison to 10 CFR 20 may be helpful in the absence of
other regulatory criteria, it should be noted that 10 CFR 20 effluent releases generally apply only to
releases from an NRC licensee and may not be applicable at a CERCLA site. The effluent
concentrations listed in Table 2 correspond to a public total dose of 50 millirem/year, which is above
those generally allowed by EPA at CERCLA Sites. Recommend you don't compare to 10 CFR 20
since EHA has a more stringent standard.
31) Attachment 1, section 4.5. Suggest removal of the last paragraph of Section 4.5 as the release of
radon into the air from stack release is not directly comparable to radon present in soil gas.
32) Attachment 1, section 4.5. 10 CFR 20 Appendix B Table 2 contains two values for radon, one for
radon in 100% equilibrium and one for radon without daughters. Suggest a clarification that radon
effluent releases are being compared to the 0.1 pCi/L criteria that assumes all daughters are present
in equilibrium, or provide a discussion of measured/assumed equilibrium factor.
33) Section 4.0. The analyses of Options 1and3 generally agree with the analyses completed by
USACE and provided to the EPA in the "Isolation Barrier Alignment Alternatives Assessment"
dated 25 August 2014.
34) Sections 4.0 and 6.0. The eastern limits of the Option l & 3 alignments shown on Drawing 002
appear to violate the location of the North Quarry wall shown on Figure 2 of Part I of the Bridgeton
Landfill Contingency Plan. Please verify that the proposed alignment does not violate the quarry
wall and indeed meets the assumed 45-degree offset.
35) Sections 4.2 and 6.2. The excavation volumes are based on a 60-foot wide working platform which
will be wide enough to accommodate the slurry trench excavating machinery and tooling. But the
typical section of the slurry trench cutoff wall shown in Dwg 16 locates the wall at the center of the
60-foot wide platform. The plan view of Alignment 1 with the Waste Cut areas shown on Dwg 003

March 9, 2015
clearly shows the alignment assumed to be at the centerline of the work platform. But to
accommodate the excavating machinery, the excavated trench will need to be much nearer one of the
edges of the work platform. Given that the alignment is fixed based on occurrence and nonoccurrence of RIM in the foundations, and the alignment must be near the edge of the working
platform, the excavation plan must be shifted laterally up to 20-feet. Similar issue with Alignment 3.
36) Section 4.2, Pg 13, 11 Paragraph. A construction platform of 45-ft was originally discussed. A
comment was made on the Pre-construction work plan, section 2.1 that asked you to ensure that the
proposed 45-ft wide excavation is enough to allow access for support vehicles. Is the additional 15
feet required for support vehicles? If so, please clarify what this width accommodates and how the
equipment will be configured such that 60' is required.
37) Section 4.2, Pg 13, 151 Paragraph. Based on a review of the cross sections and a comparison to
Option 3 (where there is substantial change of elevation along the length of the wall), it appears that
a working platform could be constructed for Option 1 with much lower pre-excavation volumes.
This would result in a slightly deeper wall but may be a good tradeoff due to odor and bird
mitigation issues.
38) Section 4.2, Page 14, top Paragraph. This indicates the barrier volume is 5,000 bey, however sheet
003 indicates the barrier volume is 7,500 bey.
39) Sections 4.3 and 6.3. The 10th line states that trench construction "using slurry would require slurry
decanting/liquid". Slurry trench construction requires large volumes of slurry (typically soilbentonite slurry) to provide trench wall support during trench excavation. When completed this
slurry is typically processed to remove as much of the soil solids that are suspended in order to
reduce the volume of slurry liquids that must be properly disposed of. A 10-foot wide, 3-foot thick,
and 40-foot deep panel will need 1,200 cu-ft (8,970 gallons) of slurry. In this case, if a particular
trench panel encounters RIM during its excavation, how will the slurry be disposed of? How you
intend to address the slurry should be included in Section 4.1 or 4.2 (and 6.1 or 6.2) as it is waste
that will be required to be disposed.
40) Sections 4.3 and 6.3. USACE has studied the 3-dimensional global stability of earthen levees
assuming discrete panels excavated near the levee toe. This analysis is completed using FLAC-30.
Depending on the geotechnical parameters of the various fills/wastes encountered in the trench and
remaining in the adjacent excavated slopes, longer panels may be safely used thereby shortening the
construction times. To complete this analysis, detailed geotechnical exploration incorporating insitu measurements of shear modulus with pressure meter must be completed. Recognize that this is
a design issue to be addressed later; however, it can impact the quoted schedule.
41) Section 4.3, Pg 14, 151 Paragraph. Recommend changing "reaction" to "SSE".
42) Section 4.3, Pg 14, 1"' Paragraph. Recommend expanding on the limitation associated with storm
water management.
43) Section 4.3, Pg 14, l 51 Paragraph. The design timeframe (103 wks) has increased substantially over
what had been previously discussed. Based on a review of the schedule there appears that there are
places where durations could be reduced. For example, investigations could begin prior to
completion of the heat extraction study.

March 9, 2015
44) Section 4.3. Last Paragraph. EPA will have to make determination on requirement regarding the
need to test waste above the 1975 topographic surface. This is a landfill and although there may not
be RIM above the 1975 topographic surface, there may be other constituents of concern and testing
may be warranted.
45) Section 4.6. Recommend that laboratory data and boring logs from last sampling event be provided
along with an updated dwg of currently know extent of contamination and information regarding
vertical distribution of contamination if the information is to be relied upon for this report to back up
a no action response. Recommend including a dwg showing estimated 1975 topographic surface and
1975 aerial photographs upon which this estimated surface is based. Would need to include that
information that is being relied upon in this report to support the no action option.
46) Section 4.6. Para 2 - recommend ~he specific section in Attachment A that contains the info being
referenced in this text be added within the parentheses so it is easy for reader to locate the
information.
47) Section 4.7, Pg 17, 6th bullet. Although there is a caveat later in the document regarding
acceptability ofleaving excavated RIM waste on-site, that is far from certain so recommend not
listing it as an advantage.
48) Section 4.7. It would be helpful in evaluating alternatives if an estimate of the potential amount of
RIM to be excavated was discussed.
49) Section 4. 7. The extent of RIM has not yet been determined. Recommend author considers
qualifying the language in the first paragraph by indicating that the statements are based upon data
collected to date and that the extent of RIM has not yet been determined.
50) Section 4.7. Report states, "Radon emissions from the RIM material located outside of the barrier
would not result in an exceedance of the Radon NESHAP." Because the extent of RIM' has not yet
been identified and because of the heterogeneity of the waste placement, recommend that this text be
revised to allow for this consideration.
51) Section 4. 7. Disadvantages - can non-rad waste removed as a result of barrier installation be placed
back in the landfill? If this has not yet been determined, then it is recommended that it be captured
as a disadvantage because there is a possibility that it would not be approved. If not approved, it
would significantly impact the construction duration.
52) Attachment B, para 1.1.2. Another opportunity to provide clarity to the design would be to assume
that the "maintenance" of the wall would include re-adjustment of the top of fill elevation on the
"hot-side" of the wall. As the pyrolysis induced settlement (accelerated settlement due to
consumption of waste materials due to SSE) occurs, the ground surface on the "hot side" of the wall
could be raised to limit the difference in ground surface between the "hot side" and "cold side" of the
wall. Use of careful compaction techniques (from just spreading fill to fully compacting the fill)
could keep the in-place unit weight of the fill to within acceptable levels to equalize the geostatic
horizontal stress placed on both sides of the wall.

March 9, 2015
53)
Attachment B, para 1.1.2. The first paragraph states that it has been determined that anchoring the
NCE into the alluvium/bedrock is not feasible. Dwg 004 shows the Option 1 NCE proposed to
extend down to elevations 420 to 430. Cross section AA in Figure 2 of Part I of the Bridgeton
Landfill Contingency Plan shows bottom of wastes or top of bedrock at/around elevation 425 under
OU-I Area I. It seems that the top of rock may be quite close and if so, anchoring the NCE into the
bedrock may not be as infeasible as first thought. Use of hydro mill technology to key into the
bedrock is a common technique. Keying into bedrock will provide clarity on the fixity of the bottom
oftheNCE.
54) Attachment B, para I .1.2. Perhaps the responsible party should consider a limited application of the
heat extraction technology installed on the "hot-side" of the wall. If successful, it could limit the
temperature applied to the concrete surface and thereby limit the heat induced stresses/strains.
55) Attachment B, para 1.1.3. See comment #42 concerning 3 dimensional slope stability using FLAC-
3D.
56) Attachment B, para 1.1.3. A monitoring system will also include surveys of the ground surface
adjacent to both sides of the wall. Also, replaceable temperature gages should be installed in the
wall interior. Given the proposed life span of the wall, the temperature gages would have to be
accessible for maintenance and replacement as necessary. Also some kind of telltale extending to
the base of the wall to determine its elevation (if not embedded into bedrock) should be considered.
It is recognize this is a design consideration and would be addressed during design.
57) Section 6.2, Pg 22, 1st Paragraph. Recommend explaining why a barrier width of 5.0-ft was assumed
versus the 3.0-ft width of Option I. It is assumed this is for structural considerations due to the
greater depth of the wall.
58) Section 6.2, Pg 22, 1st Paragraph. Sheet 010 indicates a barrier volume of 7 ,500 bey for Option 3 as
opposed to the 11,000 bey sited here in the text.
59) Section 6.7, Pg 25, 2d bullet. Recommend not listing the potential to leave excavated RIM waste
on-site as an advantage.
60) Section 6.7. The extent of RIM has not yet been determined. Recommend author considers
qualifying the language in the first paragraph by indicating that the statements are based upon data
collected to date and that the extent of RIM has not yet been determined.
61) Section 7. It is stated that for Option 4, the heat extraction points would be installed such that depths
of the extraction points would be relatively shallow. Does this shallow installation still include
installation down to the bedrock as indicated in drawing sheet 16?
62) Section 7. I. It is stated for Option 4, that the cooler would consist of an adiabatic air cooler installed
with a closed loop liquid circulation system. While Attachment C., Heat Extraction Barrier Design
Memorandum, describes a close circuit cooling tower. Please verify that a close circuit cooling
tower is the current design concept.

March 9, 2015
63) Section 7.1. The limiting criteria for any barrier system would be to maintain the waste on the north
side of the barrier at an average temperature of 17 5 degrees Fahrenheit. What is the best guess for
the entering and leaving temperatures of the cooling liquid at this time?
64) Section 7.1. The heat extraction points would be driven in place vs. drilling a well. What is the
typical depth that the pipe can be driven into place? What is the depth of the bedrock at the
proposed locations? What is the possibility of success with this method of installation?
65) Section 7.6. Para 2. Potential RIM outside the barrier is not expected to pose a significant risk (see
attachment A) and RIM outside barrier would not result in exceedance of Radon NESHAP.
Recommend the specific section in Attachment A in which the information that supports this can be
found is cited in the parentheses.
66)
Section 7.7. It is stated for Option 4, that "The RIM material that would remain outside of the
barrier wall is currently covered by 25 to 50 of solid waste and a landfill cover that prevents direct
contact with the RIM and provides shielding from gamma radiation." Recommend units of
measurement be inserted (ie. " ... 25 to 50 'feet' of solid waste ... ").
67) Section 7. 7. It is stated for Option 4, that "Installation of heat extraction points is a common
technology used for geothermal energy development and therefore this alternative is technically
feasible." However, it comes down to the numbers. How do the proposed conceptual design
conditions compare to the design conditions for a typical system that comprises this common
technology? Do geothermal systems exist that have design conditions that are in the same
neighborhood of the conditions that will exist within the SSE?
68) Attachment C, Section l. l. It is stated that "The primary data parameters recorded ... " from the
single well, GIW-4, " ... were the inflow and outflow water temperatures, flow rate and the
temperature within the casing as measured by thermocouples at multiple depths. Where is that data,
specifically the water flow rates and the entering and leaving water temperatures? Recommend that
data be included in the report to as an attachment to support the claim offeasibility.
69) Attachment C, Section 1.3. It is stated that "Estimates of the maximum heat flux in the south quarry
have been in the range of 14 Watts/sqm, as of July 2013." This rate is very low. This rate is slightly
less than 5 Btuh/sqft, which, as a comparison, would not fully heat a typical building to typical
occupied conditions in the warmest areas of this country. Over what area is this rate determined?
What is the total heat to be rejected by the system?
70) Attachment C, Section 2.2. It is stated that the vertical heat extraction elements be comprised of
corrosion resistant metal (low carbon stainless steel) or nonmetallic materials. Metallic materials
underground may required cathodic protection while temperature limitations maybe an issue for
nonmetallic materials. It is recognized that this is a design issue that will need to be considered
during design.
71) Attachment C, Section 2.3. Please confirm that the proposed design delta temperatures for a cooling
tower powered system are 175 degrees F minus 85 degrees For 90 degrees F.
72) Attachment C, Section 2.3. Please confirm that the proposed design delta temperatures for a chiller
powered system are 175 degrees F minus 40 degrees F or 135 degrees F.

March 9, 2015
73) Attachment C, Section 2.3. It is stated that "These systems will be above ground HOPE pipe with
flex connections to the extraction points." Typically, we only see HOPE pipe installed below grade
due to issues with UV. How will this be addressed? It is recognized that this is a design issue that
will need to be considered during design.
74) Attachment C - General. The issue with utilizing typical HV AC machines in this situation is that
the equipment pretty much does what it was designed to do, which is not a delta temperature of 90 to
135 degrees F. Specifically, vapor compression chillers typically will not produce a delta
temperature above 20 degrees F and will shut down on a safety if entering water temperatures
become too extreme. With a flowing fluid, do you intend to use equipment in series to achieve the
necessary temperature differential? Do you know of a specific chiller that is capable of these high
temperature drops?
75) Attachment C, Pg 3, 2nd Bullet. Why was a point of compliance of 15-ft north of the cooling
elements selected for Option 4?
76) Drawing 16. The Option 1 and 3 Typical Inert Barrier shows the barrier centerline located in the
center of the flat work area. To accommodate the heavy excavation machinery and tooling, the Inert
Barrier must be located approximately 45 to 50 feet away from either edge. USACE studies of slope
stability show that better global stability factors of safety are obtained when the heavy excavation
machinery and tooling is located on the side of the trench opposite the taller excavated slope.
77) All Drawings. All drawings show historical boundaries. Recommend these drawings be updated to
reflect current contaminant boundaries with a dashed line where the extent of contamination has not
been determined.
78)
Drawings 002 and 009. The eastern limits of the Option land Option 2 alignments shown on
Drawings 002 and 009 appears to violate the location of the North Quarry wall shown on Figure 2 of
Part I of the Bridgeton Landfill Contingency Plan. Please verify that the proposed alignments do not
violate the quarry wall and indeed meets the assumed 45-degree offset.
79) Drawings 003 and 010. Each of these drawings include values of pre-excavation and barrier
excavation volume. Recommend also showing the overall volume needing to be relocated.
80) Sections 3.5, 3.6, 3.7, 4.5, 4.6, 4.7, 5.0, 6.5, 6.6, 6.7, 7.4, 7.5, 7.6, 7.7, and Attachment D. There is
still no Bird Monitoring and Control Plan to review. The sections reviewed considered the concerns
of the St Louis Airport Authority and consistently assessed the concerns of quantity of waste and
duration of exposure and the impacts those two things have on Bird Airstrike concerns. A new
Alternative, Heat Extraction Barrier, was introduced that has less bird airstrike implications than the
other options. There was not much emphasis placed either on covering excavated waste or in
handling and transport of waste for installation of the isolation barrier. This should be covered in the
forthcoming Bird Monitoring and Control Plan.
10

March 9, 2015
USACE is available to participate in a comment resolution meeting upon request.

Respectfully,
KIEFER.ROBYN. ""''"'-"'""""""''"'"'"""'
DJol cUS.0-US ~nt.auDo0.11""NI
V.1271182852 :-::;~~~:~ "
11112
Robyn V. Kiefer
Project Manager
CC:
Scott Young-CENWK-PM-E
Jason Leibbert-CENWK-ED-E
LAMBERT-ST. LOUIS
INTERNATIONAL
AIRPORT~
Rhonda Hamm-Niebruegge
Director
November 19, 2014
Mr. Karl Brooks
Regional Administrator
U.S. Environmental Protection Agency, Region 7
I 120 I Renner Boulevard
Lenexa, KS 66219
Re:
Isolation Barrier Alternatives Analysis, West Lake Landfill Superfund Site
Dear Mr. Brooks:

Thank you for providing The City of St. Louis ("City''), the owner and operator of
Lambert-St. Louis International Airport (the "Airport"), the opportunity to comment on the
above-referenced Isolation Barrier study, dated October 10, 2014 (the "Study"), which was
prepared on behalf of Bridgeton Landfill, LLC ("BL"). The City understands that the U.S.
Environmental Protection Agency ("EPA") is dealing with an extremely complicated subsurface
smoldering events at the West Lake Landfill Superfund Site ("Site") that may pose a potential
impact to the public's health and safety. Clearly, this is an enormously complex project that must
also deal with very complex mitigation issues at the Site, and we appreciate the opportunity to be
involved.
The City has shared the Study with the Federal Aviation Administration ("FAA") and the
U.S. Department of Agriculture, Animal and Plant Health Inspection Services - Wildlife Services
("USDA-APHIS-WS") and has consulted and coordinated with each agency in the course of
evaluating the Study. As requested, this letter provides the City's comments on the Study from
the Airports perspective in regard to bird and wildlife hazards to aircraft navigation due to the
Site's proximity to the Airport.
The City has no expertise in determining whether landfill materials need to be isolated,
nor is the City able to comment on the technical effectiveness or feasibility of any of the
isolation methods evaluated in the Study. Such matters arc not within the expertise of the City,
the Airport, FAA or USDS-APHIS-WS. The City's sole purpose in reviewing the Study and the
various options evaluated in the Study is to ensure that bird and wildlife hazards to aircraft
navigation to and from the Airport will be addressed adequately in whatever action is determined
appropriate to address the ongoing subsurface smoldering events at and/or near the Site. In
addition, in making comments on this Study, the City is in no way commenting on or evaluating
any matters regarding the final or any interim remedy for the Site. The City's comments relate
solely to the Study.
P.O. Box !0212 I St. Louis, MO 63145-0212 U.S.A. I City of St. Louis Airport Authority I Main Phone 314-4268000 I Fax: 314-426-5733
~(jfSTL.com
November 19, 2014

Page 2
General Considerations
As you know, the City holds a negative easement at the Bridgeton Landfill and certain
areas in the vicinity of the Bridgeton Landfill to ensure that the landfills in this area will not pose
a bird hazard to aircraft. Putrescible waste attracts birds, which create a safety hazard to air
navigation. Any new operation that exposes putrescible waste in such close proximity to the
Airport could result' in a new bird hazard to aircraft, impacting the safety of the 13 million plus
passengers who fly in and out of the Airport every year. The City's considerations with the
options set forth in the Study focus on the amount putrescible waste that would be exposed under
each option, on the length of time such waste would be exposed, and on the manner in which the
waste is extracted and exposed. The more putrescible waste is exposed, the longer the tenn of
the exposure, and the larger the area of exposure, the greater the potential for a bird hazard to
aircraft. Any option chosen by the EPA that would expose putrescible waste must include a
robust wildlife hazard identification, monitoring, mitigation, and elimination plan to identify the
potential for bird hazards very early, before any bird activity is established because once a bird
hazard to aircraft develops, it is much more difficult to control and eliminate.
As you are aware, the City has reviewed and approved BL's Bird Hazard Monitoring and
Mitigation Plan for Ongoing Landfill Work (Revised June 24, 2014), which deals with limited
ongoing work as defined and provided for therein and expressly excludes more extensive waste
disturbance like the construction of an isolation barrier but does include monitoring and
mitigation of bird issues regarding the basins at the Site. As the City has articulated in previous
correspondence to the EPA, any time putrescible waste is excavated or exposed at the Site, a bird
monitoring and mitigation plan containing the elements set forth below must be implemented.
The more putrescible waste exposed, the more rigorous and detailed the plan must be. The
necessary elements of a bird monitoring and mitigation plan for an isolation banier plan must
include the following:
1)
Mitigation measures during work. Mitigation measures during excavation of

putrescible waste to minimize bird attractants must be an integral element of
any work plan and these measures need to be implemented throughout the time
that any putrescible waste is exposed. Depending upon the particular work, the
measures may include routine covering of excavated materials, closed
containers, rapid off-site waste disposal or other measures to minimize the
exposure of putrescible waste to wildlife. In addition, any work that will cause
the on-site pooling of storm water runoff or other water must be designed to
minimize the time that pooled water accumulates.
2)
Appropriately trained personnel. AH mitigation and monitoring measures must

be developed or approved by and work supervised by professionals trained in
wildlife management and control. The professionals must have appropriate
experience not only in wildlife management, but also in means to identify and
control wildlife hazards. Training comparable to FAA Advisory Circular
l 50/5200-36A as may be amended, or alternative training and experience
reasonably approved by the City is necessary.
November 19, 2014

Page 3
3)
Daily monitoring. Monitoring for bird hazards by trained personnel on at least

a daily basis at all times when putrescible waste is exposed. At a minimum
appropriately trained personnel must be on-site on a daily basis to monitor,
assess and document bird populations and identify any potential bird hazard
during active excavation. It is essential to timely identify the creation or
development of a bird hazard so that it may be eliminated quickly before
aircraft safety issues develop.
4)
Control measures. If monitoring indicates a bird population increase or a

potential bird hazard, the plan must call for additional measures to control and
eliminate birds. These control measures must be directed and implemented by
appropriately trained individuals. A robust and flexible bird repellant program
must be implemented including escalating measures such as an intensive
harassment program including the use of pyrotechnics, propane cannons,
trapping and, where necessary, lethal control to ensure birds do not congregate
at the Site. Appropriate equipment for dispersing birds must be on-site at all
time and staff must be properly trained in the equipment use and application.
5)
Reporting. The City will need weekly reports of bird populations and
immediate reports of any bird hazard identified during any time periods when
putrescible waste is exposed.
6)
Reimbursement agreement. Before construction starts, the City will need to

have in place an agreement with BL to reimburse the Airport for expenses
associated with monitoring and, if necessary, responding to any bird hazards at
the landfill during the project due to BL's refusal or failure to timely respond.
Isolation barrier plans that require excavation of large quantities of putrcscible materials will
necessarily require a much more detailed bird management and control plan, especially in terms
of mitigation measures, than barrier plans with minimal or no waste excavation.
Comments on Individual Options
We reviewed the Study including Mr. Rolph A. Davis, Ph.D. report dated October 7,
2014, attached as Exhibit D to the Study and entitled "Isolation Barrier Alternative Analysis Bird Control Issues". The City concurs in general with Dr. Davis's evaluation of the various
options and agrees that the final details of the bird management and control plan will need to be
determined in coordination with the City during the engineering phase of the project once the
barrier option has been selected. Listed below are the City's comments on the individual options.
No Action. The Study indicates that the No Action alternative would not create
additional bird attractions. The City will point out that even under the No Action alternative,
measures that are currently being implemented would be continued and such measures do have
the potential to attract birds since additional storm water detention is occurring and some
excavation is necessary to maintain wells and perform other activities associated with the landfill
cap. The City acknowledges, however, that iflandfill personnel are appropriately trained and the
November 19, 2014

Page4
current Bird Hazard Monitoring and Mitigation Plan is implemented, unmanageable bird hazards
are not anticipated.
Option 1: Inert Barrier Along Alignment 1. The Study indicates this option involves the
excavation of 52,000 bank cubic yards ("bey") of putrescible waste and the redeposition of this
waste on-site. Approximately seven acres of disturbed putrescible waste would be involved and
waste would be exposed for 40 weeks. The City agrees that this option poses a strong potential
for the exposure of waste that will attract wildlife to the excavation and redeposition areas. A
rigorous bird hazard and mitigation plan would need to be implemented and the project itself will
need to be designed to minimize exposing putrescible waste. In addition, since the potential for a
bird hazard cannot be known completely until the work is in progress, the project plan will need
to include the ability to halt construction, eliminate hazards and design additional bird hazard
mitigation measures during construction, if a bird hazard develops.
Option 2: Air Gap Barrier. This Option 2 was not proposed for additional detailed
evaluation due to the significant disadvantages associated with this approach as set out in the
Study. The Study does indicate that at least 540,000 bey of waste would need to be excavated to
implement this option and the option would involve 400 days of excavation. It appears that the
areas of waste exposed could exceed the areas found in typical operating landfills, which pose a
bird hazard to aircraft operations when located in close proximity to airports. Since such hazards
generally cannot be mitigated successfully, operating landfills are prohibited in proximity to an
airport (see Hazardous Wildl~fe Attractants On or Near Airport - Advisory Circular 215015200 33B). It is very doubtful that any excavation under this option could be successfully implemented
without creating substantial risk hazards to air navigation.
Option 3: Inert Barrier Along Alignment 3. The Study indicates this option involves the
excavation of 63,500 bey of waste and redeposition of waste on-site. Approximately seven acres
of disturbed putrescible waste would be involved and waste would be exposed for 48 weeks,
including newer waste that may be more attractive to birds. Similar to Option 1, the City agrees
that this option poses a strong potential for the exposure of waste that will attract wildlife to the
excavation and redeposition areas. A rigorous bird hazard and mitigation plan would need to be
implemented for this project and the project itself would need to be designed to minimize
exposing putresciblc waste. In addition, since the potential for a bird hazard cannot be known
completely until the work is in progress, the project plan will need to include the ability to halt
construction, eliminate hazards and design additional bird hazard mitigation measures during
construction, if a bird hazard develops.
Option 4: Heat Extraction Barrier. The Study indicates that no or only minimal waste
excavation/relocation is anticipated to be necessary to implement the heat extraction barrier so
that no bird mitigation/management measures are necessary. The City is skeptical that no waste
will be excavated to implement this remedy; however, this option appears to pose a very low
chance of developing a bird hazard to aircraft. Given that work would be conducted within the
waste material, the City would expect a bird hazard monitoring and mitigation plan to be
developed for the work. However, urunanageable bird hazards are not anticipated under this
option.
November 19, 2014

Page 5
The City will continue to coordinate its efforts with the FAA and the USDA-APHIS-WS and
will continue to work with EPA as it evaluates options for isolating waste at the Site. We
appreciate the opportunity to comment on the Study and we are available to discuss our concerns
and comments, at your convenience.
Very truly yours,
___ ._.,...------........_ __
~.i'..c~-?71~ ~~
Rhonda Hamm-Niebruegge
Director of Airports
cc:
The Honorable Chris Koster

Aaron Schmidt, MDNR
Jessica E. Merrigan, Lathrop & Gage
Mario Pandolfo, Associate City Counselor
Gerald A. Beckmann
"I .\I I di' \I b\! ll l<I
l)EPAR1'MEN-r ()l' NA.fLJRAL
RFS<)URC~ES
NOV Z 4 2014
Ms. Lynn Slugantz
Oflice of Regional Administrator
U.S. EPA Region 7
1120 I Renner Blvd.
Lenexa. KS 66219
RE:
Comments on lsolatkm Barrier Alternatives Analysis, West Lake Landfill Superfund

Site. dated October 10. 2014
Dear Ms. Slugantz:

This comment letter is in response to the submittal prepared by Engineering Management
Support Inc. (EMSI), Feezor Engineering. Inc., P.J. Carey & Associates, P.C., and Auxier &
Associates, Inc. entitled "Isolation Barrier Alte'rnatives Analysis, West Lake Landfill Superfund
Site'', which was transmitted to Lambert-St. Louis International Airport by letter dated October
15, 2014. The analysis was re4uested by the U.S. Environmental Protection Agency (EPA) by
letter dated August 26. 2014.
This comment letter was developed by the Department of Natural Resources, Hazardous Waste
Program and the Department's Solid Waste Management Program staff in coordination with tht!
Missouri Department of Health and Senior Services (MDHSS) and consultation with Mr. Todd
Thalhamt:r, P.E. The MlJllSS i;ornmcnts arc provided as an enclosure to this letter. Please
consider these comments as your agency. the United States Army Corp of Engineers (USACE),
and Lambt!rt Airport evaluate tht! options presented in the Isolation Barrier Alternatives Analysis
rt!port.
Hazardous W astc Program_ CO_!llJ!!.t;D.!~
Bird Mitigation Plans

The third sentence of tht: first paragraph of Section 1.0, Introduction, states, 'In the August 26.
2014 letter transmitting the lJSACF report (EPA, 2014a). the United States Environmental
Protection Agency (EPA) requested the Respondents to use the USACE report' ... as a basis to
further develop more detailed plans for the Isolation Barrier, specifically including bird
mitigation plans, for each of the proposed alignment alternatives." The document goes on to state
that a meeting was held on Septembt!r 18, 2014 between EPA and the Responsible Parties. The
EPA memorialized the meeting and refined the scope of work to he performed by an email dated
September 23. 2014 This email again rcqut.:stcd bird mitigation
...
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Ms. Lynn Slugantz

Page 'Jhrec
Additionally, the document docs m)t 4uantitatively assess the risks assm:iated with other
potential pathways identified by I :PA-ORD. MDHSS, and Mr. 1 odd Thalhamer. P.F. Thcrdore.
the conclusion that 'No Action .. is prohxtive of Human Health is not supported by the record
(sec Department letter dated April 24, 2014. Enclosure: f'v1emorandum from \1r. Todd
Thalhamer. P.E., dated April 14, 2014).
In "Section 3.6.2. Potential Impacts'" if"a SSE were to (kcur in Arca I, the first sentence of the
third paragraph states. 'Jkcausl the RII\1 \\;ould remain huried beneath other waste materials and
soil or inert fill. no changes in other exposun: patlnvays (di reel contact with or dermal exposure
lo the RIM or exposure to gamma radiation) arL~ expected to occur if a SSE were to migrate into
Arca l :' This statement appears im:onsistent with current site conditions. The Remedial
Investigation and other documcntsisite observation concludl: that radiologically-impacted
materials (RIM) occur at or very near the highly vegetated surfoct~ and are not buried by other
waste material, soil, or inert fill. \Ve suggest t:P;\ require lht: Rcspondt'nls to revise this
document and the ''SSE Impact !'.valuation' document. to include analysis of risk associat<:d \\ ith
conditions that could be created by an SSF or a surface fire.
RIM Relocation on Area 1
The discussions frir Options I anJ 3 (Sclliuns 4.7 and(, 7) describe relocation of RII'v1 onto :\rca
I. This contradicts the USACI. dornment v."hich states that RIM waste excavated as part of wall
installation will require off site JisposaL \Ve suggest !'.PA require the Respondents to re\ isc the
document to be consistent with l 1Sl\(T n:commendations.
Need for Further Charat.terization of W.IM
In '"Section 2.1. Isolation Harrier Alternatives'. tht: lirst sentence of the lasl paragraph states,
"The USACI'. report also considcn:d an additional alignrnl'nt (Alignment 2) that \\ould consist of
installation of an inert barrier located south of OI J- I Arca I tn ensure that all Rlrvt is located to
the north of the Isolation Barrier ... Full characterization of RIM is necessary to support this
consideration. The Department notes that the l !SA( 1: document states in Section I, Kt.:y Point
#1 as follows:
nu: full extent ulthe RI:\! has not heen determined,
sped/ically in the southwest portion of

OU I Area I. east <land amund the existing Tran.~/t:r Station Be.fore design work um he
rnmp/etedfur the IB. addilionul suh.rnrf(1ce invntigative work is 11eces.mry tu determine:: the
limits <~(the RIM as wi:ll as to collt!ct geotei:.lmical duta w!cc.\sary.fiJr the design of the llJ
The Department supports USACI: "s condusi1n1 with respect to the design of the Isolation
Barrier. Given slo\.\ly increasing temperatures in the neck. we further suggest l'.PA re4uire the
Respondt:!nts to immediately characterize Rl!\1 in the entire North Quarr). The Department's
SWMP is 1.:urrently requiring the installation ur needed additional temperature monitoring probes
f\h I yn11 ~lu!,'.ant;
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\1i:'suuf1'';i1. S fI'\ approvl..'d :'1<:.lk liir 1mpkmu1tatiu11 nfSuhtitk U ol'tht Resource

ai 1d I< ~;._:1 i\ i:t y :\ll {RC I\!\ i l lmkr 42 LS .C 6 11\11-(,1)911( and 411 CTR Parts ? S7
and :?SR rcquirL'llli.:llh. \1is-;11uri l1as autlwrity Ill pcnnit Lhc dc-~ign and operati1m of nw111cipal
~;nlid \\:JSk d1-;p1i..:;1l <.irc<i:.. :\ll a'PL'lh i>ILhc d-:sign. nperatiun. closure and 1111.;;t lloi.;urc of 1hc~l'.
l~l\ iliti<:' hi! tlflLkr 1l1v <t111h111i1.' ;i!llk '-"il1d \Vaslc !lv1dnage11wn1 Pl:rn
t\)11s1.:r\atirni
\\ L' '' 1..rt urn1hk t ;Nert.. in that Ull' alkniai1\..:s l'1H1sidl'ri:d i:1>1nply wllh ull ApplKahlc or
l<dn ant ;ind ;\pprnprimc RL'yu1r1.:.~rnL111-. (\RA!{...;) SpcciliLally. umh:r ;1 ('LR< 'I .A Removal
\ct1un. dfl) '.liiging. rnanagtrnl'lll ilml rdoLati1111 nf excavated \\'astl's on lhl' \\e-.;t I .akc L<mdlill
~upert'und ill'. rnust L11mpl_\ \\i1h ,1JI ,\IC\I\-.; including T\lissouri Solid \\';t,;li..: ~1ariagerm.:n1
1cgula11<>11:: <llld -;ilH1J2 rtyuirl'n1c11t-
I IL Lid ;>I dcli11iliPn hr tht'. l\"Lh .. a.~,c~~m..:111 factur.-; rnak1.: it ditfo.ult t ddcrmim wlH.:lhl'r
ing c \,\1\ <tl li>n ;iJH:I !1h)Vt:1ncnt of" decomposing n 1unicipal ':\\)I id \.\;.isle \\ Cll'
ad2(ju;1tvl:. ,p11-.:i,h:rul rn rhv l-.1>i<ttiPn H.trrict Al1crna1ivt:'< Anal~s1s prun:.~s Ass<JL'iakd follnr...;
\\liid1 ~h,11tld b,: ldkL11 iniil c1iri:-;1d;.rat1<>11 ,\'i p::iri (lf (hi' t:\itluaft1m arl' dt"l'lhsl'd throughout th<:
! 1 ii ki 1.\ l ll ~ U if Tl 1111: Jl I;
i'.. uc, !fl llldru~
1.0 lntro<lm'tion
d thL a11alysi1 d1h;.:'- [111! l'!'ll'idct the charackrisLils or the [!fl'\ inus sud:t(;(' and
,ub;.;urf...tl'1.'. l!r1:'., lh:1t ,,i..,.urred in rllL ~J11nh ()twrn \\ ith ll'lllpcraturcs 1hat rLache.:I 800'' F.
( '1 in ... idcrtn ,,n]y icr11pl'!aturc:.:. 11; a rrn1g..: '-i1rnl:.ir lo thusc tiiund 111 lhc '-;ourh ()uarry suhsurfol c
'-lJ11ildc1 ing tire ,,f appr)\ im;ilL'ly :;1 HJ' !'. l' !Wl :-.ull1cit:nl f1Jr ~tna]ysh 1d is1dat1011 barrier
<1lli..:rn:tli\c...; i S(c .. , <lSk ~ .:\sscs~;rnent ill' l<l'.'.'Uil'i 1 Renmnm.:ndatiuric, r()l hiturc Action
'-;uh;url<Ki.'
i'1.i111huqi,,11 ;jt I aidlaw fhid!.!dnn
Landfill'' :-.ubmitteJ h ... Sl S l;ng_ineeri.;
for I .aidlaw
.
.
.....
"""
I hidgdn11 l and ti I! lh(; <hscssrrH.:nt report h a\ ai lab le on the I kpartmen: ... \\Thsitc at
iillj'. t!Ji: r:_;,,' -~'.'" t'll' ~\1111pj~i_uliti1. . !.> cilid.,i..;_..;_] lFi:2.J l)11-l p,!(_ pp ] J L'L J ]h of lhe rc.:purt l
I he IJb1t:L [l\1'
I urllilnnin.:. du,: L 1rK1nnpktc ~lr<1rc1l'l('l'i1ati;J11 td rad1ol1gically-1rnpaded 111atnial in the N;irth

1_111arr). thn;~
:1ddrc.:;"
i" ti.:ighttned l'tlJKCrn \-1.ith allt\\1l1g any Ul111bustin11!ti1iu:ur m th:it art:a. I u

S\\'\;1P "n < ld.,k:r 7 ~!()14 j..;-;ucd <t lctLlr 111 H:idl,!don l.andfilL I I ,I.
thi~ (irttTrn. tilt:
Ms. Lynn Slugantz

Page Five
requiring submission of a rnrrec:tive action assessment and plan that identified a corrective action
zone encompassing the northern neck and the southern portion of the North Quarry. Bridgeton
Sanitary Landfill must be positioned to immediately implement additional measures to contain
the existing subsurface fire to the South Quarry area and to extinguish any independent fire or
reaction that might occur in the North Quarry.
In summary. consideration needs
lO
be given to:
The pott:ntial for \\astc materials in the North Quarry tn combust at a significantly higher
temperature than waste makrials found in the South ()uarry.
Adequately characterizing waste materials and determining the extent of the
radiologically- impacted material that might be affected by a smoldering fire originating,
in the Nonh Quarry ur moving into the North Quarry from the South Quarry.
If combustion were to occur in tht' North Qm1rry. an understanding of the types of
emissions that would be expected from the waste materials is needed, including any
radiologically-impacted material.
Potential impacts of an additional smoldering fire on the grout or slurry ust:d to
extinguish the I 992-1994 subsurface/surface fire through uxygen deprivation. It is
unknown how the injcch:d material will behave as it drie~ and pokntially crumbles
allowing oxygen to infiltrnle the waste mass, i.e. oxygenating the suhsurfacc fire.
3.0 No Action AlternatiH
As noted above in Section I .0. it is imperative that Bridgdun Sanitary Landfill have readily
implementable methods for addressing any northward progrt:ssion of the subsurface fire into the
North Quarry. The SWMP's Cktohcr 7, 2014 lctter to Bridg<.:ton Landfill. LLC required
submission of a corrective action assessment and a corrcctivt: action plan. The identified
corrective action zone encompasses the northt'rn neck and the southern portion of the North
Quarry. Bridgeton Landlill ha' submitted a corrective action plan and the SWMP is currently
reviewing that material for response.
1he No Action Alternative docs mit appl.ar to fully consid1..r the following:
The slowly upward trending temperature data reportt'd by Bridgeton Sanitary Landfill in
the Neck Area temperature monitoring prohes is an indicator that the \\aste mass is
slowly heating and drying out, which ncates an unacceptable risk of combustion if there
is movement of the South Quarry subsurface fire or development of a sepmak event in
the neck.
The presence of some radiologically-impacted makrial in the North Quarry (full extent
unknown at this time) and the potential for that material lo be al1i:<.:ted by an independent
smoldering fire occurring in the North Quarry given the existence of such an event
currently in the South Quarry and prc,iously in the '\Jonh Quarry.
:vL I
:111;
'-:l11g<11J11
I\I)!\' S1,
I hh .1pl1in ;1pjH.:~H.'-' t<. pl<tu: -l>lbid1.T<1bk 1.,t:ighl un th\.: unprmcn lkai J:;..trnction Pil1it
StuJ). Whik th1.: S\V\11' '-'ii\\ no technii.::<11 reason for denial oltht: pilot study, we lu1\t.'
: l'I t" he pro\ ided ~111y data tn suppo1i that this arnhienl air cooler system, on its own,
n:nH\cs sulficirnt he<\! ti h:1lt prngression t)f a smoldering fire
;~ u i imc frames wtrL: gi., en J;;r the pm vis ion of the heat trnnslt'r 111odcl ing and additional
k:inrnistrali<1rh and nalu<llHti:-- oi-1:11..tms controlling migration uf the suhsurface tire inhi
th t'>J,1rtl1 ' . ,,Jiwtr): 1hndi>1,' it i-; ul1i:kar whdhcr this mfnrnwtion will h\.' time!\ flJ')\ 1Jcd
I\! lh' chirin~ !he dn.i:;;j,.r: IJUXill!,;' f'ftH.l'SS !~Jr th<: i..;0Jat10n harrtl~I
I I;, lkpar!mcnl , rnr1lrdU1.\l lm1dlill lir1.. c\pcrl. Mr l 11Jd J hafh;1111t:r, I' J pr11\ 1dnl rn :i
I d"rLury 1_i ,'Ii 1-l l 1Hn11wn1 kncr n discussion nf riskS ;issociatt:d \vilh the sub:-.urtacc 1111.:
c11rn111~; inH; i'll1!a11 ,vi1h r:1d11ilngically impatkd makrial in the Nurth ()uarry Sucl1
ri~ k ~ 111clr1tkd the ptlll~lltial l(r srnol-.e mid dust generation from \h( interaction (lf till
sub;urfacr: !]fl' and \\ihlt.' nnkrt;\I V.!'as consideration givc11 lu !\1r lhalhamcr's
t.'< >l!lll IL'11(:-,"
lri 1 ri:n:11t r'l:pun lhi: l 'S . \< 1 sU.rks that dt1L' to dcs1g11 LnnsiJi:n11ions. c11nslrudio11 ol ;111
i-.1d:1tiPn haniu l" <ll kn< l 8 11111nth: fr11n1 beginning
\.\ hik that "chcduk is \ktaikd
;.;fq fi:, 'ill'p, th( 1rn1q1K :11h:11: ;v11.inl;! 11fthc \\'t:sl I ake { ompk' where th11usanJ'.; ,if
F"lpk live ;mcl wrk niu,1 h: tThiJcn:d in i::valuat111g 1snlatin11 harrier altern<itl\c" and
di vll11rtc; li1r t'.pedited 1111wlit1l''-'' in imp!i:mcntati.rn should he c1pplkd
1
-1.0 Option -Inert Harrier Al11ng Alignment I and

h.O Option 1 lnHI Bi1rricr Along .\Jignmt~nt :\
I lll\ i1~ !fK c'.J11t111t!'-nr.._\ pLmnint" procc.. ..,. tlk Dcrart11w111 rvcu1nn1c11Lkd c\\nstrndion Pl
,, i"1r, hn~ah. >llf1ilM 11, th:: pnipos,ds hc:\\\1cn tht: nerh. arc<1 and the Nnnh <.iu<trr;. \I
lh,11 lltn\. Hnd<:t1'11 I 1111.itlil <1nd tllL'lr uJn!rttdor-; indic<itcd that such a fin:: break \\1Jt1lJ
rir1\c 111;:fk1_:1i\l' and \(111ri L1!1du::1!1 mi1vvrnen1 and dl,sici..'.ati<>11 Pl the rli11l\1rccd
'"'icrct( IL.1, :nldit111;il inln11ati.111hcen11r1nidcd by Bridf'.ch111 Landfill tn ,iddn:''
!l i'..'.':\.' '-' >l\l. l"rf 1., '
I! tliv \11rtl !):.u11\ ,, 111;p.1t k',I h\ tl1l' :it1h~url:1i:1.. tirr. h(l\\ dl"' lI'.\ plan tu Lvaludk
rh1 tft\:c1i\t'llL''.~ iii tlh: l"l1f1n1.:cr1rw l'nrrul ( r.c. FVl >I I Cap. <1-; cxrraction a11d .:ontwl
-. ;1l1111 :-.h11ulJ radi(ilugici!!:, 1111f:<lLlcd 1natl'r1aJ-, wrLtcc a' the \\Jslt' mas" i'i rn.lultd"
lLJ",. i"c<t:;ihili1y t -..:du;11111n, h:L11 uinductcd with rt:"JXLI 11111111 :--:pnl rt1111\<1! nf ;rn:.
r.id11il,,~i1 ;tilv illl11ac1vd ltk1kruls i11 lh( i\orth ()uan) ._,
i iH h1.:;11 L'\Lh;u1gv t11bt. h.111~ 11n..,idcrtd l"r pLKl'IH<..:111 rn the n:illhl'(ed Li>lltrck d<) 111il
dJ'i''::11 l.1, h.: ;i pr1i\1 fl t-dtr11!,1~'\
\r1 lht:rl' rr<lCliutl t~\tHltrks ol..:.uch !JL'dl cxcha!l~lt
111k, hcinl;'. u-;.:J 111 "1mii:,11 .1pplirnlH1r1.'
! 1l':n ll1t: lii;;1i1ri . . 'uh:.;uri'a-.;, iir(:-- in the l\<>rth \)U<tll). \\;is cnnsider11\iPn i,!.l\Lfl l, u:;111;.:
chillm~ 111 t,'ritml l1-.:u1nk: 1,.,,:hrn1!.1gi.::~ rdthcr than adi;,ihatic Jir Ul"kr..:. ,,, t"JJSUJ\; U1c'
;ill:;\ dl"lllld t!J1~ i(\l)k\f\<'t\ c<;Jil'.l'l'.\l" htJfit:r is ffillil1hlint:d dl (.\ fl"!llr('.f<Jllln: lt< knglhC!l lltL
Ms. Lynn Slugant1

Page Seven
life of the non-combustible ele1mnt'? While mention is made to clectrirnl continuity

cables being installed at approximately 20 foot centers. the ahility of the cooling elements
to move and remain operable as shifting and/or deformation of the non-rnmbustible
clement of the structure occurs from waste reduction settlement is not dear and needs to
be further assessed.
It is unclear why only on-site relocation of cxhumed \\aste was considered. The sole
safety factor expn:ssed appears to be limiting the number of truLks leaving the facility.
Was direct load and hauling of \\astc materials considered in these alternatives? This
approach would limit odor generation as it relates to being a public nuisance, as well as
avoiding undo bird attrac.:tion. Direct load and !muling would also greatly reduce the
potential for a combustion event in any on-sik areas or the n:lncatcd waste.
It is also unclear whether considt:ralion \'>-'as givl.'.n to limiting the size of the working face.
This is routinely done in construction projects involving exposure ol' decomposing
municipal wastes Soil, foaming and other produc.:ts can be applied to exposed wastes to
assist in managing odors from excavation activities and reduces the area of expost:d
waste materials that might ad as a bird attractant.
Given the existence or RIM in the northern portitin of the North <.)uarry. evaluation of isolaiion
barrier alignments in the southern-most portion of the North Quarry, or other engineering rnntrol
options, need to he included in the analysis.
5.0 Option 2 - Air Gap Barritr
This option was not evaluated and comments are nut prm ided
7.0 Option 4 - Heat Extraction Burier
Consideration with respect lo the heat extraction barrier option should include the following:
As noted in the alternati \es ahon. the Heat Exiraction Pilot Study is a study of an as-yet
unproven. nev. lechnolog).
The potential for'' aste mah.:rials in the North Quarry to combust at a signi ticantly higher
temperature than waste materials founJ in the South Quarry does not appear to have bei:n
considered. What temrK~ratures will the heat cxtraction t cooling) points he ahle to
withstand? Can the heat extraction (cooling) points be constructed to connect to a chiller
or freezing unit rather than an adiabatic air rnoler'?
Potential impacts to the l.VUI I capping material and landlill gas \\elltield and piping
should combustion occur at higher temperatures than in the South Quarry.
It is unclear if considerati( m was given to the potential for displacement of waste material
and slope movements which could allow shifting of radiologically-impacted material in
the North Quarry as the waste ma~s is reduced.
i\ h
I.
l'at:
y1111
..;1ug;inL'
ti~hi
V<mahil1ty in tlh: rdlc ul mtivoncnt 11fthe :-;ubsurl~tLt lire has lwcn u c1in1inuing issue.
I Ii,'. rn; \Tlll1.:11t rate LJ.ssunwd m the analysis appcMs tu the curn:nl South Quarry
nit-'''' urernt11h rathcr than rntt\ 1!ll u111 r<1tes pnviously seen in the South ()uarry. ;\11 y
cllliily;j..; dv-..:igncd \(l addrC.iS fl Nurth ()uarry fire musi tonsider that the rnll" of movcrncnl
L,11tld k ;i! ka<.,t <L' high <1' the fosksl rate previous)) cakulatecl fnr till'. South ()uarry
!1rt'l ll Iii' nll\1'.llli.'1111.'rlb f::l',C :,l'f thal rdk at] 8 \() \ 0 !1.TI per J<l_\
I h:mk y1)u l()r gi1ing u.: the 11pp(JfluJiit; t11 n::\iC\\ and comment un this document. If you
qlleSllPlh pntaininr t\1 this letter. pkil"l vnnt;KI rm. with thl Department or Natural
h<l\t
:in:
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\Ir .l1natha11 (i<11,,utk lkp.1rtrnc11i ol llcalth ;111d S;.:11im Ser\'iC1:,";
\1: f';ittl R('''"~'' ln1,:'ir11..:1.:r1nh' !\h1t1<1!,:1;'1llcnt Supp11rt In
\! . . f?lin11cb 1lamm \liebru:..-gc l an1hat-S1 Loui.., lnkrnt1tit1ndl .'\irp1rt
\J1 ' l1ri,. \;;1;.:<I. I )if1.:<.:li">1. ')i1lid \I. :1-;11 l\lanagerncnt l'r11!:!.ran1
Cel&/Jrc1ting 40 years ot iakmg r;are of M1ssouo s natural resources

r,, !11arri rwrp a/10ut tt11:i Miss 1 ;un Department of Natural Resouf(;es \'isil dnr mo qov
..... .-;,..-.: .
.~
Missouri Department of Health and Senior Services

P.O Box 570. Jef'lerso~ City MO 65102 0?70
Phone 573-75H>4'.l0
FA>< 573-751-6010
RELAY~.!.SO~Bl!<Jrt:t~aing i1f1d_~~ec~ l_r_ry~iredJ-800_7-~5-2\J?? .. V01~E. 1-800-735'.~~-f!. ....
'
Jeremiah W. (Jay) Nixon
Gail Vasterling
Govern0r
Diredor
November 21. 2014
Shawn Muenks. Program Manager

Federal Facilities Section. RRA Urnt
Ha7.ardous Waste Program
Missouri Department of Natural I<csourcc.?s
P.O. Box 176
Jefferson City. MO. 65102-0176
Re: The Missouri Department of Health anJ Senior Servi<:cs' comments on the document /.rnli1tim1
/farrier A lterm1tiies Ana~rs is. West /,akc! Lmu(fill S11perfund Site; ( ktoher IO. 2014.
Dear Mr. Muenks:
The Missouri Department of Health and Senior Sen ice-. I DHSS) ha-. re\. iewc.?d the referenced drn.:ument
and provides the following comments
I. Attachment A: Radon Flu\ Analysis for Isolation Hamer J\hemativts Analysis
Attachment A. providing for radon tlux cstimatc.?s m the event a subsurface smolJenng ewnt
(SSE) occurs, utilizes formula or model inputs that are 1.1utdat<:d. The soliware package
RAECOM. provided hy World Information Senirc on Energy (WISE). is used in this do1:ument
to estimate radon flux in tho:: cHnt of an SSL
The U.S. Nuclear Rcgulatpry Commission. Offo.:e of Nudcar Regulatory Research provide., the
regulatory guide Calwlation of Radon Flux Attenuation h~ Eorthen Uranium Md/ Tailings
Cow.n, June 1989. This guidance appears to be the foundation for RAECOM. The
International Atomic Encr!!-Y Agency (!ALA) published Technical Rcrxirts Scric.?s numhcr 474.
Measurement and Calculation 11.f Radon Releases (rom NOR Af Residues. 2013. This dl1cument
provides updates on modeling rndo11 emanation and t:xhalation fwm milling rc-.idtH.:s.
DHSS recommends thai RA LCOM calculation and modeling assumptions be appraised against
the !ALA update:;, to dctcnninc if RALC< >\1 is sufticicntly protective of human health. In
support of thl' updated RAEC'OM results. Argonm National Lahliratorys RFSRAD Offsnc
software should be used a<. an additional line of e\.idencc to confirm the findings of the
RAECOM modt:ling. Tht more stringent of the findings sh<)u\d be used for decision making.
Regardless of the model u'-ed. all !ll(ldel<. pose some level of uncer1ainty. Due to thi~
uncertainty. in the event an SSE C1ccurs in the radiologil:ally-impacted material I RIMJ. DHSS
!1!!!!!-h!!l!!untu19y
rhe M,ssoun
Oepa~nt
Healthy Missourians tor Ille

o! rlea,th 11ra Senior Services will be the 1eaaer ,,promoting nrotec11ng and partne'<ng for neal!l-
A:-1 EQUAL QPPQRTJNITY, Aff;RMA fl'/E ACT'ON EMPLOYER: Servces pnvded c.n a ncneloscr1ritnatorf baS$
\111,1:k' Si1;;1\ ,
P<lg.' : uf)
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f('(irnmcnd- 1/iat 1:'1wirun;11i:n1al sampk:; hr..: ,.'.i)lkcled lp dl'LLrn11m: 1f kv1:b of radon :.md ils
PfO)!('I>;. r'Sl' un:.l\.:ccptahk rv;k il \\urkcrs and tht' pub';\\,'
-,
i't1t i.ll!lli'C
JJcntiflt:S ;1 rad11fi j~ll\ file:..' Of 0.29 fllC(l1,'.llrit:S pi:r nlt'k'I '-4ll<lfl'd ptr SCi:t\nU
-~
!{( 'ri" .~iii., tht: ''Rt)l) Fl'lltl~dy \\llh SSf'' fhiv.c't'J th<: do1.:un11:n1JpLc;1111\ provide
";i\u:!dt i. 'fl' id ~uppu"1 the <.l'.--'-u111pt ll '"" Ill ISS r~'.C1Hn11wnd.;, fl' vi l'\\ mg comment I ab, 1\ e,
updat111g R;\ f:(()\1 as 11:,un1111~ndt:d, and prl'scnling till'. ,1dditional line of('\ idenct' using
RI:;..; k \Ii (!t i-.11~
1lk'':
rL'stdts
;;Jiould IK
l~L'Si<111(('S ~wd.11; l)fl\\ p1i;1r t1 li11,tl11ing
r\:\ iew~d
i\~<im.
hy the M issuun Ucpanmcni of Na1 urn J

ll!ISS n.t1)fltrl1l11ds u1lkd1on of
i.'P" 11 i'Jlllh.'.nLti :;;unpl:~; I\' ddt'fllllrl( 1f the (11t1..omL' J:'
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Attachment 8 - MDNR Comments on

Estimated Volumes for Partial Excavation
Options Identified by EPA dated October
31st, 2014
Jeremiah W. Qay) NIXOn, Governor
Sara Parker Paulef,'Ditcctor
T OF NATURAL RESOURCES
www.dnr.mo.gov
Mr. Paul Rosasco, P.E.

Engineering Management Support, Inc.
7220 West Jefferson Avenue, Suite 406
Lakewood, CO 80235
RE:
~~t
Comments on Estimated Volumes for Partial Excavation Options Identified by EPA,

West Late Landfill Operable Uqit-1, dated October 31, ~O 14
Dear Mr. Rosasoo:

The Missouri Department of Natural Resources has completed its review of the document titled
"Estimated Volumes for Partial Excavation Options Identified by EPA" prepared by Engineering
Management Support Inc. (EMSI). This document was requested by the Environmental
Protection Agency (EPA) to use in development of the Partial Excavation Alternative analysis as
part ofanaddendum to the Supplemental Feasibility Study (SFS). The Department offers the
following comments on this document:
Volume Calculations
Please include calculations for the volume of assumed principal threat waste that may be
removed under each of the partial excavation scenarios in order to provide such information to
EPA for consideration in selecting the appropriate scenario to include in the Partial Excavation
Alternative analysis.
EPA requested by letter dated October 12, 2012 that the Partial Excavation Alternative analysis
be conducted "at a level of detail comparable to the alternatives alreadyarialy:Zed 'in the SFS."
The SFS states in Section 2.2.8, page 22, "Because the purpose of the SFS is to provide a
thorough evaluation of the potential 'complete rad removal' alternatives relative to the RODselected remedy, it is conservatively assumed that principal threat wastes may be present within
OU-I." The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) states
that EPA expectsto use "treatment to address the principal threats posed by a site, wherever
practicable." The SFS goes on to state in Section 6.1.4, page 142, "The NCP prefers remedial
actions in which treatment is used to reduce the principal threats at a site through destruction of
toxic contaminants, irreversible reduction in contaminant mobility, or reduction of total volume
of contaminated media." These NCP expectations are presented in EPA' s guidance titled, "A
Guide to Principal Threat and Low Level Threat Wastes," November 1991.
Therefore, for each of the scenarios presented in this document (i.e. 79 pCi/g, 1,000 pCi/g, and
16-foot scenario); please include calculations for the volume of assumed principal threat waste
that may be removed.. Also please include discussion on how each scenario will result in
reduction in contaminant mobility (i.e. placement of partial excavation materials in a properly
,engine~ed ~sposal cell). The information on reduction of volume and nfobility. of principal
-threat waste~'UD.der each scenario should be.provided to EPA for consideration inselecting the
.-appropriate scei;mrio-to include in the Partial Excavation Alternative analysis per the NCP
~tations. The Partial Excavation-Alternative analysis will then be included in the addendum
_-~t'o the SFS in orderto perform remedial alternative analysis and ultimately, selection ofa final
-. remedy
o 11 c.f
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Superfund
vu o I
Mr. Paul Rosasco, P.E.

---- - Page2
Janiliify29~201s
=section 4. Uncertainties _
_
_ The-Department does not understand the.purpose of Section 4-within this document-and sugge.sts
it be removed; The s~nd sentence of:Section 4 states, "The 'back ofthe-envelope' eStiII111~
volumes for the. three p~al: ~x_cavation scenarios were not develop~d to the-s$le-fovel of d~tail
as was attained for the 'c9mplete_rad removal' .alternatives presented in the SFS." However, ~e
document.states in Section.2J, pag~3, "Intervals containing or suspected to oohtain radionuclide
activities 'above the 79 pCi/g I 60,000 cpm criteria were then plotted in three dimensions and
located within the overall waste mass using the same methodology as was employed to estimate
the volume of solid waste materials to be removed under the 'complete rad removal' alternative
of the SFS." A similar statement exists in Section 2.2 for the 1000 pCi/g I 500,000 cpm scenario.
This directly contradicts the uncertainty argument. Therefore, we suggest removing' Section 4
from the document.
'!-
-In ~dition,.reference _to. ~II place~~-~der the M~terials ~gement .Plan (MMP) should~!)t be
considered m the feas1b1hty of a partial excavation alternative as the mtent of the:MMP was to
"not prejudge the selected remedy or preclude any of the potential remedial alternatives" and
have "no effect on the implementability of any of the potential remedial actions". This section
appears to be an attempt to include arbitrary argument in order to prejudge the partial excavation
alternative which was not requested by EPA. Again, we suggest removing this section and all
references to it from the document.
Thank you for giving us the opportunity to review and comment on this document. If you have
any questions pertaining to this letter, please contact me by phone at (573)151-3107; by written
correspondence to my attention at the Missouri Department of Natural Resources, P.O. Box 176,
Jefferson City,MO 65102; or email to shawn.muenks@dnr.mo.gov.
Sincerely,
HAZARDOUS WASTE PROGRAM
~~
Shawn Muenks, P.E.
FederalFacilities Section
SM:db
c:
Mr. Brad Vann, U.S. Environmental Protection Agency
Mr. Chris Nagel, Director, Solid Waste Management Program
STATE OF MISSOURI
DEPARTMENT OF NATURAL RESOURCES
PO BOX 176
JEFFERSON CITY MO 65102-0176
Q~~->Pos,..~
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Mr. Brad Vann

US EPA Region 7
11201 Renner Blvd.
; tu21;:&, KS 66219
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Evaluation of The Epa Selected Remedy For Operable Unit-1 (Ou-1) - Appendix

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Evaluation of The Epa Selected Remedy For Operable Unit-1 (Ou-1) - Appendix

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Senior Scholar

Institute for Policy Studies

Director, Field Operations

Attachment 1 - EPA ORD ETSC

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

March 28, 2014

Attachment 2 - National Remedy Review

Draft Deliberative Process Privileged Do not cite or quote

Final Draft February 28, 2013

Draft Deliberative Process Privileged Do not cite or quote

Final Draft February 28, 2013

Draft Deliberative Process Privileged Do not cite or quote

Final Draft February 28, 2013

Draft Deliberative Process Privileged Do not cite or quote

Final Draft February 28, 2013

Draft Deliberative Process Privileged Do not cite or quote

Final Draft February 28, 2013

Draft Deliberative Process Privileged Do not cite or quote

Final Draft February 28, 2013

Draft Deliberative Process Privileged Do not cite or quote

Final Draft February 28, 2013

Draft Deliberative Process Privileged Do not cite or quote

Final Draft February 28, 2013

Draft Deliberative Process Privileged Do not cite or quote

Final Draft February 28, 2013

Attachment 3 - Comments from NRRB

West Lake Landfill

Fate and Transport Modeling

Attachment 4 - Internal E-Mail from NRRB

Fw: West Lake Landfill

Cc: Audrey Asher, DeAndre Singletary

Craig W. Smith, P.E.

Attachment 5 - Comments from NRRB

I Page 2: [1] Commented

I Page 3: [2] Commented

Attachment 6 - Internal Comments by

Scope of Work and Schedule

Commented [caol]: Not sure what this letter Is hosed on as far

leachate within the subsurface.

Commented [cao2]: Board's dnift recommendations prepared

Commented [cao3]: In several places, language appears

Feasibility Study {SFS) (EMSI, 2011) for OU-1.

generally found at depths ninging between 0 to approximately 6 feet

Commenl8d [cao4]: In llaht of Board's 2012 review (plus

SOW - Fate & Transport Modeli ng

A Rew la Refill eever ever tile e1cistiRg si;rfaee ef Areas 1 aRa 2;

CeRseliaatieR ef raaielegieally eeRtaFRiRatea si;rfaee sail freFR tile Bi;ffer ZeRe/Cressreaa

Commented [caoS]: Board has said In Its memos that

Preperty ta tile eeRtaiRFReRt area;

Commented [cao7]: This makes It sound like they have been

FRill tailiAg sites aRa saAitary laAafills;

IRstiti;tieRal eeAtrels; aRa

LeRg terFR ~i;rveillaAet:{aRa FRaiRteRaRee ef tile reFReay.

SOW - Fate & Transport Modeling

from spring of 2012 questioned use of state's subtitle 0 regs--

Commented (cao13]: See comment 4

Commented [cao15]: The Board's draft recommendations

Commented [cao12]: The Board's draft recommendations

by Itself Is not 1 remedy, so not dear what performance standards

address air do they?

1 relevant to eround water SOW -J1 I

boundary and at off-site locations; and

Commented [cao10]: How Is this relevant to this SOW for