PB98-964306
EPA 541-R98-169
March 1999
EPA Superfund
Record of Decision:
St. Louis Airport/HHS/
Futura Coatings Co.
St. Louis County, MO
8/27/1998
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FINAL
RECORD OF DECISION FOR THE
ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI
JULY 1998
U.S. Army Corps of Engineers
St. Louis District Office
Formerly Utilized Sites Remedial Action Program
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FINAL
RECORD OF DECISION FOR THE
ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI
JULY 1998
prepared by
U.S. Army Corps of Engineers. St. Louis District Office. Formerly Utilized Sites Remedial Action Program
with technical assistance from
Science Applications International Corporation ESC-FUSRAP
under Contract No. DACA62-94-D-0029
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I. DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
St. Louis Downtown Site Accessible Soil/Ground Water Operable Unit
St. Louis Site
St. Louis, Missouri
Statement of Basis and Purpose
This document presents the selected remedial action for the cleanup of wastes related to
Manhattan Engineering District/Atomic Energy Commission (MED/AEC) operations in accessible
soils and ground water at the St. Louis Downtown Site (SLDS). Accessible soils are soils that are
not beneath buildings or other permanent structures. The SLDS is one of a set of properties
collectively referred to as the St. Louis site in St. Louis City and County, Missouri. The U.S.
Environmental Protection Agency (EPA) has listed portions of the St. Louis site on the National
Priorities List (NPL), but the SLDS is not included. The SLDS consists of property owned by
Mallinckrodt, Inc. (Mallinckrodt Property), and vicinity properties (VPs). VPs are categorized as
perimeter VPs, which are adjacent to the Mallinckrodt Property, as well as the utilities, roads, and
railroads, which are located within the Mallinckrodt Property boundaries.
The selected alternative was developed in accordance with the Comprehensive
Environmental, Response, Compensation, and Liabilities Act (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act (SARA) and, to the extent practicable, the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on
information available in the Administrative Record for the site.
This Record of Decision (ROD) is published by the U.S. Army Corps of Engineers (US ACE)
in consultation with the EPA. The Missouri Department of Natural Resources (MDNR) concurs in
the selected remedy.
Assessment of the Site
Actual or threatened exposure to MED/AEC-related hazardous substances (primarily
radioactivity) at the SLDS, if not addressed by implementing the response action selected in this
ROD, may present a current or potential threat to public health, welfare, or the environment.
Description of the Selected Remedy
The selected remedy for this Operable Unit (OU). i.e.. Alternative 6 of the Feasibility Study.
Selective Excavation and Disposal, is the final remedial action for accessible soils at and ground
water beneath the SLDS for MED/AEC-related hazardous substances. Portions of properties were
previously cleaned under removal action authorities. Plant 10 (City Block 1201) was cleaned to
composite criteria (ARAR based). The Mississippi River levee area was cleaned to risk-based levels
rUS208l"07239X HI
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based upon recreational use. These cleaned areas do not present risks outside the acceptable risk
range and no further remediation is required.
The mai ff components of the selected remedial action include:
• Excavation and off-site disposal of approximately 65.000 cubic meters (85,000 cubic
yards) (in-situ) contaminated soil, and
• No remedial action is required for ground water beneath the site. Perimeter monitoring
of the ground water in the Mississippi River alluvial aquifer, designated as the
hydrostratigraphic B Unit, will be performed and the need for ground water remediation
will be evaluated as part of the periodic reviews performed for the site.
Statutory Determinations
The selected remedy is protective of human health and the environment, complies with
requirements that are legally applicable or relevant and appropriate to the remedial action, and is
cost-effective. The selected remedy uses permanent solutions to the maximum extent practicable.
Because no "principal threats" were identified for this Operable Unit and because the toxicity of
radionuclides cannot be reduced through treatment, this operable unit's remedial action does not
satisfy the statutory preference for treatment as a principal element. However, treatment is a
conditional part of this remedy. Treatment technologies demonstrated to be cost-effective, may be
added as an adjunct to excavation.
Because the selected remedy will reatilfm) hazardous substances remaining onsite, a review
will be made of the adequacy o/tfie sejctedBflnedial action no less often than every five years as
required'Byjicc'tion
ut
Russell L: Fuhrmarf ' Dare
Major General, USA
Director of Civil Works
/! -
/v L'-C
_ _
Dennis Grams, P.E. //Date
Regional Administrator
U.S. Environmental Protection Agency
FL'S208P/072398
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TABLE OF CONTENTS
I. DECLARATION FOR THE RECORD OF DECISION iii
LIST OF FIGURES vii
LIST OF TABLES vii
LIST OF ACRONYMS i.x
II. DECISION SUMMARY 1
1. SITE NAME, LOCATION, AND DESCRIPTION 1
1.1 PHYSICAL SITE LOCATION 1
1.2 ENVIRONMENTAL SETTING 1
1.2.1 Land-use and Demography 1
1.2.2 Topography.. Drainage, and Surface Water 5
1.2.3 Geology/Soils 6
1.2.4 Hydrogeology/Ground Water 6
1.2.5 Ecology 8
1.2.6 Archaeological and Historical Sites -10
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES II
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION 15
4. SCOPE AND ROLE OF OPERABLE UNIT 17
5. SUMMARY OF SITE CHARACTERISTICS 19
6. SUMMARY OF SITE RISKS 31
6.1 CONTAMINANTS OF CONCERN 32
6.2 BASELINE RISK 33
6.3 ECOLOGICAL RISK 35
7. DESCRIPTION OF ALTERNATIVES 37
7.1 REMEDIAL ACTION OBJECTIVES 37
7.2 GENERAL RESPONSE ACTIONS 38
7.3 REMEDIAL ACTION ALTERNATIVES 3<>
7.3.1 Alternative 1 - No Action 40
7.3.2 Alternative 2 - Institutional Controls and Site Maintenance 40
7.3.3 Alternative 3 - Consolidation and Capping 41
7.3.4 Alternative 4 - Partial Excavation and Disposal 42
7.3.5 Alternative 5 - Complete Excavation and Disposal 42
ri.l.S:08l>.'072398
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TABLE OF CONTENTS (continued)
7.3.6 Alternative 6 - Selective Excavation and Disposal 42
7.3:7 Derivation of Remediation Criteria 43
8. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 51
8.1 THRESHOLD CRITERIA 51
8.2 PRIMARY BALANCING CRITERIA 59
8.3 MODIFYING CRITERIA 62
9. THE SELECTED REMEDY 65
10. STATUTORY DETERMINATIONS 73
10.1 PROTECTION OF HUMAN HEALTH AND ENVIRONMENT 73
10.2 ATTAINMENT OF ARARS 73
10.3 COST EFFECTIVENESS 82
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES OR RESOURCE RECOVERY
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE 82
11. EXPLANATION OF SIGNIFICANT CHANGES 83
12. RESPONSIVENESS SUMMARY 85
13. REFERENCES 87
FUS208P/072398 ' VI
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LIST OF FIGURES
1-1 Schematic Representation of the St. Louis Site 2
1-2 Locations of FUSRAP Properties in the St. Louis, Missouri Area 3
1-3 Plan View of the St. Louis Downtown Site 4
1-4 Generalized Stratigraphic Column for the SLDS 7
1-5 Hydrostratigraphic Units of the SLDS area 9
5-1 Extent of Ra-226 Contamination at SLDS 20
5-2 Extent of Th-230 Contamination at SLDS 21
5-3 Extent of U-238 Contamination at SLDS 22
5-4 Vertical Extent of Contamination at SLDS (East-West Cross Section through
Plants 7 and 2) 23
5-5 Vertical extent of contamination at SLDS North-South Cross Section through Plant 6 . 24
5-6 Vertical Extent of Contamination at SLDS (North-South Cross Section 2 through
Plants 6 and 7 26
5-7 Distribution of Metal COCs at SLDS 29
LIST OF TABLES
2-1 Interim Actions at SLDS Since April 1994 13
5-1 Distribution of Potential Chemical COCs Detection 27
6-1 Preliminary Remediation Goals for Industrial/Construction Workers
in the Workplace: St. Louis Downtown Site , 32
6-2 Baseline Risk at SLDS 34
7-1 Remedial Action Objectives for Remediation of the SLDS Operable Unit 38
7-2 Soil Preliminary Remediation Goals for Potential Radionuclides of Concern
in SLDS Soils Based on a Long-Term Worker (Industrial/Construction) Scenario 44
7-3 Plant 10 Post Removal Summary Data 46
7-4 Industrial/Construction Cancer Risk Assessment Results
in the Top 6 ft of Soil by Cover Depth 47
8-1 Summary of Comparative Analysis of Site-Wide Alternatives 52
8-2 St. Louis Downtown Site Volume 63
9-1 Residual Risk at SLDS 67
10-1 Chemical Specific ARARS for the SLDS 78
10-2 Action Specific ARARS for the SLDS 80
FUS208P/072398 VII
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THIS PAGE INTENTIONALLY LEFT BLANK
FUS208P/072398 Vlll
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LIST OF ACRONYMS
AEC .. U.S. Atomic Energy Commission
ALARA as low as reasonably achievable
ARAR applicable or relevant and appropriate requirement
BRA Baseline Risk Assessment
CERCLA Comprehensive Environmental Response, Compensation, and Liabilities Act
CFR Code of Federal Regulations
COC contaminant of concern
DOE U.S. Department of Energy
EPA U.S. Environmental Protection Agency
FFA Federal Facilities Agreement
FS Feasibility Study
FUSRAP Formerly Utilized Sites Remedial Action Program
HI Hazard Index
MA RS SIM Multi-Agency Radiation Survey and Site Investigation Manual
MCL Maximum contaminant limit
MDNR Missouri Department of Natural Resources
MED Manhattan Engineer District
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NEPA National Environmental Policy Act
NPL National Priorities List
NRC U.S. Nuclear Regulatory Commission
OU Operable Unit
PAH polycyclic aromatic hydrocarbon
PCB polychlorinated biphenyl
RCRA Resource Conservation and Recovery Act
RI Remedial Investigation
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
SLAPS St. Louis Airport Site
SLDS St. Louis Downtown Site
SMCL Secondary maximum contaminant level
TCLP toxicity characteristic leaching procedure
USAGE U.S. Army Corps of Engineers
VOC volatile organic compound
TBC to be considered
FUS208P/072398
IX
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FUS208fJ/072398
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II. DECISION SUMMARY
1. SITE NAME, LOCATION, AND DESCRIPTION
1.1 PHYSICAL SITE LOCATION
The St. Louis Site is a set of properties grouped in two areas in St. Louis City and St. Louis
County, Missouri (Figures 1-1 and 1-2). The St. Louis Downtown Site (SLDS) is the subject of this
remedial action. The SLDS is located in an industrialized area on the eastern border of St. Louis.
90 m (300 ft) west of the Mississippi River and 18 kilometers (km) [11 miles (mi)] southeast of the
Airport Area (Figure 1-3). The SLDS consists of the Mallinckrodt Chemical Works (Mallinckrodt
Property), owned by Mallinckrodt, Inc. (Mallinckrodt), and VPs. The Mallinckrodt Property is
bordered by a large metal recycling company (McKinley Iron Works) to the north; the Mississippi
River, an abandoned food processing plant (PVO Foods), and City of St. Louis property to the east:
a large lumber yard (Thomas and Proetz Lumber) to the south; and Broadway Street and small
businesses to the west. Additionally, the Norfolk and Western Railroad; the Chicago, Burlington.
and Quincy Railroad; and the St. Louis Terminal Railroad Association have active rail lines passing
in a north/south direction through the Mallinckrodt Property. An earthen levee between the river and
the SLDS protects the area from flood waters. These commercial and city-owned properties are
collectively referred to as the SLDS VPs. Perimeter VPs include the City of St. Louis property. PVO
Foods, McKinley Ironworks, and Thomas and Proetz Lumber Company. Manufacturing plants.
support facilities, and administrative buildings cover a large portion of the site with the rest of the
complex covered mostly with asphalt or concrete.
As a result of characterization of the soil, ground water, surface water, sediment, air. and
structures associated with the SLDS, radiological contamination attributable to MED/AEC
operations at Mallinckrodt was determined to be present in surface and subsurface soils. The
principal risk concern is potential exposure to radiological contaminants of concern (COCs)
attributable to MED/AEC operations at the site which include the thorium, actinium, and uranium
decay series.
1.2 ENVIRONMENTAL SETTING
1.2.1 Land-use and Demography
1.2.1.1 Land-use
Land-use within a 1.6-km (1-mi) radius of the SLDS reflects a mixture of commercial,
industrial, and residential uses. The majority of the SLDS is property owned by Mallinckrodt Inc.,
which has used the property for chemical manufacturing and related operations since 1867.
Mallinckrodt currently maintains 24-hr security at the property and limits site access to employees,
subcontracting employees, and authorized visitors. The SLDS is enclosed by a well-maintained
security fence. Mallinckrodt's health and safety plans include measures intended to protect
FUS208P/072398 1
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c
C/J
to
~4
to
St. Louis
Downtown Site
(SLDS)
Mallmckrodl
Vicinity
Properties
Remediated
I r\ec Properly
Railroad
Properties
ST. LOUIS SITE
hi II II k
Mi Kinicy II Thomas & II PVO I UnremeJiaied I
Iron llPrnclz Lumber I l:oods I Cily Properly I
I
Peri meter VPs
Norfolk &.Wcsirrn Railroud
5l Lotus Terminal R:uln>iul As^n
C'hic^po. Murlmgloii. nntl Ouuii'y K:nlm;it
SLAPS
Vicinity
Property
SLAPS DII.IK-V
Airport Area
St. Louis
Airport Site
(SLAPS)
II H h
Haul I Coldw.ilLT I
Roads I Creek I
Laity
Avenue
Properties
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(HISS)
I ulura
Coalings
Sn
Vionity
I'riipenios
I-A:I Ave
l-iosi Avi-
il>oiiiii-l Illvd
1'i-f.hall Kd
Addressed by (he Feasibility Study
Figure I-I. Schematic Representation of the St. Louis Site
HJSSl ln,,.s 1
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SI touts County
Wat *r Company
North County Plant
Airport Area
Sites
N
City of SL toutt
Chain of Rocks
Walac Tr«atm«nt Plant
Downtown Area Site
(SLDS)
IMnol»-Am*rtcan
Wat«r Plant
(Eft* BL Loub)
KEY
O Airport Area Sites
0 Downtown Area Site
[ . | St. Louis City Limits
Not to Seal*
Mml.lieO hoin BNI IWI
I IIS M I oiii", .1 (i i-jo
I -'inure 1-2. Locations i»f FlISRAl* I'ropi-rtif.s in the St. Louis, Missouri Area
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LEGEND:
.ASPHALT ROADS
RMUKUD TRACKS
•-Z'-'-i-^ RI*R OR CHANNO.
BOUNDARY OF SUK
--- PLANT BOUNOAKI
PREVIOUS DATE or RELEASE
( ) FOR UNR£STRlCI£D USt
: J*»UJ»(CKhOOT PHQPtRIi
---. ClPi PHOPERli
St. LOUIS
DUttNTOttN SITE
St. LOUIS, MISSOURI
:--.~-1:
I l-Jtlll I •> i'l.lll > ll ^ »! III. '•! 1 .,II|N I )n
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employees and visitors from excessive exposure to site contaminants. Zoning regulations prohibit
new residences from being established in the area and state regulations require ua well shall be
...constructed ...exclude all known sources of contamination from the well, including sources of
contamination from adjacent property" (10 CSR 23-3 010 (1) (A) (4). Two VPs, the McKinley Iron
Company and the Thomas and Proetz Lumber Company, are used for commercial or industrial
purposes. A third commercial operation, PVO Foods, has closed and the property has been
abandoned. Three other VPs are the Chicago, Burlington, and Quincy Railroad; the Norfolk and
Western Railroad; and the St. Louis Terminal Railroad Association, which transect the SLDS from
north to south. These railroads are actively used as transportation corridors. A VP owned by the
City of St. Louis is located between Mallinckrodt and the Mississippi River. With the exception of
a recreational bike trail installed in 1997, the City Property is undeveloped. The closest residential
dwelling is located on North Broadway, 60 m (200 ft) southwest of the southwestern corner of the
SLDS.
The SLDS, as well as most properties east of Broadway and south of Merchants Bridge, has
been used as an industrial area for well over a century. The area is currently zoned industrial, which
does not allow residential land-use. Some uses allowed within this zone under conditional use
permit are acid manufacture, petroleum refining, and stockyards. The long-term plans for this area
are to retain the industrial uses, encourage the wholesale produce district, and phase out the
remaining, marginal residential uses.
1.2.2 Topography, Drainage, and Surface Water
St. Louis is located in an area of gently rolling uplands which gradually flattens out to the
north and east in Illinois. The hilly terrain is cut by several broad river valleys (up to 16 km [10 mi]
wide) with steep bluffs. The Illinois and Mississippi Rivers join northwest of the City of St. Louis,
to be joined by the Missouri and Meramec Rivers from the west. The Mississippi River at St. Louis
has a drainage area of approximately 1.8 x 106 km2 (700,000 mi2). The average flow for a 114-year
period is 5 * 106 m3/s [177,000 cubic feet per second (cfs)]. Although flooding has occurred every
month of the year, higher flows are usually associated with snow melt and heavy rains in spring,
The water quality of the Mississippi River in the St. Louis area is fair to good and generally
meets the water quality standards set by the State of Missouri. Increased levels of polychlorinated
biphenyls (PCBs) present downstream from St. Louis suggest that a significant source of PCBs is
present in the St. Louis area. No PCBs have been found at the SLDS. The Mississippi, Missouri,
and Meramec Rivers supply 97 percent of the 4.5 billion liters (1.2 billion gallons) per year of
drinking and industrial water for the St. Louis metropolitan area.
The SLDS is on the western bank of the Mississippi River, 20 km (13 mi) downstream from
the confluence of the Mississippi and Missouri Rivers. Runoff from the SLDS flows into the
Mississippi River through an underground drainage system. All St. Louis-area municipal water
intakes are located upstream of the SLDS except the Illinois-American Water Plant. The Illinois-
American Water Plant supplies a small percentage of the water required by the City of East St. Louis,
Illinois. The Illinois-American Water Plant intake is located approximately 12 km (8 mi)
downstream of the SLDS on the opposite bank of the Mississippi River. The intake is sufficiently
FUS208P/072398
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far from any potential SLDS release points to preclude the possibility of intake of significant
contamination from SLDS.
1.2.3 Geology/Soils
The geologic history of the St. Louis area is characterized by the cyclic deposition of 1.800 m
(6,000 ft) of Paleozoic sandstones, shales, limestones, and dolomites. These layers thicken into the
Illinois Basin to the east and toward the Ozark Dome to the southwest. They are nearly horizontal.
dipping less than 1 degree to the northeast as a result of uplift of the Ozark Dome.
The stratigraphic section of interest for this site consists of the Pennsylvanian and
Mississippian bedrock and the overlying Pleistocene and recent nonlithified sediments. The surficial
sediments consist of sand, silt, and clay that typically range from less than 1.5 m (5 ft) to more than
30 m (100 ft) thick. These surficial deposits originated from multiple sources: glacial outwash
consisting of mixtures of clay, silt, sand, and gravel; silts and clays deposited in glacial lakes: wind-
deposited loess; and deposits from the Mississippi and Missouri rivers.
The SLDS stratigraphy (Figure 1-4) is characterized from surface to bedrock by a fill layer
present over most of the property with an average thickness of 4 m (13 ft) and nonlithified alluvial
deposits of stratified clays, silts, sands, and gravels which are located beneath the fill. Industrial fill
has been placed on top of the original floodplain to depths of up to 9m (30 ft) as the area has been
developed.
Limestone bedrock of Mississippian age underlies the unconsolidated sediments at a depth
ranging from 6 m (19 ft) on the western side of the SLDS to 24 m (80 ft) near the Mississippi River.
1.2.4 Hydrogeology/Ground Water
Ground water at the SLDS is found within three horizons (or hydrostratigraphic units): the
upper, nonlithified (soil) unit, referred to as the "A Unit;" the lower, nonlithified unit, referred to as
either the Mississippi Alluvial Aquifer or the "B Unit;" and the bedrock (the lithified water-bearing
unit), referred to as the "C unit" (Figure 1-4). The Mississippi Alluvial Aquifer is the principal
aquifer in the St. Louis area, including the SLDS area. Aquifers in this region also exist in the
bedrock formations underlying the alluvial deposits. Ground waters of the St. Louis area are
generally of poor quality and do not meet drinking water standards without treatment. Expected
future use of ground water at the SLDS is minimal, since the higher quality and large quantity of
the Mississippi and Missouri Rivers is readily available.
The A Unit is heterogeneous and the youngest of the three hydrostratigraphic horizons.
This young horizon overlies the B Unit on the east and bedrock on the west at the SLDS. The A
Unit has the largest range of soil constituents and thus a great spread in hydraulic conductivities
spatially. This uppermost unit does not have water levels or flow directly related to the river stage.
The base of the A Unit consists of fine-grained deposits behind the Mississippi River's natural levee.
The A Unit also had meandering creeks and swampy low topography prior to the introduction of fill
material. In the 1800's the A Unit's surface was raised with the least expensive, most readily
FUS208P/072398
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Description
RUBBLE and FILL
Grayish black (N2) to brownish black (5YR2/1). Dry to slightly moist. penerallv Iv
moist at 5-6 ft and saturated at 10-12 ft. Slight cohesion, variable with depth. moiMure
content and percentage of fines present. Consistency of relative density is unrepre->entan\
due to large rubble fragments.
Rubble is concrete, brick, glass, and coal slag. Percentage of fines as silt or clay increj^e*
with depth from 5 to 30 percent. Some weakly cemented aggregations of soil p.irticle;.
Adhesion of fines to rubble increases with depth and higher moisture content.
Degree of compaction is slight to moderate with frequent large voids.
Silty CLAY (CH)
Layers are mostly olive gray (5Y2/1), with some olive black (5Y2/1). Predominantly occur*
at contact of undisturbed material, or at boundary of material with elev.ited activity.
Abundant dark, decomposed organics.
Variable percentages of silt and clay composition.
CLAY (CL)
Layers are light olive gray (5Y5/2). or dark greenish gray (5GY4/1). Slightly moiM to moiM.
. moderate cohesion, medium stiff consistency. Tends to have lowest moisture content.
Slight to moderate plasticity.
Interbedded CLAY, silty CLAY, SILT and Sandy SILT (CL, MM, SM)
Dark greenish gray (5GY4/1) to Light olive gray (5Y6/1). Moist to saturated, dependent on
percentage of particle size. Contacts are sharp, with structure normal to sampler .IMS to le^
than 15 degrees downdip. Layer thicknesses are variable, random in alternation with no
predictable vertical gradiation or Literal continuity.
Some very fine-grained, rounded silica sand as stringers. Silt in dark mafic, biotite (Like*
Some decomposed organics.
Q.
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'•£ _
2m
.
o
0-10
Sandy SILT (ML)
Olive gray (5Y4/1). Moist with zones of higher sand content saturated. Slight to moder.ite
cohesion, moderate compaction. Stiff to very stiff consistency, rapid dilatancy. nonpl.iMic
Sand is well sorted, very fine and fine-grained rounded quartz particles.
0-50
Silty SAND and SAND (SM, SP, SW)
Olive gray (5Y4/1). Saturated, slight cohesion, becoming noncohesive with decrease ot ;
particles with depth. Dense, moderate compaction.
Moderate to well-graded, mostly fine- and medium-grained, with some fine- and coarse
grained particles. Mostly rounded with coarse grams slightly subrounded.
Gradual gradation from upper unit, silty sand has abundant dark mafic/biotite flakes
Sand is well-graded, fine gravel to fine sand. Mostly medium-grained, with some line-
grained and few coarse-grained and fine gravel.
ill
s"
I
Total
thickness
not
penetrated
during
drilling
LIMESTONE
Light olive gray (5Y4/1) with interbedded chert nodules. Generally hard to very hard;
difficult to scratch with knife. Slightly weathered, moderately fresh with little to no
discoloration or staining.
Top 5 ft is moderately fractured, with 99 percent of joints normal to the core axis. Joints are
open, planar, and smooth. Some are slightly discolored with trace ol hematite staining.
Note: The codes in parentheses following lithologies are the Unified Soil Classification Systems codes.
Source Moditiea from BNI 1992
<=US Si Lou.s30198
Figure 1-4. Generalized Stratigraphic Column for the SLDS
FUS208P/072398
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available fill materials: rubble and wood and coal combustion wastes, e.g., coal slag and cinders.
The combustion products used for fill had inherently high metal concentrations. The infiltration and
throughput of water in the A Unit is relatively minor, since the ground surface has large areas of
buildings, road surfacing, and channeled surface water flow. This shallow unit is not a productive
source of water due to poor yield and its multiple chemical constituents. The A Unit is not an
aquifer and is not considered a potential source of drinking water because it has insufficient yield.
poor natural water quality, and susceptibility to surface water contaminants of the industrial setting.
The long-term industrial filling of the site and the present industrial setting also are factors in the
consideration that the A Unit, the most shallow hydrostratigraphic horizon, is not a drinking water
resource.
The B Unit thins westwardly on the rock surface until it becomes absent beneath the SLDS,
being truncated by the rising bedrock and the A Unit (Figure 1 -5). The B Unit may attain a thickness
of 20 m (70 ft) to the east at the river. The ancestral Mississippi River deposited the B Unit's
sediments after the river's greatest erosion of the bedrock floor. Unit B is a horizon of fining-
upward, interfingered and crosscut sands and gravels with direct hydraulic connection to the
Mississippi. The granular nature and association with the river allows the B Unit to have unique
chemical and hydraulic character. The B Unit has high dissolved solids and metal concentrations
(iron and manganese above their Secondary Maximum Contaminant Levels, SMCLs). The dissolved
solids and metal content are naturally occurring. The aquifer's pressure and flow direction react to
changing river stages. The source of the B Unit's ground water recharge at low river stages is
upgradient flow from the bedrock unit and minor downward infiltration from the A Unit. Water at
high river stages, or under heavy pumping loads, is predominantly from the Mississippi. Recharge
from the B Unit aquifer is available at high volumetric rates. Extracted water from the B Unit would
require treatment to reduce the natural total dissolved solid and metal content. The use of the B Unit
for a drinking water resource is highly unlikely for several reasons: the industrial setting of the
SLDS, the site's proximity to both the Mississippi and the city's drinking water supply, and the poor
natural water quality of the B Unit. However, the B Unit does qualify as a potential source of
drinking water under the "Guidelines for Groundwater Classification under the EPA Groundwater
Protection Strategy" (Final Draft, December, 1986).
The C unit surface slopes from the western uplands to the river. The limestone bedrock has
nearly horizontal bedding, which slopes only a few degrees to the east. Solution channels and
fractures dominate the water routes through the bedrock. Uplands recharge of the C unit Hows
downgradient to the river valley providing recharge to the B Unit, the Mississippi Alluvial Aquifer.
The C unit would be an unlikely water supply source, as it is deeper and a less productive
hydrostratigraphic unit.
1.2.5 Ecology
The St. Louis Downtown Site is located in the Oak-Hickory-Bluestem Parkland section of
the Prairie Parkland Province. Topography is gently rolling with low bluffs north of the Missouri.
Presettlement vegetation is characterized by deciduous woodlands intermixed with open prairie.
Today, because of extensive industrialization, little presettlement vegetation exists in the area
including the St. Louis Downtown Site.
FUS208P/072398 8
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fii
200 400 600 800 1000
1200 MOO 1600 1800
Feet
2000 2200 2400 2600
=n
If bar*? O-K Sc.'-
• I JA.: 3
£*oqqcrot.«r. 11'.ti
-------
The SLDS is completely developed; therefore, almost no biological resources exist on or near
the SLDS. This is related to several decades of highly urbanized land uses surrounding the site. The
only animals observed at the SLDS during the site survey were insects (e.g.. ants) and swifts
(Chaetura pelagica), red-winged blackbirds (Agelaius tricolor), and pigeons (Columba livia) flying
through the area. Small mammals, particularly house mice (Mus musculus) and rats (Ratus sp.) have
habitat in the area.
1.2.6 Archaeological and Historical Sites
Two sites listed in the March 1992 edition of the National Register of Historic Places for the
State of Missouri exist within a 1.6-km (I'-mi) radius of the SLDS. The first site is the Bissell Street
Water Tower, located approximately 1.3 km (0.8 mi) northeast of the SLDS. The second is the
Murphy-Blair Historic District located 0.8 km (0.5 mi) from the SLDS.
SLDS does not contain any historic buildings. Available data indicate no archaeological sites
in the area. Consultation with the State Historic Preservation Officer has been completed. However.
no archaeological survey of the property itself has been conducted. The site is covered by a fill layer
averaging 4 m (13 ft) which overlies alluvial deposits extending to 24.0 m (80 ft). The degree of
disturbance beneath the fill layer is not presently known. The property is approximately 0.4 km
(0.25 mi) from the former location of an American Indian mound group, the St. Louis Mounds.
FUS208P/072398 10
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2. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Mallinckrodt Inc., since 1867 at this facility, has used, blended, and/or manufactured
chemicals, including organics (e.g., 1,2-dichloropropane, dichloromethane. phenol, zinc
phenolsulfonate, toluene, hexane, dimethylaniline, chloroform, alcohols, propanediols. nitrobenzene.
nitrophenols, xylenes, trichJoroethene, hexachlorobutadiene, oxydianiline tars, stearates. biphenyls.
acetonitrile), and inorganics (e.g., aluminum chloride, hydroxide salts, zinc, sulfuric acid, nitric acid.
hydrochloric acid, chromium, sodium iodide, magnesium salts, palladium, bismuth oxychloride).
A number of chemicals and compounds that have been associated with non-MED/AEC operations
have been detected in soil and ground water. A levee/floodwall located to the east of the SLDS
protects the area from flood waters.
Mallinckrodt Chemical Works, from 1942 until 1957, was contracted by MED and AEC to
process uranium ore for the production of uranium metal. Residuals of the process, including spent
pitchblende ore, process chemicals, and radium, thorium, and uranium, were inadvertently released
from the Mallinckrodt Property and into the environment through handling and disposal practices.
Residuals from the uranium process had elevated levels of radioactive radium, thorium, and uranium.
From 1942 to 1945, Plants 1,2, and 4 (now Plant 10) (Figure 1-3) were involved in the development
of uranium-processing techniques, uranium compounds and metal production, and uranium metal
recovery from residues and scrap. Uranium-bearing process residues from these operations were
stored at the SLAPS and the Latty Avenue Properties'from 1946 to 1966. Relocation and storage
of these processed wastes at SLAPS and the Latty Avenue Properties resulted in the subsequent
contamination of the SLAPS VPs. Mallinckrodt decontaminated Plants 1 and 2 from 1948 through
1950 to meet the AEC criteria then in effect, and the AEC released these plants for use without
radiological restrictions in 1951.
Plant 6 produced uranium dioxide from pitchblende ore starting in 1946. During 1950 and
1951, Plant 10 was modified and used as a metallurgical pilot plant for processing uranium metal
(until it was closed in 1956) and operations began at Plants 6E, 7, 7E, 7N, and 7S. AEC operations
in Plant 6E ended in 1957. AEC managed decontamination efforts (removal of radiologically
contaminated buildings, equipment, and soil disposed offsite) in Plants 10, 7, and 6E to meet AEC
criteria in effect at that time and returned the plants to Mallinckrodt in 1962 for use without
radiological restrictions. Since 1962, some buildings have been razed, and new buildings have been
constructed at Plants 10 and 6. Except for Building 25, which will be addressed under a separate
CERCLA action, the MED/AEC related buildings have recently been razed, making previously
inaccessible contaminated soils available for cleanup.
Process, storm, and sanitary effluent from the SLDS was collected in a combined sewer
system for discharge directly to the Mississippi River through a municipal outfall, before the Bissell
Point Sewage Treatment Plant went on line in December 1970,. The Bissell Point Sewage Treatment
Plant is approximately 1 mile north of the SLDS. After the Bissell Point Sewage Treatment Plant
went on line, dry weather sewer flow was collected for treatment prior to release to the river.
Mallinckrodt, Inc.'s discharge permit states that discharge of the wastewater shall not be at a rate that
would cause the influent at Bissell Point to exceed the 1 Curie per year limit. In times of heavy
FUS208P/072398 11
-------
stormwater flow, when the capacity of the interceptor tunnel under the SLDS is exceeded, excess
flow in the municipal sewer is discharged directly into the river.
A radiological survey conducted in 1977 at the SLDS found that alpha and beta-gamma
contamination levels exceeded guidelines for release of the property for use without radiological
restrictions (ORNL 1981). Elevated gamma radiation levels were measured at some outdoor
locations and in some of the buildings formerly used to process uranium ore. Radium (Ra)-226 and
uranium (U)-238 activities were found significantly above background in subsurface soil.
Additionally, radon and radon daughter activities in two buildings exceeded guidelines for
nonoccupational radiation exposure. In response to this survey, it was determined that further
investigation was necessary to characterize the nature and extent of contamination, and possible
remedial actions to mitigate threats to human health and the environment.
Four interim actions have been performed at SLDS. A summary of these actions is provided
in Table 2-1. Actions taken at the site will be conducted under the Formerly Utilized Sites Remedial
Action Program (FUSRAP). FUSRAP was executed by the U.S. Department of Energy (DOE) to
identify and remediate or otherwise control sites where residual radioactivity remains from activities
conducted while under contract to MED and AEC during the early years of the nation's atomic
energy program or from commercial operations that Congress directed DOE to remediate and that
DOE added to the FUSRAP sites. On 13 October 1997, the U.S. Congress transferred responsibility
for FUSRAP from the U.S. Department of Energy (DOE) to the USAGE through the 1998 Energy
and Water Development Appropriations Act. In June 1990, EPA Region VII, and DOE entered into
a CERCLA Section 120 Federal Facilities Agreement (FFA). In the FFA, DOE agreed to conduct
response actions for the following materials:
• All wastes, including but not limited to radiologically contaminated wastes, resulting
from or associated with MED/AEC uranium manufacturing or processing activities
conducted at the SLDS.
• Other chemical or radiological wastes that have been mixed or commingled with wastes
resulting from or associated with MED/AEC uranium manufacturing or processing
activities conducted at the SLDS.
The ROD addresses contamination related to MED/AEC activities in accessible soils and
ground water. SLDS Buildings 101 and 25 and St. Louis Site's currently inaccessible soils related
to MED/AEC activities will be remediated under a future CERCLA action.
In addition, there are two other major environmental contaminant abatement efforts underway
at the Mallinckrodt Property. Mallinckrodt, Inc. is pursuing a RCRA Part B permit for their entire
facility and is also attempting to terminate their NRC license for the Columbium/Tantalum process
conducted in the Plant 5 area. Columbite is the mineral name for (Fe, Mn)Nb2O6. Tantalite is the
mineral name for (Fe, Mn)Ta206.
The USAGE will continue to cooperate with the EPA, the State of Missouri and
Mallinckrodt, Inc. to ensure that response actions are coordinated so that all site threats are
addressed.
FUS208P/072398 12
-------
Table 2-1. Interim Actions at SLDS Since April 1994
Property
50 Series Buildings (Bldgs.
50, 51,51A,52, and52A)
Plant 6 and 7 Buildings
(Bldgs. 100, 116, 116B,
117,700,704,705,706,
707, and 708)
Plant 10 area subsurface
soil
City Property (Riverfront
Trail area)
Activities
Decontamination,
demolition, and
crushing
Asbestos abatement,
decontamination,
demolition to floor
elevation grade, crushing
Excavation
Excavation
Volumes Remediated*
1,000 yd3 shipped off-site;
1,000 yd' of crushate stockpiled in
a fenced area on Mallinckrodt Inc.
property
2,673 yd3 shipped off-site;
7,000 yd5 of crushate stockpiled
on the Mallinckrodt Inc. propertv,
Lot 7E
15,043 yd3 shipped off-site
750 yd3 shipped off-site
Authorizing
Document
DOE/OR.;2370 1-02.2
DOE/OR..2370 1-02.2
DOE/OR/2370 1-02. 2
DOE/OR/2370 1-02. 2
I:
* These are the volumes shipped. They are greater than the in situ impacted volumes because they include any extra
soil to assure removal and the bulking (volume increase) that results from excavation.
Source: DOE 1991. Engineering Evaluation/Cost Analysis for Decontamination at the St. Louis Downtou n Site.
St.Louis, MO, DOE/OR/23701-02.2, May.
FUS208P/072398
13
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FUS208P/072398 14
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3. HIGHLIGHTS OF COMMUNITY PARTICIPATION
Public-input has been encouraged by both DOE and the USAGE to ensure that the remedy
selected for the SLDS meets the needs of the local community in addition to providing an effective
solution to the problem.
The Administrative Record, which contains the documentation used to select the response
action, is available at the following locations:
Government Information Section
St. Louis Public Library - Central Library
1301 Olive Street
St. Louis, MO 63101
USAGE Public Information Center
9170Latty Avenue
Hazelwood, MO 63134
DOE published a Notice of Intent in the Federal Register on January 9, 1992, to present
pertinent background on the scope and content of the St. Louis site RI/FS. The comments, concerns.
and written statements from a January 28, 1992 public scoping meeting held at Berkeley Senior High
School, Berkeley, Missouri, were published in a Responsiveness Summary and made part of the
St. Louis work plan for the RI/FS. In addition, the relevant comments from a December 6. 1990
scoping meeting on the programmatic environmental impact statement were also included in the
work plan.
A copy of the Administrative Record File for actions at the SLDS has been maintained by
the USAGE and DOE at the Public Information Center and the St. Louis City Public Library and is
updated.quarterly. The community relations program interacts with the public through news
releases, public meetings, availability sessions, site tours, public workshops, meetings with local
officials and interest groups, and receiving and responding to public comments through
correspondence and the information center. The documents describing the results of the integrated
process for the St. Louis site have been made available to the public for review and comment at the
information repositories noted above. The following documents were issued by USAGE and DOE:
• The Remedial Investigation for the St. Louis Site (DOE 1994) and the Remedial
Investigation Addendum for the St. Louis Site (DOE 1995) characterizes the nature and
extent of contamination at the site.
• The Baseline Risk Assessment for the Exposure to Contaminants at the St. Louis Site
(DOE 1993) evaluates the potential risk to human health and the environment from
contaminants associated with the site in the absence of any remedial action.
FUS208P/072398 15
-------
• The Feasibility Study for the St. Louis Downtown Site (USAGE 1998a) identifies.
develops, and evaluates remedial action alternatives for the site based on the nature and
extent of contamination documented in the RI.
• The Proposed Plan for the St. Louis Downtown Site (USAGE 1998b) summarizes
background information on the St. Louis site, describes the alternatives considered to
clean up the site, presents the rationale for selection of the preferred remedy,, and solicits
public comment.
From September 1994 through December 1996, a task force known as the St. Louis Site
Remediation Task Force studied all aspects of the St. Louis FUSRAP site and formally transmitted
the results of their deliberations to the U.S. Department of Energy in the St. Louis Site Remediation
Task Force Report (September 1996). Specific areas of focus included: 1) identification of
alternative disposal sites, 2) health risks/cleanup standards, 3) development of local priorities with
respect to cleanup of the site, 4) identification of remedial action alternatives, 5) a screening of
technologies that may be applied at the site, and the 6) development of a communications and public
awareness plan.
The task force was composed of members appointed by the city and county of St. Louis.
adjacent communities, EPA, MDNR, concerned citizens, public utility and local business
representatives, representatives of congressmen, and representatives of local environmental groups.
In their summary report, the following statement was provided in Section 4, titled
Conclusions and Recommendations. "Further, the Task Force requests that remediation at the
St. Louis Downtown site and the City Levee continue or begin with 'site specific' standards for
industrial or recreational use, respectively."
The FS and Proposed Plan were released for public comment on April 8, 1998. The public
was notified of the public comment period for the Proposed Plan through public mailings, notices
in the regional metropolitan and rural newspapers, announcements on local radio stations, and
notices delivered to residences in the nearby neighborhood.
The 30-day public comment period began on April 8, 1998. A public meeting was held on
April 21, 1998 to provide information about the remedial alternatives and the opportunity to submit
comments on the Proposed Plan. A Responsiveness Summary was prepared to address comments
received during the public comment period. In general, public comments on the Proposed Plan
rejected the USAGE preferred alternative (Alternative 4) as too restrictive for properly owners; a
strong preference for Alternative 6 was expressed by the community. Based on community input
and reevaluation of CERCLA cost and risk criteria, the USAGE selected Alternative 6 for
implementation at the site. The Responsiveness Summary is provided in Appendix A of this ROD.
FUS208P/072398 16
-------
4. SCOPE AND ROLE OF OPERABLE UNIT
This operable unit is the final remedial action for the accessible soil and ground water
contaminated as the result of MED/AEC uranium manufacturing and processing activities at the
St. Louis Downtown Site (SLDS). The subsequent response action includes remediation of the two
remaining MED/AEC related buildings (buildings 25 and 101) and soil which is currently
inaccessible because of the presence of the two buildings, active rail lines, roadways, and the levee.
Previously cleaned up properties addressed under removal authority are described in Table 2-1 and
include Plant 10 (City Block 1201) and the land east of the levee (DOE 1996, 1997). Remediation
of these portions of the site is fully protective and thus they will not require further remediation.
Characterization activities at the SLDS have determined that contamination related to
MED/AEC activities is present in the soils of Mallinckrodt, Inc. and VPs at levels that require
remedial action. Much of the contamination detected resulted from MED/AEC activities while some
of the contamination is the result of other industrial processes associated with Mallinckrodt
operations and other nearby industries. Still other contaminants have leached from the coal slag and
cinders used as fill in the area. As agreed to under the FFA, hazardous substances resulting from
releases on the site during the Mallinckrodt operations for the MED/AEC are the subject of this
response action. Contaminants resulting from other actions, or preexisting contaminants at the site
are being addressed through actions being carried out by other authorities. This includes both
radioactive and hazardous substances which are the responsibility of other parties. The other actions
being carried out include termination of a Mallinckrodt NRC license for plant 5 and a RCRA action
for the entire Mallinckrodt site. EPA, NRC, the State of Missouri and Mallinckrodt, Inc. are working
together to assure that all remaining potential hazards at the site are addressed.
Inaccessible soils that contain MED/AEC contamination and associated buildings and
structures are excluded from the scope of this ROD because they do not present a significant threat
in their current configuration and because activities critical to the continued operation of the
Mallinckrodt facility prevent excavation beneath the encumbrances (ie, roads, railroads, buildings
25 and 101, etc.). Contamination present within building 25 also does not present an excessive risk
under its current configuration.
FUS208P/072398 17
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FUS208P/072398
18
-------
5. SUMMARY OF SITE CHARACTERISTICS
A remedial investigation (RJ) (DOE, 1994) was conducted in accordance with CERCLA to
determine the nature and extent of contamination at SLDS relevant to this operable unit. Analytical
results for radiological and chemical characterization surveys are summarized in the RI report (DOE
1994) and the RI Addendum (DOE 1995). Analyses performed during characterization included
thorium (Th)-230, Th-232, radium (Ra)-226, uranium (U)-238, volatile organic compounds (VOCs).
base neutral and acid extractable compounds, metals, Resource Conservation and Recover. Act
(RCRA)-hazardous waste characteristics, pH, specific conductance, total organic halogens and total
organic compounds. Characterization activities were performed at SLDS for soil, air. and ground
water. In addition, above ground structures associated with MED/AEC processes were surveyed for
fixed and transferable radiological contamination. The results of this investigation for the SLDS arc
summarized here.
Soil characterization results indicated that the areas associated with MED/AEC activities
were principally contaminated with radionuclides. Metals and VOCs were also detected in those
areas and across the site, but generally occur in limited pockets. The radiological contaminants
associated with MED/AEC activities are readily identifiable because of the distinct suite of
radionuclides used in the MED/AEC processes and the location where these contaminants were
found. However, the source of the detected non-radionuclide contaminants is not as clear. The
potential for non-MED/AEC process-related organic and inorganic releases from the Mallinck-rodt
Inc. facility and surrounding businesses is substantial given the nature and duration of industrial
activities in the area. In addition, the non-MED/AEC columbium-tantalum processing activities and
the coal combustion products used as fill in the area may have contributed radioactive contaminants
as well as metals and polycyclic aromatic hydrocarbons (PAHs). There is no indication of use or
.generation of PAHs in MED/AEC processes or operations.
Radionuclide Distribution in Soil
The principal radioisotopes associated with the MED/AEC process at the SLDS are Ra-226.
Ra-228, Th-230, Th-232, uranium (including U-238, U-235, and U-234), and their respective
radioactive decay products. Analytical results for radiological surveys at the VPs indicate that the
primary radionuclide in soil is Th-230. Figures 5-1, 5-2 and 5-3 show the extent of Ra, Th, and U
contamination associated with MED/AEC processes at the SLDS. Figures 5-4 , 5-5 and 5-6 illustrate
the vertical profile of contaminants based on projections of the boring data. Most of the
contamination is distributed near the surface, but does extend to significant depth (23 ft) at Plant 2.
Also, inaccessible soils are found at 13 ft under the levee on property owned by City of St. Louis.
Distribution of Metals in Soil
Metals were found in radiologically contaminated soil, however for arsenic, the detection
limit for the data collected during the RI exceeds the mean value for background samples collected
in a subsequent investigation (SAIC 1998). All the sources of elevated metal concentrations are not
defined. Geologic logging confirming anecdotal evidence indicates a probable source of elevated
metal concentrations in soil is the coal combustion products used as fill throughout the property
FUS208P/072398 19
-------
o>
c
£
0>
£
Q.
4)
"3
t/5
O
mumlRo-226 volues projected from deplri (o Surface
Distribution includes mot
1029600
1029400
1029200
907200 907600 908000 908400 908800 909200 909600 910000
MO State Plane Easting (feet)
Sample Location
pCi/g
Max
5400
100 150
0 200 400 6QQ 800 1QQO
FEET
-------
s.
l_J
X
0>
0>
o>
c
o
0>
o
(
O
2
Th-230 volues projected from depth to surtoce
907200 907600 908000 908400 908800 909200
MO State Plane Easting (feet)
909600 910000
+ Sample Location
pCi/g
15 40 50 100 150
Max
98000
A
N
0 200 400 600 800 1000
FEET
l-i»un- 5-2. I vluii ol I h-J.Hi < s
-------
•4)
O>
c
".c
0>
c
o
a.
o
(7)
o
X *
\\ , ,• * * »
* .+ + "*• •» V +
- •«£-. -+ + +T**
t *T\>**.^:.
Remediotea Area
U-238 vaijes projected from depth to surface
907200 907600 908000 908400 908800 909200 909600 910000
MO State Plane Easting (feet)
+ Sample Location
50 100 150 200 300 600
IMox
195000
0 200 400 600 800 1000
FEET
I liMlll > > I vUlli ..J_l
, HMl.llHIII.lll.nl ,ll S|
-------
Pland 2
Plant 7
Ra-226
i Units: pdtg
! / t>x;i(iy$ration: 20.0
! Y Front Cut: 1029900.0
VI
Plant 2
Plant 7
Th-230
Units: pCHg
; / <:xu(i(]tfr,-itiun: 20,0
\ Y Front Cut: 1029900.0
Plant 7
l'-23X
MO State Plane Fasting (feet)
Units: fJd/fj
Y Front Cut: 1029900.0
Figure 5-4. Vertical Extent of Contamination at SLDS (East-West Cross Section
through Plant 7 and 2)
?2V>.s
-------
ITOo-.SSOD
(fo
•B« '
MO Sftatt« PHamfi Nortlhooiig (feed)
Figure 5-5. Vertical! exterot of contamination at SLOS North-South Cross Section
through Pliant 6
n 'S2(ixi>
24
-------
•c<§
*:-.
fl.
8(1
' 0 00
=?=>»
ft (PtamG'A
C?
BUM)
QaQ:
SSS,®
MO State Plane Northing (feet)
Figure 5-6. Vertical Extent of Contamination nt SLDS (North-South Cross Section- 2
through Plants 6 and 7
-------
Production of Mallinckrodt products, and uranium processing activities may also have contributed.
Based on ore assays, waste analyses, and risk assessment, the metals identified in the FS that may
pose a risk and may have AEC/MED origins include arsenic, cadmium, copper, nickel, and uranium.
Table 5-1 summarizes the relevant metal and chemical data from the remedial investigation.
Nickel was not detected in the 171 samples at values above average U.S. background (40 me kn).
Copper was detected in 40 of 171 samples and ranged in concentration from 114 to 1120 mg'kg.
Arsenic was detected in 46 of 171 samples acquired from across the site. The detection limit
for arsenic was relatively high, but it was sufficient to distinguish that arsenic is widely distributed.
occurring both with other MED/AEC contaminants and randomly distributed across the site. Thirty
background samples were collected near the SLDS and arsenic was detected in each in concentrations
ranging from 4 to 27 mg/kg (SAIC 1998). While arsenic was identified as being present in the original
uranium ore, no clear association could be discerned between the presence of arsenic and the location
of MED/AEC radiological constituents. Figure 5-7 shows the distribution of arsenic.
There were 76 detections of cadmium in 171 samples. Soil concentrations ranged from less than
1 mg/kg to 44 mg/kg. As indicated in Figure 5-7, the distribution was both commingled with other
MED/AEC contamination and random throughout SLDS independent of other MED/AEC contaminants.
Cadmium was detected in 9 of 30 background samples with values up to 3.8 mg/kg (SAIC 1998).
Uranium is characterized based on both its chemical and radiological properties. Site
characteristics are addressed as a radiological constituent.
Distribution of Organic Compounds in Soil
Organic compounds commonly found in industrial areas were detected in very lo\v
concentrations across the property; approximately two-thirds of these are PAHs. Base/neutral and
acid extractables, identified as PAHs, were found in higher concentrations (ranging from 310 to
300,000 /ug/kg) than were VOCs, but they are typically not very mobile in soil. No pattern of PAH
distribution in soil was discernible across the site; these compounds are randomly distributed. In
addition, no evidence has been found that any MED/AEC process used or generated PAHs. Data
reviewed included all available information on site history and processes, and analysis of 30 off-site
background samples (SAIC 1998). PAHs were detected in 25 of 30 background samples with
concentrations to 14,000 ^g/kg. Borings exhibiting the highest concentrations of PAHs were widely
spaced across the site in Plants 1, 7W, and 10 (BNI 1990). PAHs are widespread in any urban area
which has been subject to industrial development since the mid-1800s. and thus can not be attributed
to a single process. The PAHs that occurred with the greatest frequency at the site are those
associated with coal and coal combustion residues.
One of the last steps in the production of uranium metal at the Mallinckrodt facility was to
cast the uranium into the form of hemispheres which resembled derbies. Therefore, the cast uranium
hemispheres were known as uranium derbies, or derbies. A single reference from the late 1950's
indicated that trichJoroethene may have been used to clean uranium derbies (Harrington and Ruehle.
1959) which were produced in the Plant 6 area. No information was provided on the amount of TCE
used or length of time over which it was used.
FUS208P/072398 26
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Table 5-1. Distribution of Potential Chemical COCs Detection
Analyte
Detections /
# Samples
Minimum
Maximum
Average
Detection
Plant
Arsenic (mg/kg)
Cadmium (mg/kg)
Copper (mg/kg)
Nickel (mg/kg)
ND/1
I/I
I/I
ND/1
ND
16.1
203
ND
ND
16.1
203
ND
ND
16.1
203
ND
Plant 2
Arsenic (mg/kg)
Cadmium (mg/kg)
Copper (mg/kg)
Nickel (mg/kg)
3/13
5/13
1/13
ND/1 3
63.1
0.97
167
ND
65.9
1.9
167
ND
64.9
1.15
167
ND
Plant 6a
Arsenic (mg/kg)
Cadmium (mg/kg)
Copper (mg/kg)
Nickel (mg/kg)
ND/4
3/4
2/4.
ND/4
ND
1.40
101
ND
ND
is. 2
113
ND
ND
5.13
107
ND
Plant 6b
Arsenic (mg/kg)
Cadmium (mg/kg)
Copper (mg/kg)
Nickel (mg/kg)
4/6
2/6
2/6
ND/6
44.60
3.60
109
ND
69.8
5.5
350
ND
60.6
2.3
230
ND
Plant 6c
Arsenic (mg/kg)
Cadmium (mg/kg)
Copper (mg/kg)
Nickel (mg/kg)
1/1
ND/1
ND/1
ND/1
84.4
ND
ND
ND
84.4
ND
ND
ND
84.4
1
ND
ND
FUS208P/072398
27
-------
Table 5-1 Distribution of Potential Chemical COCs Detection (continued)
Analyte
Detections /
# Samples
Minimum
Maximum
Average
Detection
Plant 7
Arsenic (mg/kg)
Cadmium (mg/kg)
Copper (mg/kg)
Nickel (mg/kg)
ND/4
3/4
2/4
ND/4
ND
1.7
239
ND
ND
3.6
482
ND
ND
2.47
361
ND
Remainder of Site
Arsenic (mg/kg)
Cadmium (mg/kg)
Copper (mg/kg)
Nickel (mg/kg)
38/142
62/142
32/142 '
ND/142
40.7
0.95
114
12.6
200
44.1
1120
24.4
64
2.25
289
20.3
ND = Not Detected
FUS208P/072398
28
-------
c
(/>
to
o
oo
O
-4
I-J
1031000
.1030800
1030000
^
Q.
^ 1029800
15
C/) 1029600
O
3 1029400
1029200
•™ Removal Boundory
Prom Or* Actions
A* Atxn* U.S. Bkqd and Above Soil Cone
O( Jl mg/kg (or Upper Soil Zone and
Above 276 mg/kg lor D»*p Soil Zone
Cd Above U.S. Bhgrd and Above Soil Cone
ol 1.6 mg/kg (or Upper Soil Zone and
Above 43 mg/kg (or Deep Soil Zone
if Both A» * Cd Above Upper and Deep Soil Zone
Limits (a* defined above)
Distribution include* monimum SOW values (boeed on composite criteria o(
5/15. 5/15, 50 pCi/g) projected (rom depth to lurloce (upper and deep soil
zonee 01 defined in Alternative 6 -- tones divided at 4 or 6 fool depth)
i i i i i i i i I
907200 907600
908000 908400 908800 909200
MO State Plane Easting (feet)
909600
910000
10
SOR
100
300
• Zone Exceeding Criteria, SOR > 1
(SOR based on 5/15. 5/15, 50)
Figure 5-7. Distribution of Metal C ()( s al SIJ)S
-------
At least forty-one samples for TCE were acquired from within or near where MED/AEC
activities were known to have taken place. Eight detections of TCE were reported. While not as
widespread as for cadmium or arsenic, the distribution was random. TCE was detected in 3 of 30
background samples (SAJC 1998).
Chemical sampling over the radiologically contaminated areas for spatial coverage of the
site indicates the soil does not exhibit RCRA-hazardous waste characteristics for corrosiviry. toxiciry
characteristic leaching procedure (TCLP), ignitability, or reactivity. In addition, no records or
information were discovered that would indicate the environmental media contained any RCRA
listed hazardous wastes.
Ground Water
Ground water has been impacted by processes conducted at this industrial location. A
number of radiological, organic, and metal analytes were detected in the A Unit's ground water.
Significant concentrations of uranium, 1,2-DCE, benzene, PCE, TCE, vinyl chloride, aluminum.
arsenic, chloride, sulfate, iron, and manganese were detected in the A Unit. Other industrial
activities at the site could have contributed any or all of these analytes.
Fewer analytes were detected in the B Unit's ground water. Significant concentrations of
dichJoromethane, hexachlorobenzene, 1,2-DCE, vinyl chloride, chloride, iron, and manganese were
detected in the B Unit. Other industrial activities at the site could have contributed any or all of these
analytes.
Section 6.1 discusses the COCs that are carried forward as part of this operable unit.
Sediments
Sediment samples taken from some of the manholes, catch basins, and sewers at the SLDS
exhibited radioactive contamination exceeding composite guidelines. Some sections of these sewer
lines are beneath buildings and are therefore considered inaccessible. Based on the observation that
contamination levels decrease with increasing distance from the site, there is limited possibility that
an accumulation of contaminated sediment of appreciable quantity exists offsite. With increasing
development in the area and collection of wastewater for treatment, the water load on the system has
increased. This has increased the likelihood that most of the loose deposits in the system have
already been scoured away.
Some radiological contamination in Mississippi river sediments was tentatively identified.
Sediment sampling was conducted in the Mississippi River along the City Property in 1987-1988
when the river water level was low. Results indicated the primary contaminants were Th-230, with
activities ranging from 1 to 160 pCi/g, and Ra-226, with activities ranging from 6 to 1,100 pCi/g.
Additional sampling conducted in 1992 to confirm earlier results yielded contaminant levels of
<1 pCi/g for both Th-230 and Ra-226. It is suspected that periods of high water between 1988 and
1992 washed the contaminants in the sediment downstream.
FUS208P/072398 30
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6. SUMMARY OF SITE RISKS
A Baseline Risk Assessment (BRA) (DOE 1993) was conducted to evaluate potential risks
to human health and the environment from the radioactive and non-radioactive contaminants at the
site without regard to the source of contamination. In accordance with EPA guidance, both cancer
and non-cancer toxic effects were evaluated for reasonable maximum exposures (RME). The
assessment evaluated the potential risks that could develop without cleanup and assumes there are
no protective controls in place, such as fencing to control access. In addition, possible effects on
animal and plant species (ecological risk) were considered.
The purpose of the BRA is to determine the need for cleanup and to provide a baseline
against which the remedial action alternatives are compared. The complete BRA report is available
from the Administrative Record File for this site. A brief summary is provided here.
The BRA identified the routes by which people and the environment may be exposed to
contaminants present at the SLDS. The SLDS has been industrial for over 100 years. The area is
zoned "K" (unrestricted district) by the City of St. Louis. This category allows all uses except
residential. Although there are residences near SLDS, the long-term plans for the area are to retain
industrial uses, encourage the wholesale produce district, and phase out junk yards, truck storage
lots, and the remaining residential uses. Based on past use, present zoning, and long-term planning,
future use is most likely to remain industrial as well. Although future residential use is plausible.
but unlikely, as a conservative measure the baseline risk assessment evaluated this scenario. Thus
risks were calculated for current industrial and construction use and future residential use. In
addition, recreational use of the City Property was evaluated. Pathways included external exposure
to gamma radiation, particulate and radon inhalation, incidental soil ingestion, arid dermal contact.
In addition, for the future resident, ingestion of, inhalation of, and dermal contact with ground water
.were evaluated as well as ingestion of food from a garden grown in contaminated soil. It is the
commercial/industrial scenario which is considered the reasonable future use upon which this
remedial action is based. The results of the baseline risk assessment are summarized in Section 6.2.
Mathematical models were used to predict the possible effects on human health and the
environment from exposure to radionuclides and chemicals for both present and future uses at the
site. The results of the BRA were developed using the EPA required reasonable maximum exposure
concentrations (representing the highest expected exposures) of the contaminants present at the site.
The modeled risk estimates were then compared to an EPA-established "target risk range" for
incremental cancer incidence (ie, the excess probability that an individual would develop cancer over
a lifetime as a result of being exposed to the contamination at the site) to determine if remediation
is warranted. A cancer risk greater than 10"4 or a hazard index (HI) greater than 1.0 are generally
considered unprotective and require action. His are calculated using reference doses and represent
the possibility of developing non-cancer health effects. A hazard index of less than one indicates
no adverse noncarcinogenic health effects are expected due to site contaminants.
The BRA used the available analytical data to characterize the risks associated with the
SLDS. Data were obtained on organic and nonradioactive inorganic chemicals and radionuclides
irrespective of whether they were associated with MED/AEC uranium activities. Limited ground-
FUS208P/072398 31
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water data for the SLDS were evaluated without regard to background levels in ground water; this
may have resulted in the BRA analysis overestimating the number of site-related anthropogenic and
naturally occurring contaminants of concern. Consequently, this could have resulted in elevated risk
estimates.
6.1 CONTAMINANTS OF CONCERN
The principal risk concern at the SLDS is exposure to radioactivity. There are three decay
series that must be considered; U-238, Th-232, and U-235 (ie, the uranium, thorium, and actinium
decay series, respectively). Radiological COCs were derived from these decay series based on their
presence on the site and associated risk. As there are many progeny within the decay series. EPA
Slope Factors derived in accordance with Risk Assessment Guidance for Superrund include short-
lived progeny as a plausible upper-bound estimate of the probability of a response per unit intake of
a chemical over a lifetime. The slope factor is used to estimate an upper-bound probability of an
individual developing cancer as a result of a lifetime of exposure to a particular level of a potential
carcinogen for radionuclides. The slope factors for radionuclides incorporate applicable radioactive
decay and ingrowth of radioactive decay products.
Table 6-1 identifies the Preliminary Remediation Goals for potential non-radiological COCs
developed specifically for the SLDS using EPA guidance. The FS identified four potential, non-
radioactive COCs: arsenic, cadmium, copper, and nickel. Derivation of chemical COCs was
accomplished by definition of the scope of MED/AEC actions at the SLDS including assessment of
ore constituents and materials used in the processing of the ores to extract uranium. The
concentration and distribution of potential COCs derived within the scope of the remediation were
then compared to applicable CERCLA risk criteria based on the anticipated future industrial land
use. Cadmium and arsenic were retained as COCs based on this process with emphasis on potential
risk at the site. Additional evaluation eliminated nickel and copper as COCs as they are not of
sufficient concentration, distribution, and toxicity to be considered COCs. Although TCE was not
identified as a PCOC in the FS, the same rationale applies. Uranium, although addressed primarily
due to its radiological characteristics, also presents chemical (heavy metal) risk to the kidneys and
is retained as both a radiological and non-radiological COC.
Table 6-1. Risk-Based Soil Concentrations for Industrial/Construction
Workers in the Workplace: St. Louis Downtown Site
Chemical
Arsenic
•Cadmium
•Uranium
Risk-based soil concentrations (Cancer Risk/Hazard Quotient) (nig/kg)
10-6/.!
0.69/5.7
1.7
150
10'Vl
6.9/57
17
1.501
IO"/3
69/171
52
4.504
Concentrations shown here exceed those indicated in the FS due to FS use of an erroneous soil ingestion rate of 480 rug/day rather
than the correct value of 136 mg/day. PRGs for carcinogens are the lower of carcinogenic and noncarcinogenic values based on either
risk of !E-6oraHI of 1. Final soil cleanup levels are presented in Section 9, The Selected Remedy of this Record of Decision.
•Uranium and cadmium concentrations are for noncarcinogenic effects. Cadmium is not carcinogenic for oral or dermal exposures
and inhalation would not result in risk above the NCP threshold for this site. Carcinogenic effects of uranium are addressed \Mih
radiological PRGs and cleanup levels.
FUS208P/072398 32
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In summary, this ROD addresses both chemical and radiological contaminants.
Radiological COCs for the SLDS consist of U-238 and its daughters, especially Th-230 and Ra-226.
U-235 and its decay products, including protactinium-231 and actinium-227, and Th-232 and its
progeny. Chemical COCs are cadmium, uranium and arsenic. Other constituents were detected and
are being addressed pursuant to other environmental remediation processes and/or efforts.
6.2 BASELINE RISK
Three exposure scenarios were evaluated using baseline data from the St. Louis Downtown
Site and are summarized in Table 6-2 to demonstrate the need for action. Baseline is defined here
as the site characteristics prior to remediation. The scenarios include a future resident (future
plausible, but unlikely, potential receptor), a commercial/industrial worker (current and most likely
future receptor), and a construction worker (plausible worker conducts infrequent deep soil
excavations). It is the commercial/industrial scenario which is considered to be the reasonable
maximum exposure. The commercial/industrial worker is a full-time on-site employee who
periodically performs subsurface excavations. The construction worker is an individual who
receives a one time exposure to deep materials. Table 6-2 summarizes risk calculations for each
receptor. Results for the residential scenario include information from the BRA (DOE 1993) that
represent exposure over the entire site. The residential scenario is provided for the purpose of
comparison only because the selected remedy assumes that the site will remain an industrial facility
under institutional control. Exposure pathways for the resident include external gamma, soil
ingestion, dust inhalation, and ground water consumption. Results for the commercial/industrial' and
construction workers are taken from the FS and include the results from the highest risk estimates
from an assessment of six exposure units. The BRA did contain an evaluation of potential risks to
an industrial worker and a construction worker. This evaluation was updated in the FS using site-
specific information that was not available during the BRA. Exposure pathways for the
commercial/industrial and construction workers include external gamma, soil ingestion. and dust
inhalation. Risk calculations assume reasonable maximum exposure conditions that tend to
overestimate actual risk.
Table 6-2 lists the risks to potential receptors from the primary radiological and non-
radiological MED/AEC related COCs including actinium- (Ac) 227, protactinium- (Pa) 231. Ra-226.
Th-230, Th-232, U-238, arsenic, and cadmium (note that uranium is listed as a radionuclide and a
chemical because it is both a carcinogenic and toxic hazard). Also listed are the pathways that create
the largest hazard as measured by the hazard index.
Results indicate that the radiological constituents contribute the most significant risk to
potential receptors at SLDS. In the unlikely event the site reverts to residential use, the total risk is
estimated as approximately 2 x 10"2. Assuming the site remains an industrial facility (the intended
land use), a commercial/industrial worker could receive a lifetime risk of approximately 5 x 10"J and
a construction worker that digs into site soils could receive a lifetime risk of approximately 9 x 10"1
if existing worker protection programs are discontinued. All baseline risk estimates exceed the
CERCLA target risk range of 10"4 to 10"6. Results from hazard index estimates indicate that the
target hazard index of 1.0 would be exceeded under the residential scenario (HI = 18) and
commercial/industrial scenario (HI = 2.3).
FUS208P/072398 33
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Table 6-2. Baseline Risk at SLDS
Baseline Risk for Radionuclides by Exposure Scenario
Analyie •
Ac-227
Pa-23 1
Ra-226
Th-230
Th-232
U-238
Primary Pathway b
Inhalation
Inhalation
External gamma
Inhalation
External gamma
Inhalation
Total Risk from Radionuclides
Residential c
I x 10°
3 x 10"
1 x 10'2
1 x 10"
2 x 10°
1 x 10°
2 x lO'2
Commercial/Industrial d
1 x 10"
8 x 1Q-"
2 x 10'3
2 x 10"
1 x 10"
2 x 10-3
5 x 10° '
Construction °
3 x 10'"
3 - 10's
3 - lO*
2 •- 10'
4 x ID'"
9 > 10'4
9x IO"1
Baseline Risk and (Hazard Index) for Non-Radionuclides by Exposure Scenario '
Arsenic
Cadmium
Uranium
Ingestion
lngestionf
Ingestion
Total Carcinogenic Risk from
Chemicals
Total Hazard Index (HI)
3x 10° (12)
1 x |0-'(0.3)
See above (6)
3 x 10°
(18)
5 x 10'5(0.3)
9x.lO-"(0.005)
See above (2)
5 x lO'5
(2.3)
3 * 10':(«0.01)
2 x IO-'°(«O.OI)
See above (0.01)
3 x 10':
(0.01)
Total Carcinogenic Risk from All Radiological and Non-Radiological Sources *
Total Carcinogenic Risk
2 x lO'2
5 x 10°
9 x lO"1
' Includes relevant decay products and associated radionuclides. For example, Pb-210 is included with Ra-226:
Ra-228 and Th-228 are included with Th-232; and U-234 and U-235 are included with U-238.
" Pathway resulting in largest contribution to risk or hazard index is listed. Pathways include direct gamma, soil
ingestion, dust inhalation, and ground water ingestion (resident only).
c From the Baseline Risk Assessment (DOE 1993)
"From the St. Louis Downtown Site Feasibility Study (USAGE 1998). The Baseline Risk Assessment also included
industrial and construction scenarios. Those scenarios, however, were revised for the Feasibility Study to
incorporate site-specific information not available at the time of the Baseline Risk Assessment. Six exposure units
were evaluated in the Feasibility Study. The highest (most conservative) risk from those exposure units is listed for
the commercial/industrial and construction workers.
'.The hazard index is provided in parentheses ( HI)
f Cancer risk for Cd from inhalation pathway only. The primary ingestion pathway is due to noncarcinogenic
efforts.
•The total carcinogenic risk is provided here as per OSWER Guidance Directive 9400.4-18.
All risk estimates are rounded to one significant digit. Reported values may contain round-off error.
Ground water beneath the site is not currently used for any purpose and, after 45 years since
uranium production ceased, does not contain hazardous levels of the COCs addressed in this ROD
in the potentially usable B Unit.
The substantial variations in correlations between Ra-226 in soil and Rn-222 preclude
accurate modeling of indoor radon in industrial structures especially if such structures do not have
basements. No buildings currently exist within the OU. Actual radon concentration anticipated in
structures to be built on site are currently indeterminate but could be significant. Radon
concentrations must, therefore be measured in any such structure and the associated risk assessed
individually based on such measurements after buildings they are constructed.
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6.3 ECOLOGICAL RISK
An ecological risk assessment was conducted to evaluate potential effects from
contamination at SLDS. Due to the urban environment, the SLDS has limited wildlife habitat and
biotic diversify. The ecological assessment compared contaminant concentrations detected in
various media (soil, sediment, and water) at the site with literature on contaminant toxicity to biota.
This study indicated that only arsenic, thallium, and PAHs are at concentrations in soil that could
potentially impact biota, and of these, only arsenic could be associated with uranium ores or uranium
processing. Since habitats are unlikely even in the future, the ecological assessment concluded that
the significance of the St. Louis site with regard to ecological resources is minimal, and that potential
human health effects would determine the need and levels for cleanup (DOE 1993).
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7. DESCRIPTION OF ALTERNATIVES
A Feasibility Study was prepared to evaluate potential remedial action alternatives for the
SLDS. Remedial alternatives were evaluated in accordance with the requirements of CERCLA. as
amended by the Superfund Amendments and Reauthorization Act (SARA), and the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). The evaluation of remedial action
alternatives for the site included identifying remedial action objectives specific to the contaminated
environmental media, identifying general response actions (GRAs) required to attain the remedial
action objectives for the site, identifying and screening technologies and process options applicable
to these GRAs, and evaluating the screened process options with regard to their effectiveness.
implementability, and cost. The purpose of the final screening step was to develop a set of site-wide
alternatives for detailed analysis.
Modeling indicates that loss of current controls would present an unacceptable risk to
industrial/construction workers, although actual current risks at SLDS are protective for on-site
industrial workers. The risks from MED/AEC contaminants, primarily radionuclides, must be
addressed to eliminate direct contact of on-site industrial/construction workers with surficial
contaminants, since risk could be expected to exceed CERCLA protectiveness criteria. Further, the
residual site risk from the anticipated industrial land use, including excavation of soils in support
of on-site construction and development, must be protective under CERCLA.
7.1 REMEDIAL ACTION OBJECTIVES
Remedial action objectives specify unit-specific contaminants, media of concern, potential
exposure pathways, and remediation goals. Remedial action objectives are based on the nature and
extent of contamination, threatened resources, and the potential for human and environmental
exposure. Throughout the characterization process, preliminary remediation goals are modified as
information concerning the unit and potential remedial technologies becomes available. Final
remediation goals, which establish acceptable exposure levels protective of human health and the
environment, are determined when the remedy is selected.
Media-specific remedial action objectives were developed for SLDS for soil and ground
water. In general, mitigation of the exposure pathways of concern and compliance with ARARs
provide a framework for media-specific remedial action objectives. Media-based remedial action
objectives are discussed below. Potential environmental pathways warranting mitigative measures
are:
• Direct contact with soils through ingestion and dermal contact,
• External gamma radiation from the surface soil (Risks are minimal for gamma radiation
from subsurface soil containing radionuclides based on the shielding provided by clean
surface soils.),
• Inhalation of fugitive dust and radon gas emissions from soils, and
FUS208P/072398 37
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Ingestion of ground water. The risk from this exposure is remote since existing impacts
do not affect usable ground water and migration to potentially usable ground water is not
expected. Ground water is not currently used as a potential drinking water source.
ground water is of poor quality, yields in the bedrock are poor, and the area has abundant
surface water which makes future ground water use unlikely. This site is being
remediated for industrial land use. Many of the anthropogenic compounds detected in
the A Unit are not found in the B Unit suggesting little or no migration from the A Unit
is occurring.
Soils at SLDS were characterized in the BRA as posing potentially unacceptable risks to
human health and the environment due to the following MED/AEC related radiological COCs:
Th-230, Th-232, Ra-226, Ra-228, U-235, U-238, and their respective radioactive decay products.
Non-radiological COCs that may have been introduced by MED/AEC operations include arsenic and
cadmium in uranium ore processing areas. The primary contribution to risk from uranium at this site
results from its radioactivity. However, because uranium is a toxicant in addition to being a
radionuclide, it is included in both the radiological and non-radiological categories. Remedial
alternatives developed to address contamination in soils should consider elimination or mitigation
of the exposure pathways listed above as well as compliance with guidelines (Table 7-1).
Table 7-1. Remedial Action Objectives for Remediation of the SLDS Operable Unit
Medium
Soil
Ground water
Remedial Action Objective
Prevent exposures from surface residual contamination in soils greater than the criteria
prescribed in 40 CFR Part 192
Eliminate or minimize the potential for humans or biota to contact, ingest, or inhale soil
containing COCs
Eliminate or minimize volume, toxicity, and mobility of impacted soil
Eliminate or minimize the potential for migration of radioactive materials offsite
Comply with ARARs
Eliminate or minimize potential exposure to external gamma radiation
Remove sources of COCs in the A Unit
Continue to maintain low concentrations of OU COCs in the B Unit
7.2 GENERAL RESPONSE ACTIONS (GRAs)
The toxicity of radionuclides cannot be reduced through treatment and treatment for
stabilization and volume reduction purposes has not been found to be effective in this case.
Therefore, GRAs considered for SLDS are limited to no action, institutional controls, containment,
excavation and disposal. Excavation and disposal could be implemented based on unrestricted future
land use or based on anticipated future industrial land use with numerous possible variations of each
of these general approaches, predicated on CERCLA modifying criteria including community and
FUS208P/072398
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state participation. Each action may include several technology options. The GRAs are structured
to achieve protectiveness for human health and the environment and applicable remedial action
objectives.
Remedial action technologies that could be used to implement GRAs were identified and
evaluated in detail in the Initial Screening of Alternatives (ISA) report for the St. Louis site (DOE
1992). The ISA, which is one of the St. Louis site's primary CERCLA documents, was prepared
prior to the FS for the purpose of performing an initial screening of the available technologies for
the contaminated media. In the ISA the universe of available technologies was narrowed to only
those applicable to St. Louis site media, contaminant types and concentrations, and site-specific
conditions. Chapter 2 of the ISA presents the remedial options considered along with a short
description of the process option and evaluation of the available technologies effectiveness.
implementability, and cost. Although not specifically called a technology, replacement of
contaminated material with clean fill effectively blocks the gamma pathway. Fifteen to thirty
centimeters (6 to 12 in.) of fill, reduces gamma radiation of the energies involved to essentially
nondetectable levels. These factors are considered as follows:
• technologies are evaluated for effectiveness in terms of protecting human health and the
environment in both the short-term and the long-term, and in reducing contaminant
toxicity, mobility, and/or volume;
• technologies are evaluated for implementability in terms of technical feasibility.
administrative feasibility, and resource availability; and,
• technologies are evaluated for cost in a comparative manner (ie, low, moderate, or high)
for technologies of similar effectiveness or implementability.
The ISA document identifies potentially viable technologies and processes retained for
consideration as components of the media-specific alternatives. Retained technologies are
subsequently combined to form a broad range of alternatives for each medium. In the ISA, Chapter
3 identifies the alternatives that were considered for further evaluation during the FS development
and screening of alternatives.
7.3 REMEDIAL ACTION ALTERNATIVES
Remedial action alternatives for the OU were evaluated using the criteria established under
CERCLA to assure that the remedial action is protective of human health and the environment.
Sitewide alternatives were developed to cover a wide range of options that address the source media
of concern for the SLDS and provide overall protection of human health and the environment. A
"no-action" alternative was evaluated in accordance with CERCLA to provide a baseline for
comparison.
Given that excavation and remote disposal is generally the only viable option for the SLDS
and that cleanup level is the only major variable left to evaluate, Alternatives 4, 5, and 6 below were
developed essentially from the same general alternative, i.e., excavation and remote disposal. It was
considered appropriate in this case to compare varying degrees of excavation.
FUS208P/072398 39
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Sitewide remedial action alternatives for the SLDS selected for detailed evaluation are:
• Alternative 1 - No Action
• Alternative 2 - Institutional Controls and Site Maintenance
• Alternative 3 - Consolidation and Capping
• Alternative 4 - Partial Excavation and Disposal
• Alternative 5 - Complete Excavation and Disposal
• Alternative 6 - Selective Excavation and Disposal
To make costs comparable across all alternatives, the cost of addressing inaccessible soils
is included in the costs for Alternative 3,4, and 6, although this in not actually a part of the scope.
All of the action alternatives are considered protective of ground water and include the
implementation of a long-term ground-water monitoring program to demonstrate the effectiveness
of the source removal action. Agreements with the state and local water authorities to restrict the
installation of wells within a specified area could be used to control ground water use.
The sitewide remedial alternatives are described in detail in the FS, which is available in the
Administrative Record File, and summarized in the following sections. The various components of
the remedial action alternatives discussed here are considered representative of the general
technologies that define the alternatives.
7.3.1 Alternative 1 - No Action
The no-action alternative was developed to provide a baseline for comparison with other
alternatives in compliance with CERCLA requirements. This alternative consists of performing no
remedial actions and maintaining a "status quo" at the site. Therefore, no soil would be removed.
Buildings and structures would continue to be used and operated as is currently being done; and
routine monitoring of air, buildings, ground water, and storm water, would continue. The NCP
requires that a No Action alternative be included to serve as a basis for comparison with other
alternatives.
Alternative 1 does not comply with ARARs. Residual radionuclide concentrations in soil
would continue to exceed guidelines. No reduction of risk would be realized under the No Action
alternative.
The present value for Alternative 1 would be approximately $22 million.
7.3.2 Alternative 2 - Institutional Controls and Site Maintenance
Under this alternative, institutional controls and site maintenance would be implemented to
prevent significant exposure to site contamination. Institutional controls would include land-use
restrictions, maintenance, and ground-water use restrictions through ground-water use advisories.
Missouri regulation could be used to limit drilling wells for drinking water in areas of known
contamination. Site maintenance would include surveillance of land, restricted ground-water use,
environmental monitoring of affected media, and implementing minimal engineering controls such
FUS208P/072398 40
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as radon abatement. Site security, including fences and signs, is already maintained at most of the
SLDS properties, including 24-hour security at the Mallinckrodt, Inc. Plant. Mallinckrodt's health
and safety plan would continue to protect onsite employees. Barriers, such as fencing and posted
signs, would be employed at other areas such as the city property and accessible areas of VPs.
The objective of environmental monitoring is to measure contaminant concentrations.
location, and movement. The B Unit would be monitored for OU COCs. A long-term monitoring
plan would be developed to measure the effectiveness of passive collection systems for newly
constructed buildings.
This alternative would be protective of human health and the environment and comply with
ARARs as long as institutional controls are maintained. The 30-year cost for Alternative 2 would
be approximately $29 million.
7.3.3 Alternative 3 - Consolidation and Capping
Soil excavated to composite criteria (ARAR-based) as defined in Section 7.3.7 would be
consolidated and covered with a low permeability cap at a suitable location onsite. The property
associated with the consolidated pile would be acquired by the federal government. Either the city
property or the area formerly occupied by the 50 series buildings at Plant 2 could be used. Plant 2
covers approximately 2 hectares (5 acres). To determine costs, it was assumed that the cap would
be low permeability and consist of all-natural materials, no synthetic liners or other man-made
materials.
The potential for subsidence over the proposed area to be capped would be evaluated during
remedial design. Remedies to prevent uncontrolled subsidence would be employed as required to
stabilize the cap area. Costs for these actions are included in the Alternative 3 cost analysis.
A long-term management plan would be developed to address notification requirements for
property.owners as well as monitoring and maintenance requirements into the future. This plan
would include provisions addressing how property owners should contact the agency responsible for
long-term control of impacted areas and how these areas will be reviewed, maintained, and
monitored by the federal government after completion of Alternative 3.
The cap system reduces the potential for human exposure, for migration of contaminants into
surface water and ground water, and for generation of fugitive dust. Capping is an effective means
of preventing human exposure to underlying contaminated materials.
Alternative 3 would be protective of human health and the environment and comply with
ARARs through use of institutional controls to restrict and regulate access to capped soils.
The 30-year cost for Alternative 3 would be approximately $100 million. This cost includes
the inaccessible soil and building decontamination in order to provide comparability across the
alternatives.
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7.3.4 Alternative 4 - Partial Excavation and Disposal
This alternative includes excavation of accessible contaminated soil on the Mallinckrodt
property to two feet and on VPs to depth based on the composite criteria (ARAR-based). Soils on
the Mallinckrodt property from two feet to depth are excavated to site specific deep soil risk based
removal criteria. (See Section 7.3.7.1 for derivation of criteria). Residual risk is assessed at each
plant area under anticipated future industrial use of the property. This alternative assumes a periodic
continuing government role to support disposal of soils exceeding the composite criteria (ARAR
based) below 2 feet in depth that are brought to the surface by excavation pursuant to Mallinckrodt
construction efforts on-site. It also assumes site institutional controls and development of a long-
term agreement between Mallinckrodt and the government with respect to responsibilities for
residual soil exceeding the composite criteria (ARAR based).
Alternative 4 would be protective of human health and the environment and meet ARARs
through the use of institutional controls to restrict access to the subsurface.
The 30-year cost for alternative 4 would be approximately $92 million. As with Alternative
3, inaccessible soils and buildings 25 and 101 are included in the estimate. Alternative 4 may
include substantial additional future costs to the government for disposal of soils above composite
criteria (ARAR-based) which are excavated pursuant to construction activities on the Mallinckrodt
property. Inability to accurately define long-term construction activities precludes inclusion of these
potentially significant costs in the cost estimate.
7.3.5 Alternative 5 - Complete Excavation and Disposal
This alternative consists of excavation and off-site disposal of all accessible soils above the
composite criteria (ARAR-based). Chemical COC's that are within the scope of the ROD are also
remediated.
As with Alternatives 3 and 4, excavation of the source material would be protective of the
ground water. A monitoring program for ground water will be established and enforced until
discontinued pursuant to five-year CERCLA reviews. Agreements negotiated with the state and
local water authorities to restrict the installation of wells within a specified area could be used to
prevent unauthorized use of ground water.
Alternative 5 would be protective of human health and the environment and meets ARARs.
The 30-year costs for Alternative 5 would be approximately $140 million, including
inaccessible soils and building decontamination.
7.3.6 Alternative 6 - Selective Excavation and Disposal
This alternative excavates soils to composite criteria (ARAR based) on perimeter VPs, and
Mallinckrodt Plant 7. Plant 10 was previously protectively addressed pursuant to a removal action
to the composite criteria (ARAR based). Within the remainder of the OU, this alternative excavates
accessible soils on the Mallinckrodt property to composite criteria (ARAR based) in the top 4 or 6
FUS208P/072398 42
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feet and to depth to deep-soil criteria (risk based). (See Section 7.3.7.1, Derivation of soil criteria).
This alternative also includes levee property which was previously addressed to protective
recreational use .standards pursuant to a removal action and is not subject to further action under this
ROD. Only approved off-site borrow would be used to fill in the excavation at the perimeter VPs
and in the top 4 or 6 feet across the Mallinckrodt property. Material below the deep-soil criteria
(risk-based) could be used as backfill at depths greater than the composite criteria (ARAR-based)
concentration depth. Thus, below 4 or 6 feet, material below the deep-soil criteria (risk based) would
be replaced with material less than the deep-soil criteria (risk based) provided it does not exhibit a
hazardous characteristic. (Hazardous characteristic tests would be conducted on samples of potential
backfill from each excavation.) Potential ground water degradation would be controlled by: removal
of sources of soil contamination; implementing institutional controls, when applicable; and perimeter
ground-water monitoring in the B Unit to assure post remediation compliance.
For Alternative 6, excavation to the most stringent criteria proceeds to a depth of 6 ft in areas
of the Mallinckrodt portion of the site located west of the St. Louis Terminal RR Association tracks
and at the former locations of Buildings 116 and 117; excavation to the composite criteria (ARAR
based) occurs at other areas of the site to a depth of 4 ft except the Plant 7 area and vicinity
properties where the composite criteria (ARAR-based) are applied to depth.
Alternative 6 is protective of human health and the environment and meets ARARs (see
Section 10). This alternative focuses on minimizing the need for future studies, design, and remedial
actions in addition to protection of human health and the environment relative to Alternative 4.
Deeper excavation to the composite criteria (ARAR based) and use of off-site borrow as backfill
above 4 to 6 foot depths reduces potential risk to personnel supporting ongoing and future excavation
on the Mallinckrodt property and eliminates potential costs to the government for future disposal of
contaminated soil generated during excavation in support of construction. As future construction
activities cannot be fully defined, the anticipated future costs to the government associated with
disposal of these soils cannot be fully assessed at the current time and are, therefore, excluded from
cost analysis. The 30 year cost for Alternative 6 would be approximately $114 million, including
the cost of excavation and disposal of inaccessible soils and the cost of building decontamination.
7.3.7 Derivation of Remediation Criteria
7.3.7.1 Radiological
40CFR192 and criteria contained therein for residual radium and thorium serves as an ARAR
(see Section 10, ARAR analysis). As such, 5 pCi/g of radium or thorium is used as a standard for
these radioisotopes in the top 15 cm (6 inches) and 15 pCi/g of radium or thorium is used in any
subsequent 15 cm (6 inch) soil layer to 1.2 or 1.8 m (4 or 6 ft) for remediation of the site. Based on
contaminant distribution in the subsurface, application of the 15 pCi/g standard is expected to result
in residual concentrations that average below 5 pCi/g, but confirmation of remediation completion
will be in accordance with the 5/15 ARAR or supplemental standards, as appropriate. In conjunction
with the site-specific risk assessment for radium and thorium, USAGE developed site-specific
supplemental standards for U-238 which with Ra-226 and Th-230, represent the major radioisotopes
of interest.
FUS208P/072398 43
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This remedy must also incorporate all radiological contaminants of concern in the OU. To
assure that all potential radiological contaminants of concern are addressed, the BRA Investigation
included all pertinent radionuclides. In particular, rather than assume that Pa -231 and Ac-227 were
in secular equilibrium with their U-235 parent, direct measurements were made of Ac-227. That
data was then compared to other radionuclides to enable derivation of a statistical relationships
between Pa-231, Ac-227, and other radionuclides. Analyses of data supported use of a conservative
1:2.5 ratio for Ac-227 to Ra-226. This approach, together with factors that account for inclusion of
appropriate daughter activity with the parent nuclide, assures that the risk assessment performed to
develop this remedy incorporates applicable radionuclides and activity. Remediation cleanup lev els
are derived for the primary site contaminants Ra-226, Th-230, Ra-226, Th-232 and U-238 as
remediation of these radioisotopes would assure that all radioactive contaminants are addressed
concurrently.
Derivation of cleanup guidelines for U-238 pursuant to 40 CFR 192.21(h) necessitates
determination of the site specific NCP point of departure remediation goal (See Table 7-2) The
combined effects of a number of qualifying factors "including but not limited to exposure factors.
uncertainty factors, and technical factors" are then addressed if required to move away from the
remediation goal point of departure.
Table 7-2. Soil Preliminary Remediation Goals and Risk-Based
Concentrations for Potential Radionuclides of Concern in SLDS Soils Based
on a Long-Term Worker (Industrial/Construction) Scenario
Radionuclide
Ac-227
Pa-23 1
Ra-226+D
Th-230
Th-232+D
U-235
U-238+D
Cancer Risk
1 x 10-' (PRG)
1 x 10»
1 xio-4
3x 10"""
PRG Concentration (pCi/g)
0.2
0.2
-------
Review of the point of departure (10~6) remediation goal for U-238 (2.6 pCi/g) indicates that this
value is within the range of site background concentrations (0.159 to 3.78 pCi/g for 32 sample
detects). The point of departure concentration also presents significant issues with respect to
implementability. To enable field measurement of U-238, preclude the cost for over excavation of
clean soils, and facilitate statistical confirmation of the cleanup, the remediation goal was adjusted
upward to 50 pCi/g. This guideline is protective in that it corresponds to a risk of less than 2 * 105
without regard to clean cover. This value is a valid, supportable remediation criterion for this site
given that actual residual concentrations are generally substantially less than the applicable criterion.
and is further appropriate given the need to minimize over excavation of soils and the associated
costs.
As other nuclides are also present in most cases with U-238 it is necessary pursuant to 40
CFR 192.21 (h) to address the potential health effects of multiple contaminants. To concurrently
address each of the major radionuclides of interest, a sum of the ratios calculation is applied as
follows for Ra-226, Th-230 and U-238, the major radioisotopes of interest at this site:
greater of Ra-226 or Th-230 greater of Ra-228 or Th-232 U-238 , „ . , . .
— *- * (all isotopes above background) < 1
in the top 15 cm (6 in) or
greater of Ra-226 or Th-230 greater of Ra-228 or Th-232 U-238 /n. . . , . ..
+- + (all isotopes above background) < 1
from the 6" to 4 or 6 feet. Taken together, these are called the composite criteria. Soil that meet the
above criteria do not need to be removed.
This approach will result in excavation based on the primary isotope(s) of interest in each
plant area and, given inclusion of U-238 and minimal quantities of Ra-228 and Th-232 on site, is
fully protective and is expected to result in a more conservative remediation than the approach
discussed in OSWER directives.
As previously noted, USAGE also verified the appropriateness of the 5/15 pCi/g criterion for
radium and thorium through a comprehensive review of residual contamination levels for Plant 10
(a portion of the SLDS previously remediated to the 5/15 criterion with a 50 pCi/g U-238 limit), and
comparison of these results with EPA guidance. Table 7-3 presents the residual concentrations of
radionuclides following the Plant 10 removal action.
Review of the data (which includes site background) clearly establishes that contaminant
distribution in Plant 10 was such that remediation to criteria of 5/15 pCi/g for radium and thorium
resulted in residual site, contamination below 5 pCi/g. Use of the 15 pCi/g subsurface standard is
expected to result in a protective residual condition consistent with the land use at this site (USAGE
1998a).
FUS208P/072398 45
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Table 7-3. Plant 10 Post Removal Summary Data
Ra-226 (pCi/g)
Th-230 (pCi/g)
U-238 (pCi/g)
Average
(including
background)
2.0
4.9
20
Std dev
1.9
3.0
35.1
Minimum
0.4
1.4
0.8
Maximum
14
26
290
Averase
Site"
Background
2.8
1.9
1.4
*The standard deviation, minimum and maximum apply to the average residual concentration
including background. Average site background is included for comparison (SAIC 1998). Data
are rounded to two significant figures. Data were averaged over 100 square meters.
•The same uranium criteria as used in the current operable unit was used in the Plant 10 cleanup
(50 pCi/g above background for U-238).
The composite criteria (ARAR based) were developed to address near-surface contaminated soils.
The supplemental standards pursuant to 40CFR192.21 are invoked for contaminated soils at depths
below two feet for Alternative 4 and below 4 or 6 feet for Alternative 6. Deep-soil criteria (risk-
based) were derived to address deep soils which provide a more limited potential for exposure.
Calculation of preliminary remediation goals for radium and thorium in deep soils under the
industrial/construction worker scenario using 1 * 10"6 as the point of departure results in PRGs of
less than 1 pCi/g. Development of a remediation design for cleanup levels in this range presents
significant implementability and practicability problems, e.g. (1) cleanup goals are effectively
indistinguishable from background (2) confirmation becomes statistically complex (3) inability to
accurately measure main radionuclides of interest at concentrations approaching background will
preclude field instruments.
Further, design and implementation factors systematically lead to over excavation and
residual concentrations well below cleanup criteria (see confirmation results of Plant 10 cleanup).
Development of the deep criteria accounts for predictable overexcavation by examining the risks
posed by anticipated residual conditions (see Table 7-4). Application of criteria for radium and
thorium of 50/100 pCi/g for deep soil will result in residual risks that are protective per the NCP risk
range for all exposure units even under the hypothetical assumption that no cover is in place, and will
minimize the amount of "clean" soil that will be excavated and transported offsite for disposal
thereby improving cost-effectiveness. It will also comply with exposure criteria applicable in the
event of loss of site controls.
Uranium cleanup guidelines were developed for deep soil, for soils two feet or more from
the surface under alternative 4 and more than four or six feet under alternative 6, based on the
anticipated continued industrial use of the sites. Use of the 10"6 remediation goal, point of departure
of 2.6 pCi/g would present substantial implementability problems related to field measurement of
concentrations approaching background, statistical comparison with background and costs of
remediation associated with overexcavation of soils. A guideline of 150 pCi/g for U-238 represents
FUS208P/072398
46
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a mid-point (5.7 * 10'5) between 10'5and IO"1 based on the assumption of no clean cover. Use of
150 pCi/g as a remediation goal would, with the existence of clean cover, assure protectiveness
Table 7-4. Industrial/Construction Cancer Risk Assessment Results
in the Top 6 ft of Soil by Cover Depth
Removal Option
Ra-226/Th-230/U-238 (pCi/g)
A: No Removal
B: 200/400/600
C: 100/200/300
D: 50/100/150 (Alt 6)
E: 15/40/100
F: Composite Criteria
(SOR> 1)
Risk by Exposure Unit - No Cover
Plant 1
3.6 x 1C'3
3.3 x 10°
2.7 x IO"
2.7 x 10"
2.7 x 10"
3.5 x 10-'
Plant 2
1.5* 10'2
4.2 x lO^*
3.0 x 10"
1.8x 10"
1.8 x 10"
1.7 x 10"
Plant 6a
2.8 x 10°
5.2 x 10"
6.9 x 10"
2.1 x 10-"
2.6 x 10"
2.3 x 10"
Plant 6b
.7 x 10"'
9.0 x 10"
6.4 x 10"
3.5 x 10-"
3.9 x 10"
3.1 x 10"
Plant 6c
6.2 x 10"
3.0 x IO"
3.0 x 10"
3.0 x 10"
3.0 x 10"
8.6 x 10"'
Plant 7
1.1 x I0':
3.8 x 10°
1.1 x 10°
1.1 x IO0
2.3 x IO'4
2.3 x 10"
Removal Option
A: No Removal
B: 200/400/600
C: 100/200/300
D: 50/100/150 (Alt 6)
E: 15/40/100
F: Composite Criteria
(SOR> 1)
Risk Exposure Unit - 6-Inch Cover
Plant 1
5.4 x 10"
5.0 x IQ-4
3.8 x lO'5
3.8 x lO'5
3.8 x 10"'
5.1 x lO"6
. Plant 2
2.2 x 10°
5.1 x lO'5
4.1 x |05
2.5 x 10's
2.5 x 10'5
2.6 x 10"$
Plant 6a
4.0 x 10"
7.6 x lO'5
1.0 x 10"
3.1 x 1 O'5
4.0 x I0's
3.4 x 10'5
Plant 6b
2.5 x 10"
1.4 x 10"
9.7 x |0'S
5.3 x JO'5
6.2 x JO'5
4.8 x 10"S
Plant 6c
9.5 x |0's
4.8 x 10"S
4.8 x 10s
4.8 x 10"S
4.8 x lO'5
1.3 x ID'5
Plant 7
1.7 x IO'1
5.8 x 10"1
1.7.x IO"
1.7 x 10"
3.6 * 10 •'
3.6 x 10's
Removal Option
A: No Removal
B: 200/400/600
C: 100/200/300
D: 50/1 00/1 50 (Alt 6)
E: 15/40/100
F: Composite Criteria
(SOR> 1)
Risk by Exposure Unit - 2-Ft Cover
Plant 1
1.8 x 10-*
1.6 x 10-*
1.2x 10'7
1.2x JO'7
1.2x JO'7
l.6x 10"'
Plant 2
6.8 x IO*
1.8 x lO'7
1.6 x 10'7
9.7 x 10-'
9.7 x 10-'
9.6 x IQ-1
Plant 6a
1.3 x 10"*
2.6 x lO'7
3.5 x lO'7
1.1 x JO'7
1.5 x lO'7
1.2 x |0'7
Plant 6b
8.5 x lO'7
4.6 x JO'7
3.3 x JO'7
2.0 x 1C'7
2.5 x 10'7
1.9x 10'7
Plant 6c
3.3 x lO'7
2.0 x lO'7
2.0 x 10'7
2.0 x lO'7
2.0 x 10'7
4.6 x 10"'
Plant 7
5.3 x 10'*
1.9 x 10"
6.4 x |0 '•
6.4 x JO'7
1.4 x 10"'
1.4 x JO'7
FUS208P/072398
47
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approaching the-point of departure, especially given comparison between remediation goals and post
remediation concentration.
Derivation of remediation criteria for soils two feet or more below the surface are based on
the sum of Ra-226, Th-230, and U-238 concentrations, the primary radionuclides of interest, using
Table 7-4. It is immediately apparent from this table that protective remediation of Plant 7 due to
risk associated with elevated Ra-226 concentration necessitates use of composite criteria (ARAR
based) to depth. Such remediation assures protectiveness and compliance with standards applicable
in the event of loss of site controls. Remediation criteria of 50/100/150 pCi/g was developed using
the following sum of the ratios in consultation with stakeholders:
Ra-226 Th-230 U-238 , „ . . . . .. ,
+ + (all isotopes above background) <
50 100 150 *
Soil that meets this standard does not need to be removed. It represents a movement away
from the 10'6 point of departure for remediation goals to the range of 2.5 * 10"5 to 5.3 * i Q'5 with a
6 inch cover depending on the plant area.
Giving consideration to applicable clean cover for Alternative 4, use of this criteria would
assure protectiveness given consideration of chemical COCs. For Alternative 6, use of off-site
borrow as backfill to 4 to 6 feet across the site would result in residual site risk of less than the
CERCLA 10-6 point of departure.
To address comments that site-specifically derived remediation goals would be inclusive of
background rather than exclusive of background as shown here, additional risk analysis shows that
addition of background concentrations to the remediation goals would not alter any judgments
regarding the protectiveness of this approach.
7.3.7.2 Derivation of Chemical Remediation Criteria
As a point of departure, preliminary remedial goals were developed for the reasonable
maximum exposure identified in the Feasibility Study (FS) which was more recently developed than
the Baseline Risk Assessment. PRGs were calculated for both carcinogenic risk at a lifetime cancer
risk of 1 x 10"6 (1/1,000,000) and for noncarcinogenic toxic effects at a hazard quotient (HQ) of 1.0
Under the NCP, PRGs may be modified based upon the consideration of appropriate factors
including, but not limited to, exposure factors, uncertainty factors, technical factors and other factors
consistent with the five balancing criteria to determine final remedial goals, so long as the remedy
would still be protective.
Arsenic in surface soil was retained as a chemical of concern because some of the onsite soil
samples contained levels of arsenic above background as well as above risk-based screening
benchmarks. The carcinogenic point of departure PRO was 0.69 mg/kg and the noncarcinogenic
PRO was 15.8 mg/kg. The carcinogenic point of departure of 0.69 mg/kg was considered
FUS208P/072398 48
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unachievable. This concentration is an order of magnitude less than the average site background
concentration of arsenic in surface soils (9 mg/kg). Cleaning up to 0.69 mg/kg is not achievable
because many uncontaminated soils will contain more arsenic than this.
A final cleanup level of 60 mg/kg for arsenic in surface soil was determined based on
considerations consistent with the five balancing criteria. This level is clearly distinguishable from
background and the corresponding cancer risk of 9E-5 is within the protective risk range. Non-
carcinogenic risk is also protective.
Cadmium in soil was retained as a chemical of concern because it was present onsite in
concentrations above average site background {0.75 mg/kg), because some onsite concentrations
exceeded risk-based screening levels, and because cadmium may have been present in some of the
MED/AEC wastes.
Cadmium is not carcinogenic for oral or dermal exposures. The 10'6 inhalation pathway
carcinogenic point of departure is reached at 5.4 mg/kg compared with an HQ = 1 concentration of
1.7 mg/kg. Consequently, 5.4 mg/kg is identified as the PRO for cadmium based on the more
conservative value. This concentration was considered to be unachievable as it is within the range
of measured background values. Therefore, the cadmium cleanup goal was adjusted to the
concentration corresponding to a HQ of 1, yielding a revised surface soil cleanup level of 17 mg/kg
which is also protective of cancer risk at 3.1E-6 which is well below 1E-4, the upper end of the.NCP
protective range. Using this value will assure that the residual soil concentrations of cadmium are
well below 17 and that the residual combined cadmium and uranium concentrations will not exceed
an HI of 1.0.
A similar rationale may be applied to metals in deep soil. Deep soil cleanup guidelines for
arsenic, cadmium, and uranium are based on the anticipated continued industrial use of the site. For
arsenic and cadmium, the deep-soil criteria were based on the construction worker who is exposed
to deep soil as described in section 6.2. The non-carcinogenic effects of arsenic and cadmium
presented greater threats than the carcinogenic effects to the construction worker. The deep-soil
concentrations determined for a hazard index value equal to one were 2,760 and 430 mg/kg for
arsenic and cadmium, respectively. Cleanup of uranium to 150 pCi/g will result in a non-
carcinogenic HQ of less than 0.1. Therefore, addressing uranium as a radiological threat reduces the
non-carcinogenic effects of uranium to negligible values. Since cadmium and arsenic do not affect
the same organs, their respective cleanup criteria for deep soils were established separately and
below the soil concentrations equivalent to HQs equal to one (i.e., 2,500 and 400 mg/kg for arsenic
and cadmium, respectively).
FUS208P/072398 49
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FUS208P/072398 . 50
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8. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The following discussion presents the advantages and disadvantages of the alternatives
described in the preceding section in a comparative fashion, based on specific evaluation criteria
prescribed under CERCLA. This information is used to select a preferred alternative for remediation
of the SLDS.
Each of the remedial alternatives is evaluated using the nine criteria specified in the NCR.
The criteria are derived from CERCLA Section 121. The criteria are:
• overall protection of human health and the environment;
• compliance with ARARs;
• long-term effectiveness and permanence;
• short-term effectiveness;
• reduction of toxicity, mobility, or volume through treatment;
• implementability;
• cost;
• state or support agency acceptance; and
• community acceptance.
The first two criteria are threshold criteria which must be attained by the selected remedial
action. The next five criteria are considered primary balancing criteria, which are considered
together to identify significant tradeoffs and determine the optimal alternative among those having
passed the threshold criteria. The final two criteria are modifying criteria which are evaluated
following public comment on the RI/FS and Proposed Plan. Table 8-1 presents the evaluation of the
remedial alternatives. Summaries of the comparative analysis are provided in this section.
8.1 THRESHOLD CRITERIA
Overall Protection of Human Health and the Environment. This criterion addresses whether
an alternative provides adequate protection of human health and the environment, and describes how
risks posed through each exposure pathway are eliminated, reduced, or controlled through treatment.
engineering controls, or institutional controls. It also examines whether the alternative poses any
unacceptable short-term or cross-media impacts.
Each of the alternatives except no-action (Alternative 1) is protective of human health and
the environment. The degree of protection and permanence of the protectiveness is a function of
whether and to what extent an alternative uses dedicated engineering containment, a removal
strategy, or institutional control strategies. Alternative 1, with contaminated media left in place, is
the least protective. Alternative 2, with contaminated media left in place, is more protective through
the use of institutional controls and site maintenance. Alternative 3 confers more protection than
Alternative 2 through consolidating the soils in a central location and reducing the opportunity for
exposure. Alternative 4 confers more protection than Alternative 3 through removing the highest
FUS208P/072398 51
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c
c/i
KJ
o
oa
Table 8-1. Summary of Comparative Analysis of Site-Wide Alternatives
Criteria
Overall Protection
• Human Health
• Ground water
• Environment
Compliance with ARARs
Long-term Effectiveness
and Permanence
• Magnitude of
Remaining Risk
• Adequacy of Controls
Alternative 1
No Action
Not Protective
Not Protective
Not Protective
Not compliant for
soils
Same as HRA
Existing site
security would
provide limited
control over
exposure
Alternative 2
Institutional Controls/
Site Maintenance
Protective as long as
proposed institutional
controls are maintained
Prevents consumption by
land use restrictions,
drilling restrictions, and
monitoring
Protective
Compliant as long as
proposed institutional
controls arc maintained
Low as long as proposed
institutional controls arc
maintained
Adequate us long as
proposed institutional
controls arc maintained
Alternative 3
Consolidation and Capping
Similar to Alternative 2, but
risk is less if institutional
controls fail because
contaminated area is
consolidated.
Similar to Alternative 2, but
risk is less if institutional
controls fail because
contaminated area is
consolidated.
Protective
Compliant; site-specific
supplemental standards and
institutional controls
invoked for capped area.
Hackfill would need to pass
hazardous characterization
Low as long as proposed
institutional controls arc
maintained; lower than
Alternative 2 if controls fail.
Good
Alternative 4
Partial Excavation
and Disposal
Protective
Protective
Protective
Compliant; hack fill
would need to pass
ha/ardous
characterization
Low
Good
Alternative 5
Complete Excavation and
Disposal
Protective
Protective
Protective
Compliant; backfill would
need to pass ha/ardous
characterization
Low
Excellent
Alternative 6 -Selective
\ Excavation and
Disposal
Protective
Protective
Protective
Compliant; backfill
would need to pass
ha/ardous
characterization
Low
Good
l/l
N)
-------
Table 8-1. Summary of Comparative Analysis of Site-Wide Alternatives (continued)
Criteria
• Reliability of Controls
• Long Term
Management
• Irreversible and
Irretrievable
Commitment of
Resources
Reduction of
Contaminant (overall)
• Volume
• Toxicity -
• Mobility
Alternative 1
No Action
Limited by need for
security
Long-term
management plan;
environmental
monitoring; site
security
Restricted lurid use
None
None
None
Alternative 2
Institutional Controls/
Site Maintenance
Reliable for security as
long as institutional
controls are maintained
Long-term management
plan; environmental
monitoring; site security
,
Restricted land use
None
None
None
Alternative 3
Consolidation and Capping
Reliable for security as long
as institutional controls are
maintained. Better than
Alternative 2 because area to
be controlled is
consolidated.
Long-term management
plan; environmental .
monitoring; site security
Restricted land use at capped
area; fill material; petroleum
None, however, treatment
retained as a conditional part
of the remedy
None
Reduced by the cap
component of disposal
Alternative 4
Partial Excavation
and Disposal
Reliable
Long-term
management plan;
environmental
monitoring; site
security; radiological
restrictions may be
reduced following
remedy selection for
inaccessible soils and
buildings 25 and 101.
Restricted land use at
disposal facility;
restricted to confined
industrial use; fill
material; petroleum
Onsite volume reduced
with offsite disposal
options; however.
treatment retained as a
conditional part of the
remedy.
None
Reduced by removal
component
Alternative 5
Complete Excavation and
Disposal
Reliable
Long-term management plan
environmental monitoring;
site security; only necessary
until remedy for inaccessible
soils and buildings25 and
101 is selected.
Restricted land use at
disposal facility;
fill material; petroleum
Onsite volume eliminated
with offsile disposal options;
however, treatment retained
as a conditional pan of the
remedy.
None
liliminaled by removal
component
Alternative 6 -Selective
Excavation and
Disposal
'.Reliable
Long-term management
plan; environmental
monitoring; site security;
radiological restrictions
may be reduced
following selection of
remedy for inaccessible
soils and buildings 25
and 101.
Restricted land use at
disposal facility;
restricted to confined
industrial use; fill
material; petroleum
Onsite volume reduced
due to offsite disposal;
however, treatment
retained as a conditional
part of the remedy.
None
Reduced by removal
component
-------
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oo
Table 8-1. Summary of Comparative Analysis of Site-Wide Alternatives (continued)
Criteria
Short-term Effectiveness
and Environmental
Impacts
• Protection of
Community
• Protection of Workers
• Environmental Impacts
- Geology and Soils
- Water Quality
Alternative 1
No Action
No additional
health effect
No additional
health effect
Potential
uncontrolled
migration of
contaminants
No adverse effects
beyond baseline
conditions
Alternative 2
Institutional Controls/
Site Maintenance
Protective with controls
Protective with controls
Potential uncontrolled
migration of contaminants
No adverse effects beyond
baseline conditions
Alternative 3
Consolidation and Capping
Minimal short-term risk to
community; protective with
controls; long-term benefit
Short-term occupational risk
to workers; protective with
controls
Short-term soil disturbance
during excavation;
replacement of soil
Short-term minor impacts
during excavation; short-
term impact on surface
water; long-term
improvement in surface and
ground water
•
Alternative 4
Partial Excavation
and Disposal
Minimal short-term
risk to community;
protective with
controls; long-term
benefit
Short-term
occupational risk to
workers; protective
with controls
Short-term soil
disturbance during
excavation;
replacement of soil
Short-term minor
impacts during
excavation; short-term
impact on surface
water; long-term
improvement in
surface and ground
water
Alternatives
Complete Excavation and
Disposal
Minimal short-term risk to
community; protective with
controls; long-term benefit
Short-term occupational risk
to workers; protective with
controls, which may be
discontinued following
removal of inaccessible soil.
Short-term soil disturbance
during excavation;
replacement of soil
Short-term minor impacts
during excavation; short-
term impact on surface water;
long-term improvement in
surface and ground water
Alternative 6 -Selective
Excavation and
Disposal
•
Minimal short-term risk
to community; protective
with controls; long-term
benefit
Short-term, occupational
risk to workers;
protective with controls
Short-term, soil
disturbance during
excavation; replacement
ofsoil
Short-term minor
impacts during
excavation; short-term
impact on surface water;
long-term improvement
in surface and ground
water
-------
c
e/i
ro
o
ea
-o
o
-o
K)
Table 8-1. Summary of Comparative Analysis of Site-Wide Alternatives (continued)
Criteria
- Hiotic Resources
Terrestrial biota
Aquatic biota
- Threatened and
Endangered Species
- Wetlands
- Floodplains
- Air Quality
• Archcological, Cultural,
and 1 listorical
Resources
• Land Use and
Recreational/Aesthetic
Resources
Alternative 1
No Action
No adverse effect
beyond baseline
conditions
No adverse effect
beyond baseline
conditions
No impact
No wetlands
present
No impact
No impact
No impact
Land use continues
but future reuse is
limited
Alternative 2
Institutional Controls/
Site Maintenance
No adverse effect beyond
baseline conditions
No adverse effect beyond
baseline conditions
No impact
No wetlands present
No impact
Improvement with radon
controls
No impact
Land use continues but
future reuse is restricted
by institutional controls
Alternative 3
Consolidation and Capping
Temporary loss of habitat;
long-term benefits due to
removal of contaminant
source; permanent loss of
habitat for disposal location
Minimal adverse effect
during excavation
No impact
No wetlands present
Potential impact over long-
term if levee fails
Short-term increase in
fugitive dust associated with
remediation activities;
improvement with radon
controls
No impact
Restricted land use fur
inaccessible soils and
capped area; restrictions on
ground-water use;
unrestricted land use for
remediated areas
Alternative 4
Partial Excavation
and Disposal
Temporary loss of
habitat; long-term
benefits due to
removal of
contaminant source
Minimal adverse effect
during excavation
No impact
No wetlands present
No impact over long-
term
Short-term increase in
fugitive dust
associated with
remediation activities;
improvement with
radon controls
No impact
Restricted land use;
restrictions on ground-
water use and land use
Alternative 5
Complete Excavation and
Disposal
Temporary loss of habitat;
long-term benefits due to
removal of contaminant
source
Minimal adverse effect
during excavation
No impact
No wetlands present
No impact over long-term
Short-term increase in
fugitive dust associated with
remediation activities;
improvement with radon
controls
No impact
Restricted land and ground-
water use for inaccessible
soils; unrestricted land use
for remediated areas
Alternative 6 -Selective
Excavation and
Disposal
.
i '
Temporary loss of
habitat; long-term
benefits due to removal
of contaminant source
Minimal adverse effect
during excavation
No impact
No wetlands present
No impact over lung
term
Short-term increase in
fugitive dust associated
with remediation
activities; improvement
with radon controls
No impact
Restricted land use;
reduced restriction's
compared to Alternative
4 due to greater depth of
excavation; restrictions
on ground-water use
-------
Table 8-1. Summary of Comparative Analysis of Site-Wide Alternatives (continued)
Criteria
• Sociocconomic and
Institutional Issues
- Community and
Institutional Issues
- Public Services
- Local Transportation
Impacts
• Unavoidable Adverse
Impacts
• Short-term Uses and
Long-term Productivity
Alternative 1
No Action
Conflict with
community.
Inhibits land use.
No impact on
utilities. Low
potential for impact
on emergency
response services.
No impact
Potential risks to
human health and
the environment
posed by site-
related
contaminants
Short-term use
remains; long-term
productivity would
decline with limited
reuse of land
Alternative 2
Institutional Controls/
Site Maintenance
Conflict with community.
Inhibits land use.
No impact on utilities.
Low potential for impact
on emergency response
services.
No impact
All contaminants remain
onsile requiring
institutional controls
Short-term use remains;
long-term productivity
would decline with
restricted reuse of land
Alternative 3
Consolidation and Capping
Near term impact on
community. Allows
development outside of
capped area. Impact on
industrial properties.
Low impact on utilities.
Short-term potential impact
on emergency response
services.
Minor local traffic volume
increased and road
deterioration during
implementation
Potential short-term negative
impact on surface water and
air quality; short-term loss of
habitats and animals;
potential increase in noise
annoyance, fugitive dust and
traffic volume
Short-term use influenced by
remedial activities;
long-term productivity high
for unrestricted areas; cap
reduces long-term
productivity hy restricting
future land use
Alternative 4
Partial Excavation
and Disposal
Near term impact on
community. Allows
development to
proceed. Impact on
industrial properties.
Low impact on
utilities. Short-term
potential impact on
emergency response
services.
Moderate local traffic
volume increased and
road deterioration
during implementation
Potential short-term
negative impact on
surface water and air
quality; short-term loss
of habitats and
animals; potential
increase in noise
annoyance, fugitive
dust and traffic volume
Short-term use
influenced by remedial
activities; long-term
productivity high for
unrestricted areas;
reduced long-term
productivity by
restricting future land
use
Alternative 5
Complete Excavation and
Disposal
Near term impact on
community. Allows
development to proceed.
Impact on industrial
properties until inaccessible
soil remediated.
Low impact on utilities.
Short-term potential impact
on emergency response
services.
Significant local traffic
volume increased and road
deterioration during
implementation
Potential short-term negative
impact on surface water and
air quality; short-term loss of
habitats and animals;
potential increase in noise
annoyance, fugitive dust and
traffic volume
Short-term use influenced by
remedial activities;
long-term productivity high
for unrestricted areas;
restricted at disposal facility
Alternative 6 -Selective
Excavation and
Disposal
,
'
Near term impact on
community. Allows
development to proceed.
Less impact on industrial
properties than
Alternative 4.
Low impact on utilities.
Short-term potential
impact on emergency
response services.
Moderate local traffic
volume increased and
road deterioration during
implementation
Potential short-term
negative impact on
surface water and air
quality; short-term loss
of habitats and animals;
potential increase in
noise annoyance,
fugitive dust and traffic
volume
Short-term use
influenced by remedial
activities; long-term
productivity high for
unrestricted areas; long-
term productivity
enhanced over
Alternative -1
o
00
o
-~l
K)
sO
00
ON
-------
Table 8-1. Summary of Comparative Analysis of Site-Wide Alternatives (continued)
N)
o
00
o
~J
KJ
Criteria
• Cumulative Impacts
IMPLEMENTABILITY
• Technical Feasibility
• Administrative
Feasibility
• Monitoring
COST
• Total Cost
Alternative 1
No Action
None
Feasible
Feasible
Long-term onsite
monitoring
$22 million
Alternative 2
Institutional Controls/
Site Maintenance
None
Feasible
Feasible but requiring
institutional controls such
as rezoning and land use
restrictions
Long-term onsite
monitoring
$29 million
Alternative 3
Consolidation and Capping
Ongoing activities al
Mallinckrodt Inc. in relation
to inaccessible soils. Loss of
use of capped area.
Feasible
Feasible but requires
institutional controls such as
rezoning, land purchases,
land use restrictions.
Long-term onsite monitoring
$100 million
Alternative 4
Partial Excavation
and Disposal
Ongoing activities at
Mallinckrodt Inc. in
relation to inaccessible
soils
Feasible
Feasible but requires
institutional controls
such as rezoning and
land use restrictions.
Long-term monitoring
at disposal facility and
at locations of
inaccessible soils
S92 million
Alternative 5
Complete Excavation and
Disposal
Ongoing activities at
Mallinckrodt Inc. in relation
to inaccessible soils
Feasible
Feasible but requires
institutional controls until
remedy for inaccessible soils
is selected.
Long-term monitoring at
disposal facility and al
locations of inaccessible
soils
SI40 million (overburden
reused)
Alternative 6 -Selective
Excavation and
Disposal
Ongoing activities at
Mallinckrodt Inc. in
relation to inaccessible
soils
Feasible
Feasible but requires
institutional controls
such as rezoning and
land use restrictions.
Long-term monitoring at
disposal facility and at
locations of inaccessible
soils
$1 14 million
(overburden to off-site
disposal)
-------
risk soil from the site. Alternative 6 confers more protection than Alternative 4 by removing
contamination at lower concentrations to a greater depth than Alternative 4. Alternative 5 confers
the most proteclion by removing the most contaminated soil from the site.
Alternatives 4 and 6 rely on continued institutional controls to maintain protectiveness.
Alternative 3 would require permanent institutional controls for the capped area. Environmental
monitoring and institutional controls are used in all alternatives to achieve protectiveness for the
inaccessible soil and buildings 25 and 101 pending the selection of a remedy for these soils and
buildings.
The no-action alternative cannot be implemented at the SLDS because it would not achieve
the threshold criteria of being protective of human health and the environment as required by the
NCP. It is included in the FS to provide a baseline case. Alternative 2 would use institutional
controls to achieve overall protection of human health and the environment from soil and ground-
water contamination. Alternatives 3,4, 5, and 6 would use engineered and institutional controls to
achieve overall protection of human health and the environment from soil and ground-water
contamination.
Under Alternative 5, accessible contaminated materials will be ultimately excavated and
disposed, with the result that institutional controls could be removed in the remediated areas.
Alternatives 2, 3, 4, 5, and 6 will reduce the long-term risks associated with existing MED/AEC
contamination to protective levels.
The transportation of the SLDS waste long distances from the site involves risk of injuries
and fatalities that are much greater than any radiological cancer incidence resulting from these
activities. The risk to the worker and the public from a transportation accident involving serious
injury or fatality increases from Alternative 3, 4, 6 to 5 due to increasing excavated contaminated
soil volume and necessary backfill volume. As the haul distances increase, the risk also increases.
Alternatives 3, 4, 5, and 6 would reduce contaminant mobility by capping or encapsulation
as a component of disposal. Capping or encapsulation would prevent infiltration of precipitation
through contaminated materials. Furthermore, capping or encapsulation would eliminate
contaminant migration by means of wind erosion or surface runoff, and would prevent human
exposure to the waste. Alternatives 3,4, 5, and 6 provide the greatest degree of protection from
residual risk because contaminated materials identified as posing potentially unacceptable risks to
human health and the environment are removed from the site and permanently isolated in an
engineered disposal facility. All current potential exposure pathways are eliminated by these
alternatives.
Alternative 1 does not control ground-water use. Alternative 2 restricts the use of ground
water through use of institutional controls. Alternatives 3, 4, 5, and 6 remove the source of potential
future ground-water contamination from above and below the water table. Alternative 2 is more
effective than Alternative 1 in controlling access to contamination. Alternatives 3,4, 5, and 6 are as
effective as Alternative 2 in controlling access to ground-water contamination and are more effective
than Alternatives 1 and 2 at minimizing potential for future ground-water contamination and are
comparable to each other in this regard.
FUS208P/072398
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Compliance with ARARs. This criterion addresses whether an alternative will meet all
ARARs of Federal and state environmental laws, or provide justification for invoking a waiver.
CERCLA Section 121(d) identifies specific circumstances under which an ARAR may be waived.
However, no waivers would be required for remedial action alternatives discussed herein, except for
the no-action alternative.
Alternative 1 would not comply with ARARs, since radionuclide concentrations in readily
accessible soil would continue to exceed guidelines. Alternative 2 would meet ARARs through
implementation of institutional controls. Alternatives 3, 4, 5 and 6 would comply with ARARs.
Supplemental standards are applicable when it can be demonstrated that remedial action would cause
environmental harm that is excessive compared to health benefits, where remedial action would pose
a clear and present risk of injury to workers, or where cleanup costs are unusually high and
contamination left in place presents no significant exposure hazard. Thus, Alternatives 3, 4. 5. and
6 would achieve ARARs with institutional controls being maintained for inaccessible soils at the site
until a remedy is selected. Ground-water restrictions under institutional controls would cease in
areas where the source term was remediated once protection of human health and the environment
is demonstrated by risk assessment. Accordingly, these alternatives would comply with relevant
standards for restoration of radiologically contaminated sites. Tables 10-1 and 10-2 contain a listing
of ARARs.
8.2 PRIMARY BALANCING CRITERIA
Long-term Effectiveness and Permanence. This criterion addresses the magnitude of residual
risk remaining at the conclusion of remedial activities, and the adequacy and reliability of controls
established by a remedial action alternative to maintain reliable protection of human health and the
environment over time, once cleanup goals have been attained.
Alternative 5 has the highest degree of long-term effectiveness and permanence because
contaminated soils are excavated for permanent disposal at permitted offsite facilities. Alternative
6 has the second highest degree of long-term effectiveness and permanence because the criteria used
for excavation below 4 to 6 feet depth are higher than Alternative 5. Alternative 4 is third because
the higher concentration criteria begins at a depth of 2 feet. Alternatives 4, 5 and 6 rely more on
engineering controls and less on institutional controls for isolating contamination from the
environment. Alternatives 3, 4, 5, and 6 have a high degree of long-term effectiveness and
permanence compared to Alternatives 1 and 2 in terms of residual risk because contaminated soils
are either permanently disposed of onsite or are transported offsite for permanent disposal. The cap
for onsite disposal under Alternative 3 provides isolation of contamination from the environment.
Alternatives 3,4 and 6 rely more on institutional controls and less on engineering controls, therefore
making these alternatives less effective in the long-term than Alternative 5. Alternative 2 has only
a moderate degree of long-term effectiveness and permanence compared to Alternative I due to the
contaminated soils and building materials remaining onsite and the primary use of institutional
controls. Alternative 1, No Action, has low long-term effectiveness and permanence.
Pursuant to SARA, a long-term management plan would be implemented, including reviews
every five years for all alternatives because some radioactive contaminants (ie, soil and/or ground
FUS208P/072398 59
-------
water) would remain onsite. By using institutional controls and ground-water monitoring.
Alternatives 2, 3, 4, 5 and 6 would achieve comparable long-term effectiveness and permanence for
ground water. -
Implementing Alternatives 2 or 3 would result in the permanent commitment of land for
waste disposal. This commitment would occur throughout the SLDS for Alternative 2, and at Plant 2
or the City Property for Alternative 3.
The Alternative 3 onsite cap would cover most of the Plant 2 area. A portion of the perimeter
would need to be used as a buffer zone and the sides of the cap would be sloped to promote drainage.
No other area of the SLDS would sustain a long-term impact as a result of this cleanup action.
Perpetual care would be needed for the committed land because the waste would retain its toxicity
for thousands of years. Thus, the cap would need to be visually inspected, ground water would be
monitored, and the effectiveness of the overall system would be reviewed every five years under
Alternative 3.
Implementing any of the final action alternatives would not be constrained by the availability
of resources or supplies beyond those currently available in the St. Louis area or expected to be
available at the offsite disposal facilities. Consumptive use of geological resources (eg, quarried
rock, sand, and gravel) and petroleum products (eg, diesel fuel and gasoline) would be required for
the removal, construction, and disposal activities for Alternatives 3,4, 5 and 6. Adequate supplies
of these materials are readily available in the St. Louis area and would also be available in the area
of the offsite disposal sites. Additional fuel use would result from offsite transport of the waste.
However, adequate supplies are available without affecting local requirements for these products.
Reduction in Contaminant Volume, Toxicity, and Mobility through Treatment. This criterion
addresses the statutory preference (CERCLA Section 121) for selecting remedial actions that employ
treatment technologies that permanently and significantly reduce toxicity, mobility, or volume of the
hazardous substances as their principal element. This evaluation addresses the anticipated
performance of the technologies that may be employed in achieving these treatment goals. It
includes the amount of waste treated or destroyed; the reduction in toxicity, mobility, or volume; the
irreversibility of the treatment process; and the type and quantity of residuals resulting from the
treatment process.
At this time, treatment is a conditional component of all the retained remedial alternatives
except Alternatives 1 and 2. Even though none of the alternatives offer reduction in contaminant
volume, toxicity, or mobility through treatment, the addition of treatment (if warranted in the future)
could be achieved as an adjunct to Alternatives 3, 4, 5 and 6.
Alternatives 3,4, 5 and 6 would reduce contaminant mobility by disposal of the contaminated
soils. The disposal of the soils under the cap in Alternative 3 would reduce the migration of
contaminants by retarding infiltration into contaminated soil, by preventing fugitive dust emissions.
and by isolating surface runoff from the contaminated media. Offsite disposal for Alternatives 4,
5 and 6 would reduce onsite contaminant volume because contaminated materials would be
permanently disposed of offsite.
FUS208P/072398
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Short-Term Effectiveness. This criterion addresses the effects of an alternative during the
construction and implementation phase until remedial action objectives are met. including the speed
with which the remedy achieves protectiveness and the potential to create adverse impacts on human
health and the environment during construction and implementation. Also included under this
criterion are impacts to soil, water, biotic resources, air quality, socioeconomics. land-use.
aesthetic/recreational resources, and cultural/historical resources.
An increase in the complexity of an alternative typically results in a decrease in short-term
effectiveness because of increased waste handling and processing. Other than Alternative 1.
Alternative 2 is the most effective in protecting the community and workers from short-term impacts
and in achieving implementation because there is no handling nor removal of waste materials.
Alternative 2 requires the shortest time to implement, followed by Alternative 3. Alternatives 4 and
6 would have significantly greater short-term impact than Alternatives 1, 2, or 3 because
contaminated soils would be shipped offsite, constraining the excavation rate. Alternative 5 has the
longest implementation time frame. Alternatives 2, 3, 4, 5 and 6 are comparable in short-term
effectiveness of ground-water contamination control.
With respect to soil excavation, Alternative 3 has a higher degree of short-term effectiveness
compared to the other excavation alternatives, because it requires the minimum amount of handling
or movement of the contaminated soils among the action alternatives. Once the soils are removed
and incorporated into the area to be capped, an initial layer of fill material is deposited on the
contaminated materials. The initial layer of fill material would isolate the workers from the source
material during remedial activities. Dust generated by the earth-moving aspects of the alternative
would be controlled.
Alternatives 4, 5 and 6 offer a moderate degree of short-term effectiveness compared to
Alternative 3 because they would require more time to implement than Alternative 3. The
nonradiological occupational hazards increase significantly for Alternatives 4, 5, and 6. Fugitive
dust generation and increased erosion and silt loading of surface waters are among the most
significant concerns of Alternatives 4, 5 and 6.
Implementability. This criterion addresses the technical and administrative feasibility of
implementing an alternative, and the availability of services and materials required during its
implementation. This evaluation includes such items as the ability to construct and operate the
technology; the reliability of the technology; the ease of undertaking additional remedial actions; the
ability to obtain services, capacities, equipment, and personnel; the ability to monitor the
performance and effectiveness of technologies; and the ability to obtain necessary approvals and
coordinate with regulatory agencies and authorities.
The design, engineering, and administrative requirements of Alternatives 1 and 2 are
essentially negligible. Materials required for the components of these alternatives are readily
available. The remaining alternatives are technically and administratively feasible. The engineering,
design, and administrative requirements increase with the complexity of the alternatives in the
following order: 4, 5, 6 and 3. Alternative 3 has the greatest complexity because of the construction
of the cap in addition to excavation. Except for Alternatives 1 and 2, Alternative 4 is the most
amenable to timely implementation of an expedited remedial approach. It requires the least site
FUS208P/072398
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preparation, provides disposal (without construction of a disposal facility) of a smaller volume than
Alternative 5 or 6, and involves the fewest logistical problems. Alternative 5 is the next best
approach to implementing expedited soil removal. It is less implementable than Alternative 4
because of the-increased volume. Volumes of soil under each alternative are given in Table 8-2.
Alternatives 4 and 6 would require segregating soil below deep-soil criteria and returning this
material to depth. Alternative 3 would remove the same volume of soil as Alternative 5. but the
additional task of design and construction of the liner and cap would delay implementation of
Alternative 3 relative to Alternatives 4, 5 and 6.
Materials and services for the removal of contamination and environmental monitoring
activities for the various alternatives are readily available. The degree of difficulty in implementing
alternatives increases with the amount and depth of contaminated soils to be excavated, the level of
the design/transportation required to dispose of soils in accordance with regulations, and the
time/coordination involved in completing the alternative. The degree of difficulty greatly increases
when the excavation proceeds below the water table. This is due to the excavation of saturated
materials requiring dewatering prior to disposal.
Cost. The comparative analysis of costs examines the differences in capital, operations and
maintenance (O&M), and present-worth values. Costs for each alternative, itemization of individual
components, and the sensitivity analysis for each alternative can be found in Appendix B of the FS.
The total costs for the alternatives increase as follows: Alternatives 1, 2, 4, 3, 6 and 5. The total
30-year costs for the six alternatives are:
• Alternative 1 - No Action $22 million
• Alternative 2 - Institution Controls and Site Maintenance $29 million
• Alternative 3 - Consolidation and Capping $ 100 million
• Alternative 4 - Partial Excavation and Disposal $92 million
• Alternative 5 - Complete Excavation and Disposal $140 million
• Alternative 6 - Selective Excavation and Disposal $114 million
The differences in costs among alternatives are very significant and increase primarily with
the amount of contaminated soil to be excavated. Alternatives 2 and 4 do not include long-term
costs for management of residual contamination which are eliminated by Alternative 5 and addressed
more comprehensively by Alternative 6.
8.3 MODIFYING CRITERIA
State and Community Acceptance. This criterion evaluates the technical and administrative
issues and concerns the State and neighboring communities may have regarding each of the
alternatives.
The St. Louis Site Remediation Task Force requested that remediation at the St. Louis
Downtown Site and the City Levee continue or begin with 'site specific' standards for industrial or
recreational use, respectively."
FUS208P/072398
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GO
oo
T3
o
vD
oe
TABLE 8-2 St. Louis Downtown Site Volumes
(CY insitu)
Volume
Impacted Volume Excavated (Insitu)
Overburden and Overexcavation Volume
Excavated (Insitu)
Total Volume Excavated (Insitu) including impacted
material, overburden, and over-excavation (insitu)
Volume of Below Criteria Excavated Material used
as Backfill
Disposal Volume prior to application of 1.25 swell
factor
Final Disposal Volume
Alt. 1
No Action
0
0 •
0
0
0
0
Alt. 2
Institutional
Controls and
Site
Maintenance
0
0
0
0
0
0
Alt. 3
Excavation,
Consolidation
& Capping
87,900
71.986
159.886
54,406
0'
0*
Alt. 4
Partial
Excavation &
Disposal
44,900
24.259
69.159
15,279
53.880
67.350
Alt. 5
Complete
Excavation &
Disposal
87.900
71.986
159,886
54,406
105.480
131,850
Alt. 6
Selective
Excavation &
Disposal
57.983
42,822
100,805
17,601"
83.204
104,005
OS
* Table shows accessible volumes only. Inaccessible Soils will be disposed of as they become available in the future
'* Alternative 6 below criteria overburden is used only as deep soils backfill with the balance sent to disposal.
-------
A wide spectrum of stakeholders, including MDNR, local governments, federal agencies and
lawmakers, citizen groups, and concerned citizens participated in the review of the proposed plan
for SLDS during the 30-day comment period starting on April 8, 1998 and ending on May 8. 1998.
A public meeting was held on April 21, 1998 to hear comments and answer questions regarding the
SLDS' feasib'ifity study and proposed plan.
State and public comments expressed concern over the protectiveness of Alternative 4 with
respect to workers' health and the consequences of future liabilities Mallinckrodt, Inc. would have
to negotiate as the result of handling and disposing of contaminated soils displaced during future
construction and enhancement projects. Both state regulators and community stakeholders expressed
overwhelming support for Alternative 6, particularly for the increased depth of remediation. It was
asserted that the more extensive cleanup associated with Alternative 6 would not only provide
greater protection of the worker, it would also allow Mallinckrodt the flexibility it needed to expand
and grow, and be a valuable asset to the community without future remediation obstacles. Some
support was also expressed for Alternative 5.
The Missouri Department of Natural Resources commented that:
"The State of Missouri prefers Alternative 6 as the remedy for cleaning up
radioactive contamination at the St. Louis Downtown Site. We believe Selective
Excavation and Disposal provides the best vehicle for attaining the objectives of the
St. Louis Site Remediation Task Force. Only approved off-site borrow should be
used to fill the excavations at the vicinity properties.
We do believe the remediation should clean up to industrial use criteria (he
Mallinckrodt site and 5/15 'any use' levels at any depth for the vicinity properties.
We believe Alternative 6 can be accomplished in a manner that will leave property
owners whole. Such will result in the best response to the federal nuclear weapons
production legacy in this part of the community. "
The community also expressed concern that Alternatives 4 and 6 did not address removal of
all the contamination on Vicinity Properties to the stringent "composite" criteria, regardless of depth.
The reviewers felt that the VP soils need to be remediated to levels which would allow for
unrestricted land-use and soils that are inaccessible at the time of remediation should be managed
with institutional controls until such time as the obstruction is removed. Once the obstruction is
cleared the contaminated soil should be remediated.
Concerns were also expressed regarding contaminated soils remaining onsite under Alternative
3, which involved capping the soils. No State or public concerns were expressed regarding
Alternatives 1 and 2. The Responsiveness Summary in Appendix A discusses and responds to
individual comments received during the public meeting and throughout the comment period.
FUS208P/072398 64
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9. THE SELECTED REMEDY
EPA and the USAGE have determined that Alternative 6 (Selective Excavation and Disposal)
is the most appropriate remedy for this operable unit and ground water and accessible soil at SLDS
based upon consideration of the requirements of CERCLA, the detailed analysis of the alternatives
using the nine criteria, and extensive public participation and comment. This alternative, a
refinement to Alternative 4, makes it unlikely that the federal government will have to manage and
dispose of soil containing residual levels of radioactivity displaced by future industrial construction
and maintenance projects at the SLDS. It also reduces the need for additional risk and fate and
transport studies to demonstrate that the site remains protective.
Several areas of particularly elevated radioactivity exist within the OU, especially where
uranium ore was digested and uranium was extracted. No treatment technology has been identified
that could cost effectively reduce the mobility and toxicity of the radioactivity to acceptable risk
levels, primarily because the toxicity of radionuclides cannot be reduced through treatment.
Treatment is retained as a conditional part of the remedy. Treatment will be fully assessed during
the design phase. If a treatment technology is identified to reduce the contaminant's volume.
toxicity, or mobility and is demonstrated to be cost effective, it may be included as an adjunct to
excavation. The volume and mobility of the contaminants are reduced without treatment by
removing them and disposing offsite in an approved facility. The remedial action's excavation of
soil also mitigates potential adverse health affects from the toxic and carcinogenic nature of the
contaminants.
Approximately 77,000 m3 (100,000 yd3) of soil will be excavated under this remedy. This
includes the excavation of overburden that must be removed in order to access subsurface pockets
of contamination. Approximately 13,000 m3 (17,000 yd3) of this soil will be returned to depths
below 1.2 or 1.8 m (4 or 6 ft) as backfill, because it does not exceed the deep-soil criteria (risk-
based) or exhibit a hazardous characteristic. The remainder of excavated soil will be disposed
offsite. Approved borrow obtained from an offsite location will be used to backfill excavations
above 1.2 or 1.8 m (4 or 6 ft) to grade. [The estimated cost for the remedy for this operable unit is
$114 million.]
Sources of soil contamination within the A Unit's ground water will be removed and water
that must be managed as part of the excavation will be treated and disposed of appropriately.
Ground water in the B Unit is not currently impacted by COCs identified in this remedy.
The goal of the ground-water portion of this remedy is to maintain protection of the
potentially usable ground water (B unit) and establish the effectiveness of the source removal action
in this regard. The strategy to accomplish this goal is to install and monitor perimeter wells on a
long-term basis to demonstrate that there will be no significant impacts from COCs on the
Mississippi Alluvial Aquifer (B Unit). Monitoring will be conducted during and after the source-
term removal. If monitoring of the B Unit shows that the MED/AEC COCs have significantly
exceeded MCLs or thresholds established in 40 CFR 192, a Ground-water Remedial Action
Alternative Assessment (GRAAA) would be initiated. The GRAAA would model and resolve:
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MED/AEC COC fate and transport, risk to the public and environment, practical and efficient
technologies to reduce the COCs, the likely concentration to be removed, the likely concentration
of the COC(s) remaining post-treatment, impact of Mississippi River flooding inflows to the B Unit.
and a recommendation for action in the Mississippi Alluvial Aquifer, the B Unit. The outcome of
the alternative assessment could lead to an action for ground-water improvement within the
Mississippi Alluvial Aquifer. Regardless of whether the GRAAA is implemented, a ground-water
monitoring plan will be developed as part of the remedial design to evaluate the impacts of the
Remedial Action. The goal of the monitoring plan will be to assess the fate and transport of
MED/AEC residual contaminants through and following the Remedial Action. A monitoring
program for ground water will be established and enforced until discontinued pursuant to five year
CERCLA review.
The estimated cost of this remedy is $114 million.
Cleanup levels
The purpose of this response action is to control risks posed by direct contact with soils and
sediments and to maintain low concentrations of MED/AEC COCs in the B Unit's ground water.
(The State of Missouri has designated the B Unit as a potential future public drinking water supply).
The baseline risk established for this site indicates that existing conditions in this operable unit
potentially pose an excess lifetime cancer risk to a commercial/industrial worker of 5 * 10'3 from
direct contact with soil and sediments. There is not a plausible future pathway for ingestion of
currently impacted ground water under the reasonable projected industrial land use, nor do COCs
related to this operable unit currently exist at significant concentrations in the B Unit. The
investigative limits when exceeded trigger the GRAAA are: 50 vg/L for arsenic, 5 /ug/L for
cadmium, or 20 jug/L for total uranium.
This remedy will address soil contaminated with radioactivity, arsenic, and cadmium related
to MED/AEC uranium manufacturing and processing at SLDS. Contaminants mixed or commingled
with these MED/AEC radiological COCs will be removed as a consequence of the remedial action
to address these MED/AEC COCs.
Post-remedial risks for this remedy are presented in Table 9-1 for a commercial/industrial
worker and for a construction worker. These scenarios represent the most likely future land use
scenario: that SLDS will remain an industrial facility under institutional control. Risk estimates
were calculated for the FS and are summarized here assuming that the preferred alternative
(Alternative 6) has been implemented.
The commercial/industrial worker represents a full-time on-site worker that occasionally
excavates into shallow site soils. This worker could be exposed to residual concentrations of
radionuclides that remain under several feet of approved borrow (used as backfill after remedial
actions) or soil near or at the surface that meet the criteria in 40 CFR 192. The construction worker
is an individual that receives a one time exposure to deep materials. This worker could potentially
be exposed to soil excavated to the 50/100/150 pCi/g criteria or to soil remediated to 40 CFR 192
criteria.
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Table 9-1. Residual Risk at SLDS
Residual Risk for Radionuclides by Exposure Scenario
Analyte '
Ac-227
Pa-23 1
Ra-226
Th-230
Th-232
U-238
Primary Pathway b
Inhalation
Inhalation
External gamma
Inhalation
External gamma
Inhalation
Total Risk from Radionuclides
Commercial/Industrial c
> 2-ft Cover
< 10-*
< 10-*
< 10-*
< 10-*
-------
A key component of this remedy, recommended by the community and other stakeholders.
is that approved offsite borrow is to be used to backfill the excavations from grade to 1.2 or 1.8 m
(4 or 6 ft). Greater use of offsite borrow and extending the depth of the composite criteria are the
significant diffeTences between Alternative 4 and the selected remedy. Alternative 6 was selected
as the remedy primarily because it reduced the liability of the .federal government from costs
associated with managing and disposing of soil containing residual radioactivity displaced by future
construction or maintenance projects. The use of this thickness of approved offsite borrow also has
the benefit of reducing the post remedial risk to well below the 1 * 10"6 level for excess cancer
incidences for the commercial/industrial worker. On the rare occasion that a construction worker
works at depths greater than 1.2 or 1.8 m (4 or 6 ft), the excess lifetime cancer incidence risk of that
worker would not exceed 1 * 10"5 for the highest risk exposure unit.
Insufficient data was available in some of the exposure units to support a reasonable
assessment of risk from the chemical contaminants. The excess cancer incidence from arsenic will
be reduced to 9 x 10"5 and cadmium will not exceed a hazard index of approximately 0.9 if it is
assumed that the average concentration of arsenic and cadmium will simply meet the criteria
established for this cleanup. The actual average concentrations remaining after excavation will be
far below these values considering that 1.2 or 1.8 m (4 or 6 ft) of approved offsite borrow will be
used to backfill the excavations.
Note that the exposure scenarios considered in this evaluation represent reasonable maximum
exposure conditions that tend to overestimate actual risk.
The cleanup criteria for this operable unit apply to areas affected by the MED/AEC uranium
manufacturing and processing activities and consist of the following components:
• Excavation of accessible soils according to the ARAR-based composite cleanup
criteria of 5/15 pCi/g above background for Ra-226, Ra-228, Th-232, and Th-230. and
50 pCi/g above background for U-238 in the uppermost 1.2 or 1.8 m (4 or 6 ft)
throughout the OU and at the Perimeter VPs (see section 1.1). See Section 10 for
ARAR determination.
• On the portion of the Mallinckrodt property addressed in the OU, site-specific target
removal levels of 50 pCi/g above background for Ra-226, 100 pCi/g above
background for Th-230, and 150 pCi/g above background for U-238 (50-100-150
guidelines) will be used as the deep-soil cleanup guidelines below 1.2 m (4 ft) in
most areas within the plant boundaries and below 1.8 m (6 ft) as described in Section
7.3.6.
• For arsenic and cadmium:
1) within the upper 1.2 or 1.8 m (4 or 6 ft) of grade, soil concentrations of
arsenic greater than 60 mg/kg and/or cadmium concentrations, greater than 17
mg/kg will be removed, or
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FUS208P/072398
2) below 1.2 or 1.8m (4 or 6 ft) of grade, soil concentrations of arsenic greater
that 2500 mg/kg and/or cadmium are greater than 400 mg/kg will be
removed;
Remediation goals for radiological contaminants are applied to soil concentration
above background consistent with the ARAR (40 CFR 192), from which they derive.
However, addition of background concentrations to these goals would not alter any
judgments regarding protectiveness. Remediation goals for non-radiological criteria
are applied to soil concentrations including background consistent with the NCP.
Compliance with soil contamination criteria will be verified by methods that are
compatible with MARSSIM for soils being cleaned up in the OU effective with
MARSSIM publication. (A representative number of samples obtained in the bottom
of excavations will also be subjected to chemical analysis and comparison to
chemical COCs criteria.);
A post-remedial action risk assessment will be performed to describe the level of risk
remaining from MED/AEC contaminants following completion of remedial
activities;
Final determinations as to whether institutional controls and use restrictions are
necessary will be based on calculations of post remedial action risk derived from
actual residual conditions. Five year reviews will be conducted per the NCP for
residual conditions that are unsuitable for unrestricted use.
Institutional controls may include land use restrictions for those areas having residual
concentrations of contaminants unsuitable for unrestricted use. This determination
will be made based on risk analysis of the actual post-remedial action conditions.
Until a decision is developed to address the ultimate disposition of inaccessible soils,
steps will be taken to control uses inconsistent with current uses and to learn of
anticipated changes in conditions that might make these soils accessible or increase
the potential for exposure. Periodic reviews with affected property owners will be
conducted throughout the duration of active site remediation. For residual conditions
requiring use restrictions after the period of active remediation, coordination with
property owners and local land use planning authorities will be necessary to
implement deed restrictions or other mechanisms to maintain industrial/commercial
land use.
A long-term ground-water monitoring strategy will be implemented to confirm
expectations that significant impacts to the Mississippi Alluvial Aquifer (B unit) will
not occur. Although ground water use in this area is not anticipated, agreements will
be proposed to state and local water authorities to prevent well drilling, which may
be impacted by the surficially contaminated A unit.
Perimeter wells in the Mississippi Alluvial Aquifer will be monitored to determine
if further action will be required with respect to ground water,
69
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Protactinium-231 (Pa-231) and actinium-227 (Ac-227) will be included in the
analyses for the post-remedial action residual site risk; and
• Contaminated sediments in sewers and drains considered to be accessible will be
remediated along with the soils.
During the remedial investigation of the SLDS, sediments containing radioactivity were
found in a small area of the Mississippi River bed. A subsequent investigation could not re-locate
radioactivity on the river bed. Presumably it was carried downstream during high flows. The
location of the river bed where radiological contamination was detected during the remedial
investigation will be revisited and characterized. If radiological contamination criteria established
in this ROD are exceeded, the remediation of the river bed will be addressed under a subsequent
response action . If no contamination is present above the composite criteria (ARAR based), the
remedy will be considered the final remedy for this portion of the site.
Contamination present beneath the existing levee will be addressed in a subsequent response
action. The exposure and land-use assumptions used to remediate the bicycle trail on the strip of
land east of the levee and west of the Mississippi River, were different than the assumptions used
in this ROD. The area standards, as part of interim actions preceding this ROD, were established
after discussions with the St. Louis Site Remediation Task Force. No further action is necessary for
this property, but it is to be included in the post remedial action risk assessment for the OU to
determine whether restrictions will be required on this portion of the site.
No further action is required on City Block 1201 except to include it in the post-remedial
action risk assessment to reconfirm the protectiveness of the removal action there.
Alternative 6 is selected as the preferred remedy for the SLDS. It is protective of human
health and the environment, meets ARARs, and was developed to provide the best balance of
effectiveness, cost, and implementability compared with the other alternatives considered.
Additionally, it addresses more fully the CERCLA modifying criteria of "state and community
acceptance."
All the proposed alternatives are protective of human health and the environment.
Alternative 6 provides more protection than any of the others except for Alternative 5. Alternative 6
removes the contaminated soil to at least the 1.2 or 1.8 m (4 or 6 ft) depth. This depth is needed for
protection of industrial workers during ongoing operations. Only Alternatives 3 and 5 remove deeper
soil from the contaminated locations, however Alternative 3 consolidates the excavated material
under an earthen cap located onsite. This cap would require maintenance and institutional controls
to be effective.
Alternative 6 would comply with applicable and relevant requirements for permissible levels
of residual contamination through a combination of excavation of the contaminated soil above the
human health target risk range, removal of soil above 40 CFR Part 192 requirements within the depth
of plausible intrusion, and institutional controls. Public doses would be less than 25 mrem/yr as
required by 10 CFR 20 Subpart E. Residual risk would be within the CERCLA target risk range.
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Institutional controls would ensure continued protectiveness through digging restrictions and
adherence to federal and state worker safety regulations. Alternative 6 could readily be performed
in accordance with specific ARARs.
The remedial action taken under Alternative 6 would provide a permanent and effective
means of protecting the workers and the public from the residual MED/AEC contaminants in the
soil. The alternative would permanently remove the significant contaminants in the upper 1.2 or
1.8 m (4 or 6 ft) of soil at the site. In addition to removal of contaminated soil, backfilling with 1.2
or 1.8 m (4 or 6 ft) of approved borrow will make exposure to the remaining contaminants unlikely.
The backfill will also shield potential receptors from gamma emissions. Exposure to the material left
below the 1.2 or 1.8 m (4 or 6 ft) boundary, as well as the contaminated soils that are inaccessible.
would be managed by implementing institutional controls and a monitoring program.
Alternative 6 is readily implementable, as are all the alternatives evaluated. The components
of the remedial action use well established site preparation, excavation, and disposal strategies used
at other commercial and CERCLA sites. The occupational and radiological hazards associated with
implementing the remedial action are easily mitigated through the use of protective equipment and
the adherence to OSHA regulations and the approved health and safety plan. The institutional
controls and monitoring programs can be implemented fairly quickly. The materials, as well as
experienced labor resources needed to perform the remedy, are abundantly available. The necessary
permits and municipal approvals are also obtainable with few delays. The overall time to implement
Alternative 6 is not significantly different from the other excavation alternatives.
The cost of Alternative 6 is lower than Alternative 5, the most protective alternative.
Although the cost for the rest of the alternatives are less than 6, they are not as effective in
permanently protecting the current or future land-user. Alternative 3 is only effective as long as the
cap is maintained and institutional controls are enforced. Alternative 4 would leave material
exceeding free release criteria at depths below 0.6 m (2 ft) where it may be inadvertently disturbed
during ordinary renovation and construction activities. In addition to increased risk and dose to the
worker, such intrusions would result in unaccountable future liabilities for waste handling and
disposal. Although Alternative 5 provides the most permanent and most effective protection of
human health and environment, it is not cost effective. The cost benefit trade-off of complete
removal to all depths, as in Alternative 5, is high since only the top 1.2 or 1.8 m (4 or 6 ft) of the soil
has the potential for significant human exposure during the industrial life of the site. Alternative 6
would cost $22 million more than Alternative 4, but the reduction in dose, risk, and future liability
would be substantial. In addition, implementation of Alternative 6 would reduce the probability of
material being brought to the surface where it would impose an increased risk. Alternative 6 was
the preferred remedy of the State of Missouri, Mallinckrodt, and the public though it provides
protectiveness exceeding CERCLA requirements.
Based on the above discussions, Alternative 6 is believed to provide the best balance among
the six alternatives with respect to the NCP evaluation criteria. Alternative 6 is protective of human
health and the environment, compliant with ARARs, implementable, low risk and cost-effective.
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10. STATUTORY DETERMINATIONS
Section 121 of CERCLA requires that all remedial actions shall:
• be protective of human health and the environment
• attain legally applicable or relevant and appropriate standards, requirements, criteria.
or limitations, unless such standard, requirement, criteria, or limitation is waived in
accordance with Section 121(d)(4);
• be cost effective; and
• use permanent solutions and alternative treatment technologies to the maximum
extent practicable.
The manner in which the selected remedy satisfies each of these requirements is discussed in the
following sections.
10.1 PROTECTION OF HUMAN HEALTH AND ENVIRONMENT
Section 121(d)(l) of CERCLA requires remedial actions to attain a degree of cleanup of
hazardous substances, pollutants, and contaminants released into the environment and of control of
further release that, at a minimum, assures protection of human health and the environment. The
selected remedy for this operable unit at the SLDS will protect human health by reducing current
and reasonably anticipated future risks to levels at or below CERCLA acceptable risk criteria.
During remedial activities, institutional controls (e.g., access restrictions) and environmental
monitoring and surveillance activities will be maintained to ensure protectiveness, so that no member
of the public will receive radiation doses above guidelines from exposure to residual radioactive
contaminants.
There are no short-term threats associated with the selected remedy that cannot be readily
controlled and mitigated. In addition, no adverse cross-media impacts are expected from the remedy.
10.2 ATTAINMENT OF ARARS
Section 121(d)(l) of CERCLA requires that with respect to any hazardous substance.
pollutant or contaminant that will remain onsite, remedial actions must, upon completion, achieve
a level or standard of control which at least attains legally applicable or relevant and appropriate
standards, requirements, criteria, or limitations under Federal environmental law or any promulgated
standard, requirement, criteria, or limitation under a State environmental or facility siting law that
is more stringent than any Federal standard, requirement, criteria, or limitation (applicable or
relevant and appropriate requirements or ARARs), unless such standard, requirement, criteria, or
limitation is waived in accordance with Section 121(d)(4). Applicable requirements are those
requirements which specifically address a hazardous substance, pollutant, contaminant, remedial
action, location, or other circumstance found at the site.
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Relevant and appropriate requirements are those requirements which, while not applicable
to a release, are relevant and appropriate to the circumstances of the release. Section 300.400(g)(2)
of the NCP lists various factors to be considered in determining whether a requirement is relevant
and appropriate. "These factors include the purpose of the requirement compared to the purpose of
the CERCLA action, the medium regulated or affected by the requirement compared to the medium
contaminated or affected at the site, and the substances regulated compared to the substances found
at the site.
ARARs have been classified into three types to simplify identification and compliance with
environmental requirements: action-specific requirements, chemical-specific requirements, and
location-specific requirements. Action-specific requirements are those with which design.
performance, and other aspects of implementation of specific remedial activities must comply.
Chemical-specific requirements are media-specific and health-based concentration limits (criteria)
developed for site-specific levels of contaminants in specific media. Location-specific standards are
based on the particular characteristics or locations of the site, such as the presence of wetlands.
floodplains, or sensitive ecosystems or habitats, or places of historical or archaeological significance.
In addition to ARARs, other advisories, criteria, or guidance may be useful in developing
CERCLA remedies. These "to be considered" (TBC) advisories, criteria, or guidance may be
developed by EPA, other federal agencies or states. The TBCs are not ARARs and are not legally
binding. Their use is at the discretion of the lead agency if they would be useful to implementation
of the selected remedy.
USAGE has determined that the following statute and regulations are ARARs, as that term
is defined in CERCLA, for the cleanup of the contamination present at the SLDS. All Federal laws
and regulations pertaining to NEPA are not included as ARARs as the USAGE is following the
CERCLA process which is the functional equivalent to NEPA.
Chemical Specific ARARs
The USAGE identified no requirements directly applicable to the cleanup of MED/AEC-
related radiological contaminants in accessible soils at the SLDS. Regulations promulgated pursuant
to the Uranium Mill Tailings Radiation Control Act (UMTRCA) at 40 C.F.R. Part 192 Subpart B
apply to the cleanup of land and buildings with residual radioactive materials at designated inactive
uranium processing sites. Since the SLDS is not one of the designated processing sites, these
regulations do not apply to the SLDS. However, based upon comparisons of the purpose of these
regulations with the purpose of this operable unit, the medium involved, and the hazardous
substances regulated, the USAGE concludes the standards found in 40 C.F.R. § 192.12(a) for
cleanup of radium-226 in soils are relevant and appropriate to the cleanup of (radium-226) accessible
soils at the SLDS. The areas of the SLDS adjacent to the portions of the site where uranium ores
were digested are similar to vicinity properties of mill tailings sites with respect to the general
distribution of contamination and the mechanism(s) which resulted in distribution of the
contamination. Radium-226 and uranium are the major contaminants under Plants 7 and 2,
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respectively. Adjacent areas are similar to mill site vicinity properties in their proximity to uranium
processing operations and associated migration of contamination from the uranium processing areas.
40 C.F.R. § 192.12(a) establishes cleanup standards for land, defined as "any surface or
subsurface land that is not part of a disposal site and is not covered by an occupiable building. It
provides that remedial actions shall be conducted so as to provide a reasonable assurance that the
concentration of radium-226 in land averaged over any area of 100 square meters (nr) shall not
exceed the background level by more than 5 pCi/g averaged over the first 15 cm of soil below the
surface and 15 pCi/g averaged over 15 cm thick layers of soil more than 15 cm below the surface.
In accordance with OSWER directive 9200.4-18 "Establishment of Cleanup levels for
CERCLA Sites with Radioactive Contamination," the 5/15 pCi/g criteria for residual radium in soil
.are considered relevant and appropriate for SLDS. This site is sufficiently similar to Title I Sites
under UMTRCA for the reasons stated above and in consideration of contaminant distribution.
There is not a significant profile of contamination between 5 and 30 pCi/g in the subsurface and
application of the 15 pCi/g subsurface criterion has resulted in a cleanup below 5 pCi/g. Site
characterization data and general experience in excavation of these materials under previous removal
actions, e.g., Plant 10, verify this result. Remediation of Plant 10 to the 15 pCi/g UMTRCA limit
resulted in residual contamination below the 5 pCi/g. Similarity of the adjacent areas to mill site
VPs when taken with the'existing Plant 10 data (which achieved sub 5 pCi/g post remedial action
soil concentrations for radium and thorium) supports the conclusion that UMTRCA VP criteria apply
and that remediation to a design soil criteria of 15 pCi/g should assure protectiveness of the residual
site.
40 C.F.R. § 192.21 provides for the establishment of supplemental standards in lieu of the
standards in 40 C.F.R. § 192.12(a) under certain conditions. 40 C.F.R. § 192.21(c) provides for such
supplemental standards when the estimated cost of cleaning up a vicinity site is unreasonably high
in comparison to the long-term benefits, and the residual radioactive materials do not pose a clear
present or future hazard. Remedial action is generally not necessary where residual radioactive
materials have been placed semi-permanently in a location where site-specific factors limit their
hazard and from which they are costly or difficult to remove, or where only minor quantities of
residual radioactive materials are involved. Based on site-specific conditions at the SLDS.
MED/AEC- related radiologically contaminated soils beneath 4 or 6 feet, depending upon the
specific location on the Mallinckrodt property, satisfy the criteria for establishment of supplemental
standards. Risk-based supplemental standards were developed as described in section 7.3.7.
40 C.F.R. § 192.02(a) provides that control of residual radioactive materials and constituents
shall be designed to provide reasonable assurance that releases of radon-222 from residual
radioactive material to the atmosphere will not exceed an average release rate of 20 pCi/nr/second
or increase the annual average concentration of radon-222 in the air at or above any location outside
the disposal site by more than one-half pCi/1. These requirements are considered to be relevant and
appropriate to cleanup of accessible soils at the SLDS.
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Radon standards in Subpart B require that, in any occupied or habitable building, the
objective of remedial action shall be to achieve an annual average radon decay product concentration
(including background) not to exceed 0.02 working level. The remedy will satisfy this requirement
for the units that are remediated. Radon in buildings 25 and 101 overlying inaccessible soil will be
controlled through active and passive radon reduction measures until a remedy for the inaccessible
soils unit is selected.
10 C.F.R. 20 Subpart E pertains to the decommissioning of NRC licensed facilities. It provides
standards for determining the extent to which lands must be remediated before decommissioning of
a site can be considered complete and the license terminated. These standards are: unrestricted use -
25 mrem/yr total effective dose equivalent (TEDE) and ALARA; restricted use - 25 mrem/yr TEDE
100 mrem/yr with loss of site controls and ALARA. These standards are applicable to any NRC-
licensed materials commingled with MED/AEC-related wastes subject to this remedial action and
are relevant and appropriate to any FUSRAP materials similar to licensable materials under the
Atomic Energy Act.
Federal and state laws and regulations related to drinking water are not considered to be applicable
or relevant and appropriate to currently impacted groundwater in Unit A beneath the SLDS. For the
reasons summarized in Section 1.2.4, Unit A is not considered a potential source of drinking water.
Use of the Mississippi River alluvial aquifer (Unit B) in this area is not likely; however, MCLs and
the groundwater protection requirements found in 40 CFR Part 192, Subpart A, Table 1, are relevant
and appropriate with regard to evaluation of the need for further study of groundwater in Unit B.
Action-Specific ARARs
UMTRCA, 42 U.S.C. 7901 et. seq., requires the control of residual radioactive material at
processing and disposal sites in a safe and environmentally sound manner. This requirement is
considered relevant and appropriate to the remedial action at the SLDS. The selected remedial action
will provide for the removal of radiological contaminants to a level that protects the public health
and the environment which meets this requirement.
Federal and solid and hazardous waste disposal laws and regulations are considered relevant
and appropriate to any excavated materials that will be reused as fill materials on the site. A
determination will be made as to whether excavated materials are a listed or characteristic RCRA
hazardous waste before the excavated materials are used as onsite fill. The substantive requirements
of the laws and regulations will be met for materials remaining at the site. State regulations
regarding the disposal of radioactive materials in sanitary landfills are not considered to be
applicable or relevant and appropriate.
State regulations pertaining to any state permits for onsite work, are not considered to be
applicable or relevant and appropriate as CERCLA provides in Section 121 (e)(l), 42 U.S.C. 9621
(e)(l), that no federal, state, or local permits are required for the conduct of onsite response actions.
Substantive requirements of such provisions will be implemented as appropriate.
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Federal and State laws and regulations pertaining to Dredge or Fill requirements are not
considered to be applicable or relevant and appropriate because no dredge or fill will be discharged
into or removed"from a wetland and/or waters of the United States as part of the remedial action.
Federal and State laws and regulations relating to drinking water are not considered ARARs
because none of the A unit ground water is currently valuable as a drinking water source.
Monitoring and assessment of the B unit ground water is addressed by the 40 CFR Subpart A.
Table l.asan ARAR.
State regulations pertaining to asbestos are not considered to be applicable or relevant and
appropriate because the response action does not include the removal of buildings.
While Federal and State laws and regulations pertaining to Safety and Health Standards
including, but not limited to OSHA, are not considered ARARs, per se, however, federal contractors
are required to comply with applicable Safety and Health laws and regulations.
Location-Specific ARARs
Federal and State laws and regulations pertaining to the National Historic Preservation Act,
State Historic Preservation Act, Archeological and Historical Preservation Act, and Native American
Graves Protection and Repatriation Act are not considered to be applicable or relevant and
appropriate.
Federal and state laws and regulations and Executive Orders pertaining to Floodplain
Management and Protection are not considered to be applicable qr relevant and appropriate because
the site is not located on a floodplain, as defined by relevant regulations, 40 C.F.R. Part 6, Appendix
A. The existence of a 500 year flood protection structure (the St. Louis floodwall) takes the SLDS
out of the definition of a floodplain.
All Federal and State laws and regulations pertaining to Endangered Species are not included
as ARARs in so far as available data indicates that there are no known endangered species or their
habitats on the site.
Table 10-1 summarizes the chemical-specific ARARs appropriate for cleanup actions at the
site. Table 10-2 summarizes the action-specific ARARs.
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o
oo
o
-j
Table 10-1. Chemical Specific ARARS for the SLDS
Standard, Requirement,
Criteria or Limitation
Uranium Mill Tailings
Radiation Control Act
(UMTRCA) (October
1992): Cleanup of
Radioactively Contaminated
Land and Contaminated
Buildings
EPA Policy directives for
radioactive contamination
Uranium Mill Tailings
Radiation Control Act
Resource Conservation and
Recover)' Act
Citation
40C.F.R.I92.12(a)
40C.FR. 192.21
and 192 22
40C.F.R.
I92.02(b)(l)
OSWKR Directive
9200.4-23
OSWER Directive
9200.4-18
40C.F.R. 192.40,
192.41
40 C.F.R 257-272
Description of Requirement
Residual radioactive material concentration of Ra-226
and Ra-228 in land averaged over any 100 m2 area shall
not exceed the background level by >5 pCi/g averaged
over the first IS cm of soil (6 inches) and IS pCi/g
averaged over IS cm thick layers of soil >I5 cm below
the surface.
Supplemental Standards: Site-specific target removal
levels of SO pCi/g above background for Ra-226, 100
pCi/g above background for Th-230, and 1 SO pCi/g
above background for U-238 (50- 100- ISO guidelines)
will be used as the deep-soil cleanup guidelines below
1.2 m (4 ft) in most areas within the plant boundaries
and below 1.8 m (6 ft) in areas delineated in Section
7.46.
Radon-222 releases not exceeding 20 pCi/m3/sec. or 0.5
pCi/l in air above site
EPA policy for ARAR determination for radioactive
sites.
KPA policy on using 40 C.F.R. Part 192 for CERCLA
cleanup criteria at radioactive sites, including radium
and thorium.
Criteria for sites where thorium ores were processed.
Establishes accountability in handling hazardous waste
from generation to disposal.
ARAR
Status
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
TBC
TBC .
Relevant and
Appropriate
Relevant and
Appropriate
Comment
i i
This ARAR was used for to establish composite
cleanup criteria for radium and thorium soils to a
depth of 4-6 ft.
The provision allowing the development of
supplemental standards under certain conditions was
basis developing deep soil, i.e., greater than 4-6 ft..
criteria.
These directives were consulted in developing
radioactive cleanup criteria because of the similarly
between these sites and the UMTRCA sites.
This regulation was used in developing the thorium
cleanup criteria.
Any excavated materials that remain on site will meet
all ha/ardous waste requirements in addition to ihc
radiological cleanup criteria.
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Table 10-1. Chemical Specific ARARS for the SLDS (Continued)
Standard, Requirement,
Criteria or Limitation
NRC Radiological Criteria
for License Termination
Citation
IOC.F.R.20
Subpart E
Description of Requirement
This rule provides consistent standards to NRC licensees
for determining the extent to which lands must be
remediated before decommissioning of a site can be
considered complete and the license terminated.
ARAR
Status
Applicable
Comment
These criteria would be applicable to any NRC-
liccnsed materials commingled with ME.D/AKC-
related wastes and are relevant and appropriate to
materials similar to Atomic Energy Act licensable
materials.
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Table 10-2. Action Specific ARARS for the SLDS
Standard, Requirement,
Criteria or Limitation
General Prctrcatment
Regulation
Solid Waste Disposal Act,
as amended; Identification
and Listing of Hazardous
Wastes
RCRA Land Disposal
Restrictions
Clean Water Act, National
Pollutant Discharge
lamination System; Water
Quality Standards
Missouri General
Pretreatmcnt Regulation
Missouri Storm Water
Regulations: Surface Runoff
and Erosion Control;
Missouri Storm Water
Discharge Regulations
Standards for Construction,
Monitoring and Plugging of
Wells
Uranium Mill
Tailings Radiation
Control Act (UMTRCA)
(October IW2)
Citation
IOCSR 20-6. 100
40 C.F.R. 260 and
261
40 C.F.R. 268
40 C.F.R. 122-125
IOCSR 20-7.031
(4)(l)
IOCSR 20-6 100
IOCSR 20-6.200
IOCSR 20-6.010(13)
IOCSR 23-3
40 C.F.R. 192.02
fable 1 to Suhpart A
Description- of Requirement
Provides for procedures to prevent the introduction
of pollutants into publicity-owned treatment works
(POTWs).
Provides for identification and characterization of
hazardous wastes.
Provides rule for treatment hazardous waste before
landfilling.
Provide for limitations on point source discharge to
surface water.
Provides for procedures to prevent Ihe introduction
of pollutants into publicity-owned treatment work
(POTWs).
Provides for the use of best management practices to
control storm water, erosion control and sediment
transport.
Provides procedures for constructing, monitoring and
plugging of wells.
Table 1 describes maximum concentrations of
constituents for ground water protection, including
0 05 and 0.01 mg/l arsenic and cadmium, and 5 pCi/l
for radiutn-226 and radium-228 and 30 pCi/l lor
uraniiim-234 and uranium-"2.18, respectively.
ARAR
Status
Applicable
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Applicable
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Comment
To the extent waters are encountered during cleanup,
and disposal to a POTW is chosen, pretreatment
requirements will be met.
These requirements will be used only for purposes of
analyzing suitability of excavated material for backfill
onsite.
These are applicable only for purposes of analyzing
suitability of excavated material for offsite disposal
and for analyzing for backfill onsite.
If a point source discharge is sued to dispose of waters
encountered during cleanup, specific effluent limits
will be established as part of work plans developed
during remedial design or remedial action. 1 lowevcr,
a formal NPDES discharge permit will not be
obtained.
To the extent waters are encountered during cleanup.
and disposal to a POTW is chosen, prelreatment
requirements will be met.
To the extent storm waters are encountered during
cleanup, they will be treated as required to meet
substantive discharge criteria. Substantive surface
control measures will be implemented as appropriate,
although a slate permit, per se, will not be obtained.
Ground water monitoring wells will be installed and
operated consistent with substantive procedures, hut
permits will not be obtained.
Only Table 1 of this regulation is relevant and
appropriate as it provides concentration limits that will
trigger assessment of the H unit ground waicr if
exceeded.
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10.3 COST EFFECTIVENESS
The selected remedy is the most cost-effective of the alternatives because it provides the best
balance between cost and risk reduction. Alternative 6 successfully removes soils above cleanup
criteria in current and potential future use areas, thus eliminating the most likely exposure pathways
without unnecessary removal of soil. Additionally, the selected alternative will minimize liability
associated with future remedial or protective actions necessary to accommodate future operational
activities.
Total present worth cost for the selected alternative is estimated at $114 million. In
consideration of these factors, the selected remedy provides the best overall effectiveness of all
alternatives evaluated proportional to its cost. SLDS has been identified as a possible value
engineering study area. Value engineering studies will be conducted as appropriate in order to
maximize its cost effectiveness.
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES OR RESOURCE RECOVERY TECHNOLOGIES TO THE
MAXIMUM EXTENT PRACTICABLE
The selected remedy for SLDS provides a permanent solution to contamination that currently
exists on these properties. The selected remedy provides the best balance of trade-offs among the
alternatives with respect to the evaluation criteria. The criteria that were most critical in the selection
of Alternative 6 were cost effectiveness and overall protection of human health. Expenditures of
large sums beyond that required by Alternative 6 would result in negligible reduction in dose.
The state, as well as the community, has expressed a strong preference for removal and
out-of-state disposal. The selected remedy meets the statutory requirement to utilize permanent
solutions and treatment technologies to the extent practicable. Treatment has not been demonstrated
capable of achieving cleanup criteria for the SLDS soils. Soils in north St. Louis County have been
tested using soil washing technologies. While high percent removal efficiencies were obtained, the
composite criteria (ARAR based) could not be reached. Thus excavated soil, if treated, would still
need to be disposed offsite following treatment. It is anticipated that sufficient backfill below deep-
soil criteria (risk-based) will be obtained in the upper 4 or 6 feet to completely fill excavations to
those depths without treatment.
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11. EXPLANATION OF SIGNIFICANT CHANGES
The PP provided for involvement with the community through a document review process
and a public comment period. A public meeting was advertised and held on April 21. 1998.
Comments that were received during the 30-day public comment period are addressed in
Appendix A of this Record of Decision.
Review of State and community comments indicates that all respondents preferred
Alternative 6 in lieu of Alternative 4 as stated in the Proposed Plan. Stakeholders consisting of the
State of Missouri, City of St. Louis, County of St. Louis and St. Louis Oversight Committee, and
Mallinckrodt, Inc. were universally supportive of adoption of Alternative 6.
Upon further investigation it was determined that substantial additional costs would expect
to be incurred by the government for Alternative 4 to support future monitoring and disposal
considerations. Depending on the precise nature of Mallinckrodt construction activities, cost
associated with excavation of contaminated soils and related studies may result in long-term costs
for Alternative 4 which equal or exceed those of Alternative 6. This status, together with reduced
operational impacts reduction in residual site risk, and consistent with state and community
recommendations, Alternative 6 was selected. Residual site risks are substantially reduced for both
an industrial/construction worker and for a utility worker due to the increased depth of excavation.
As a result of community comments, the remedy selected was changed to Alternative'6.
Selective Excavation and Disposal. The preferred remedy in the initial draft Proposed Plan was
Alternative 4. Based on public and stakeholder comments, Alternative 4 was not considered to be
sufficiently protective considering the high possibility of construction activities intruding below a
2 foot depth interval. Additionally, concern was expressed regarding the open-ended liability for
handling and disposal of wastes excavated from below 2 feet as a result of future activities.
Alternative 6, as the preferred alternative, satisfactorily addresses these concerns and comments.
Therefore, Alternative 6 was selected pursuant to State and community comments to reduce
future government costs for monitoring; impact and costs of disposal of contaminated soil carried
to the surface by excavation activities; and operational impact on land owner's construction efforts.
Use of Alternative 6 also substantially reduces residual site risks to construction/industrial workers
on the site by minimizing exposure associated with soil excavation and overall access to radioactive
material present in soil.
Building decontamination (buildings 25 and 101) will be included in a separate CERCLA
action. This was done because, like the inaccessible soils, the building remediation would have to
be deferred until the owner makes it available. The buildings and inaccessible soils will be managed
through institutional controls until such time as they are otherwise addressed under a future
CERCLA action. In addition, questions have arisen regarding whether contaminated buildings 25
and 101 may be addressed under CERCLA.
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12. RESPONSIVENESS SUMMARY
Numerous comments were received during the public comment period. In general these
comments indicated overwhelming support by stakeholders for Alternative 6 instead of
Alternative 4.
Many specific technical issues were also identified for consideration by USAGE in
developing the final remedial action design. The complete responsiveness summary to these
comments is provided in Appendix A.
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13. REFERENCES
Argonne National Laboratory 1989. Derivation of Uranium Residual Radioactive Material
Guidelines for-the Three St. Louis FUSRAP Sites: St. Louis Downtown Site. St. Louis Airport Site.
and Latty Avenue Properties. January.
BN1 1990. Radiological, Chemical, and Hydro geological Characterization Report for the St. Louis
Downtown Site in St. Louis, Missouri, Revision 1, DOE/OR/20722-258, Oak Ridge, TN. September.
DOD, DOE, EPA and NRC 1997. Multi-Agency Radiation Survey and Site Investigation Manual.
NUREG 1575; EPA 402-R-97-016, December.'
DOE 1990a. Memorandum. Fiore to Price. Uranium Cleanup Guidelines for St. Louis Missouri.
FUSRAP Sites. November 6.
DOE 1990a. Uranium Cleanup Guidelines for St. Louis, Missouri, FUSRAP Sites, DOE Office of
Environmental Restoration, Division of Eastern Area Programs. November 6
DOE 1990b. Federal Facility Agreement for The United States, St. Louis and Hazelwood. Missouri.
Docket No. VII-90-F-0005. December.
DOE 1991. Engineering Evaluation/Cost Analysis for Decontamination at the St. Louis Downtown
Site, St. Louis, MO, DOE/OR/23701 -02.2. May.
DOE 1992. Final, Initial Screening of Alternatives Report for the St. Louis Site, St. Louis. MO.
DOE/OR/21590-777. October..
DOE 1993. Data Collection Handbook to Support Modeling the Impacts of Radioactive Material
in Soil. ANL/EAIS-8. Environmental Assessment and Information Science Division, Argonne
National Laboratory, Argonne, IL. April.
DOE 1993. Manual for Implementing Residual Radioactive Material Guidelines Using RESR.4D.
Version 5.0: Working Draft for Comment, ANL/EAD/LD-2. Environmental Assessment and
Information Sciences Division, Argonne National Laboratory, Argonne, IL. September.
DOE 1994. Remedial Investigation Report for the St. Louis Site, St. Louis, MO, DOE/OR/21949-
280. January.
DOE 1995. Baseline Risk Assessment for Exposure to Contaminants at the St. Louis Site.
DOE/OR/23 701 -41.1, Argonne, IL. November.
DOE 1996. Post-Remedial Action Report for the Remedial Actions Conducted in St. Louis, Missouri
During Calendar Year 1995. November.
DOE 1997. Post-Remedial Action Report for the Remedial Actions Conducted in St. Louis, Missouri
During Calendar Year 1996. November.
FUS208P/072398
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EPA 1989. Risk Assessment Guidance for Superfund: Volume I: Human Health Evaluation Manual.
Part A, Interim Final. EPA/540/1-89/002. Office of Emergency and Remedial Response.
Washington, D.C. March.
EPA 1989. Exposure Factors Handbook Final Report. EPA/600/3-89/043. Office of Health and
Environmental Assessment, Office of Research and Development, Washington. DC. March.
EPA 1991. Risk Assessment Guidance for Superfund, Volume I: Human Health Evaluation Manual.
Part B, Development of Risk-Based Preliminary Remediation Goals, Interim. EPA/540/R-92/003.
Office of Research and Development, Washington, DC. December.
EPA 1991. Human Health Evaluation Manual, Supplemental Guidance: Standard Default Exposure
Factors. OSWER Directive 9285.6-03. Office of Emergency and Remedial Response, Washington.
DC. March.
EPA 1991. Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions
OSWER Directive 9355.0-30. Office of Solid Waste and Emergency Response, Washington. DC.
April.
EPA 1995. Health Effects Assessment Summary Tables (HEAST). Annual Update, FY 1995.
Environmental Criteria and Assessment Office, Office of Health and Environmental Assessment,
Office of Research and Development, Cincinnati, OH. • 1995.
EPA 1995. Integrated Risk Information System (IRIS). Duluth, MN.
EPA 1996. Reassessment of Radium and Thorium Soil Concentration and Annual Dose Rates.
Office of Radiation and Indoor Air, Washington, DC. July.
Harrington and Ruehle, 1959
Science Applications International Corporation 1998. Memorandum SAIC to USACE. Validated
data results from SLDS background characterization. July.
St. Louis Site Remediation Task Force 1996. St. Louis Site Remediation Task Force Report.
September.
USACE 1998a. Feasibility Study for the St. Louis Downtown Site, St. Louis, MO. April.
USACE 1998b. Proposed Plan for the St. Louis Downtown Site, St. Louis, MO. April.
FUS208P/072398
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APPENDIX A
DETAILED RESPONSES TO COMMENTS
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A-2
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1.0 PUBLIC MEETING COMMENTS
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DETAILED RESPONSES TO COMMENTS
1.0 Public .Meeting Comments
The 30-day comment period for the Proposed Plan for the St. Louis Downtown Site
began on April 8, 1998 and ended on May 8, 1998. A public meeting was held on April
21, 1998 to hear comments and answer questions regarding the SLDS' Feasibility Study
and Proposed Plan. The following comments were taken from the St. Louis Downtown
Site Public Meeting transcript and paraphrased for continuity and clarity. Verbatim
statements by meeting participants, as they appear in the transcript, are written in italic
font.
Comment 1
Commentor:
Comment:
Response:
Mr. Bob Eck. Mr. Eck is the director of the Missouri Department of
Natural Resources, St. Louis regional office. He is speaking on behalf
of the Department Director, Steve Mahfood.
Mr. Eck stated the preference of the St. Louis Site Remediation Task
Force for Alternative 6 and that all backfill should be from approved
offsite borrow locations. Mr. Eck stated,
"The State of Missouri prefers Alternative 6 as the remedy for
cleaning up radioactive contamination at the St. Louis Downtown
Site. We believe Selective Excavation and Disposal provides the
best vehicle for attaining the objectives of the St. Louis Site
Remediation Task Force. Only approved off-site borrow should be
used to fill the excavations at the vicinity properties.
We do believe the remediation should clean up to industrial use
criteria the Mallinckrodt site and 5/15 "any use' levels at any
depth for the vicinity properties. We believe Alternative 6 can be
accomplished in a manner that will leave property owners whole.
Such will result in the best response to the federal nuclear
weapons production legacy in this part of the community
Mr. Eck also expressed his support for the use of institutional controls
"to ensure continued protection until a remedy for inaccessible soils is
developed."
The USACE agrees to select Alternative 6 as the preferred remediation
alternative, instead of Alternative 4. This will be reflected in the
Record of Decision (ROD). This decision is largely due to the
A-5
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Comment 2
overwhelming support for Alternative 6 by the public. Mallinckrodt.
Inc. and local, state and federal government officials. Both alternatives
are protective of the current and future worker and the environment.
However, Alternative 6 reduces radionuclide levels further, thus
providing additional protectiveness relative to Alternative 4. In
addition, this alternative will reduce the need for future studies.
designs, and remedial actions, thus avoiding future potential liability
and costs to the federal government. Alternative 6 also allows
Mallinckrodt, Inc. the freedom to grow and support the local
community without future remediation liabilities.
As stated in the Proposed Plan and the Feasibility Study, Alternative 6
will continue to use soils from onsite removal activities as backfill, as
long as the radiological contamination levels of the soil are less than
ALARA criteria. This soil will only be used as backfill up to depths of
4 or 6 feet, depending on the excavation zone. Only approved borrow
from offsite will be permitted to backfill areas at the vicinity properties
and above 4 or 6 feet at SLDS. This approach is more cost effective
than using offsite soil for all the backfill due to avoidance of disposal
fees and minimizing transport costs for the new soil. Additionally.
clean offsite backfill to depth will provide little or no substantial health
benefits since the backfill areas in question extend deeper than areas
projected to be disturbed by future activities.
In addition to choosing Alternative 6 for implementation, the USAGE
has revised Alternative 6 so the vicinity property soils will be
remediated to levels equal to or less than the more stringent
"composite" criteria regardless of depth. Inaccessible soils on the
vicinity properties will be managed through institutional controls until
a remedy is developed for the inaccessible soils operable unit. This
rigorous level of remediation will allow unrestricted use of the
accessible soils on the vicinity properties.
Commentor: Anna Ginzburg. Ms. Ginzburg represented the Mayor's Office of the
City of St. Louis.
Comment: Ms. Ginzburg read a prepared statement from Mayor Harmon. The
statement was principally in support of Alternative 6 and for the
Mallinckrodt's "outstanding corporate citizenship". The statement
opened,
A-6
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"As Mayor of the dry of St. Louis. I submit (he following
statement in response to the Army Corps of Engineers Proposed
Plan for the downtown site dated April 1998. The Mallinckrodt
site should be cleaned up to the standards laid out in Alternative 6
of the April 1998 Proposed Plan. This alternative is most
consistent with the recommendations of the St. Louis Site
Remediation Task Force which states that the Mallinckrodt
properties should be cleaned up to a depth of 8 feet. Cleanup to
the 4 and 6-foot levels stated in Alternative 6 will allow for the
future development at the Mallinckrodt site. "
The statement went on to praise Mallinckrodt as a "positive presence"
by reading,
"The Mallinckrodt Corporation has displayed outstanding
corporate citizenship throughout the entire cleanup and public
input process. They have made major in-kind contributions of
time, energy and resources moving the site cleanup forward
significantly. The City of St. Louis values Mallinckrodt' s
commitment to the Near North Riverfront area and the other
neighborhoods surrounding its facility.
The plan laid out in Alternative 6 will allow Mallinckrodt to
undertake development and expansion that will help the company
maintain and expand its positive presence. Supporting
Mallinckrodt development plan is a top priority for the City of St.
Louis. "
The Mayor was critical of Alternative 4 because it "does not take into
account the long-term costs related to ongoing oversight and
monitoring for the significant level of contamination that would
remain." And, "// is unfair to assume that Mallinckrodt Corporation
will accept this burden indefinitely."
The Mayor's statement expressed concern for the contamination on the
vicinity properties by stating,
"These vicinity properties include several small businesses, as well
as property owned by the City of St. Louis. The City property is
adjacent to the recently opened Riverfront Trail. It is essential that
this property be cleaned up to standards for unrestricted use in the
near future since it is likely to be frequented by families using the
trail.
A-7
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The cleanup of the businesses included in (he vicinity- properties
must be closely coordinated with the business owners so that
economic activity is not disrupted. The Army Corps of Engineers
should begin negotiations with these businesses in order to develop
a cleanup plan. Under no circumstances should the burden of
cleanup costs or the responsibility for monitoring and oversight of
continuing contamination fall on these businesses.
At a minimum, we need to clean up the vicinity properties to the
same unrestricted use standards that the City, the County and the
State want to see utilized at the Airport Site and adjacent
properties in the much more affluent North County neighborhoods
surrounding the Airport Site. "
Response: Based on public comment, the USAGE has selected Alternative 6 for
implementation, rather than the initially proposed Alternative 4. The
public and stakeholders expressed strong concern that Alternative 4
did not provide satisfactory protection of workers during Mallinckrodt.
Inc. industrial activities. These parties also expressed concern that the
residual contamination left in place below 2 feet represents an open-
ended liability for Mallinkrodt, Inc. with respect to management of
waste soils made available during future activities. It was noted by
commentors that minimizing limitations so Mallinckrodt, Inc. can
freely expand and renovate is of utmost importance to the community
and the local economy. Selection of Alternative 6 as the preferred
alternative provides an additional level of protectiveness relative to
Alternative 4, and satisfactorily mitigates stakeholder concerns by
reducing further the amount of residual radionuclide contamination
and eliminating any future burden associated with Mallinckrodt, Inc.
land-use. In addition, Alternative 6 will reduce the need for future
studies, designs, and remedial actions, thus avoiding future potential
liability and costs to the federal government.
In addition to selecting Alternative 6 for implementation, the USAGE
has revised Alternative 6 so the vicinity property soils are remediated
to levels equal to or less than the more stringent "composite" criteria
regardless of depth. Those inaccessible soils on the vicinity properties
at the time of remediation will be managed through institutional
controls until a remedy is developed. This rigorous level of
remediation will allow unrestricted use of the accessible soils on the
vicinity properties.
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Comment 3
Commentor: Mr. Richard Cavannaugh. Mr. Cavannaugh is the Chair of the St. Louis
FUSRAP Oversite Committee. He represented the St. Louis Comm-
and presented a Statement from the St. Louis County Executive. Buzz
Westfall.
Comment: Before reading the county executive's statement, Mr. Cavanaugh gave a
brief overview of the committee's purpose to collaboratively work with
the City "to provide oversight and assurance that standards are
maintained on the cleanup" on the Downtown site as well as the
Airport Site and adjacent properties.
The Mr. Westfall's statement, read by Mr. Cavanaugh, expressed
disagreement with the proposed alternative based on recommendations
by the St. Louis Site Remediation Task Force and the long-term adverse
economic impact Alternative 4 may have to Mallinckrodt Inc. and the
region. Mr. Westfall's statement read,
"7 [Mr. Westfall] must, however, disagree with the Corps of
Engineers" current recommendation for Alternative 4 for cleanup
of the St. Louis Downtown site. Alternative 4 would only provide a
partial solution to the cleanup issue at the Mallinckrodt plant.
Most importantly, the proposed plan for Alternative 4 is not
consistent with the recommendations of the St. Louis Site
Remediation Task Force. The Task Force recommendation--
based on over three years of hard work and study by the
Radioactive Waste Commissions of both St. Louis County and the
City of St. Louis—clearly calls for the use of clean backfill at the St.
Louis Downtown Site.
The Mallinckrodt Corporation is a long standing and vital
employer in the St. Louis region. Several other businesses operate
in the nearby vicinity properties. The proposed Alternative 4
would result in radioactive contamination remaining in the ground
on the north St. Louis site. The perceived short-term cost savings
of Alternative 4 are overshadowed by the long-term economic
benefits of complete remediation of the Downtown Site.
It is the hope of the St. Louis community that Mallinckrodt will
continue to operate a plant at the Downtown Site. Further, it's
expected that Mallinckrodt will build future manufacturing
facilities at that location. When such construction is contemplated,
further radioactive waste remediation would be required prior to
A-9
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construction. Both the cost and lime involved in such future
remediation will functionally argue against Mallinckrodt 's
consideration of the north St. Louis site for future economic
development. "
Mr. Westfall's comments conclude with the recommendations of
proceeding with Alternative 6 instead of Alternative 4. Alternative 6.
according to Mr. Westfall's statement will "assure complete
remediation of the Mallinckrodt Site and will be a worthwhile
investment in the future of a vibrant economy for our region. Any
strategy short of (he complete remediation outlined in Alternative 6
would be short sighted".
Response: Please refer to-the Responses associated with Comments 1 and 2.
pertaining to the selection of Alternative 6 for implementation, based
on public comment.
Comment 4
Commentor: Ms. Mimi Garstang. Ms. Garstang's comments were on behalf of State
geologist Dr. James Williams.
Comment: Ms. Garstang began with a brief description of the site's groundwater
system and its current use. Her principle concern was for the protection
of the aquifer system potentially influenced by the site's contamination
and that the selected remedy provide this protection. Ms. Garstang's
statement read,
"You 're probably all aware that the St. Louis Downtown Site is
located on the Mississippi River flood plain. The facility is
underlain by a major groundwater aquifer that extends from the
northern reaches of the Mississippi River to the Gulf of Mexico.
This aquifer supplies groundwater for private, public and
commercial uses throughout much of its extent.
I [Dr. Williams] recognize that the Mississippi River alluvial
aquifer in the general vicinity of the St. Louis Downtown Site is not
currently used for public water supply. However, the potential for
such use cannot be discounted. The quantity as well as the quality
of the water in this aquifer is adequate and suitable for many uses.
Protection of the aquifer is essential given the volume and
reliability of the water present.
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The close proximity of the Mississippi River means that there is a
measurable influence by the river on the aquifer. The bedrock
aquifer to the west influences the alluvium to a lesser amount. I
[Dr. Williams] realize that treatment of the water in this alluvium
may be necessary prior to consumption. The extent of treatment
may also be impacted by man-made influences on the aquifer.
However, that does not allow for contamination risks to exist that
knowingly would or could cause degradation of water quality
beyond reasonable limits for standard treatment by the user.
All remedial actions considered for the St. Louis Downtown Site
should include efforts to eliminate the potential for radionuclides
or other contaminants to adversely impact the alluvial aquifer
usable as a water supply. "
Response: Alternative 6, in addition to protecting the workers and providing
flexibility for Mallinckrodt growth, also provides protection of
ground water by removing the majority of the source material
responsible for deteriorating the water quality. A more aggressive
treatment approach for meeting remedial objectives is not practical
from a cost and technological standpoint because of the proximity to
the Mississippi River, the nearest receptor, and the reduction of source
material provided by the preferred alternative. Despite not being
treated, residual contamination left by Alternative 6 does not pose a
significant risk to water users since groundwater is not directly used as
a water source and contaminants in the Upper Zone are not present in
sufficient concentration to impact the quality of the Mississippi River.
Alternative 6, in addition to removing the majority of the source
material, also provides for future assurances that the current non-use of
regional groundwater continues. Alternative 6 regulates groundwater
use through institutional controls that restrict groundwater usage until
such time as the water no longer poses a threat. In addition to water-
use restrictions, Alternative 6 also monitors the potential migration of
the contaminants to determine the remedy's effectiveness and to
provide a determination of water quality impacts.
Comment 5
Commentor: Ms. Sally Price. Ms. Price's comments were made on behalf of the St.
Louis FUSRAP Oversight Committee, of which she is a member.
Comment: Ms. Price presented the opinion of the oversight committee that the
preferred Alternative 4 should be switched to Alternative 6 based on the
A-ll
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Response:
increased protection to human health offered by 6. as well as
Alternative 6 being "more conducive to the continued long term growth
and viability interests of Mallinckrodt Chemical Company". She
stated,
"At the committee 's last meeting this past Friday on April 17,
1998. they discussed the St. Louis Downtown Site Feasibility Study
and Proposed Plan. As a result of the discussions, the committee
unanimously approved a motion to support the Alternative 6
cleanup option offered in the report".
Ms. Price closed her statement by emphasizing the importance of
Mallinckrodt, Inc. and the vital economic base it provides the
community as well as the North St. Louis area.
Please refer to the Responses associated with Comments 1 and 2,
pertaining to the selection of Alternative 6 for implementation, based
on public comment.
Comment 6
Commentor: Ms. Rita Bleser. Ms. Bleser is the Vice Present and General Manager
of Mallinckrodt, Inc. and Plant Manager of the St. Louis Plant.
Comment: Ms. Bleser opened with an overview of the Mallinckrodt company and
its past growth and future upgrade plans. She emphasized Mallinckrodt
growth and commitment to the FUSRAP Program by stating,
"Over the last 10 years Mallinckrodt has invested more than 200
million dollars in new manufacturing and support facilities in the
St. Louis plant. Over the next 5 years Mallinckrodt hopes to
continue investment in upgraded and new facilities at the plant.
Mallinckrodt's interest in the continued development of the St.
Louis plant makes it very concerned about the government cleanup
of residual contamination under the FUSRAP program.
Mallinckrodt has been an active partner in all FUSRAP activities.
Employees serve on the Oversight Task Force, and we have
committed staff and revenue to cleanup projects. To facilitate
FUSRAP remedial activities, Mallinckrodt has relocated on-going
operations, utility systems and demolished structures.
A-12
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Given our involvement in FUSRAP remedial activities and our
continued desire to invest in and expand the St. Louis plant, we are
concerned about the Corps stated preference for implementation of
Alternative 4 of the plan. This alternative simply does not remove
enough contaminated soil to ensure that future investment in the
plant is financially justified.
The presence of contaminated soil in future construction zones will
add costs, complexity and time to the construction of
manufacturing and support facilities at the St. Louis plant. As a
result, it may be more cost effective for Mallinckrodt to invest in
facilities where such burdens do not exist. "
Ms. Bleser expressed concern for the USACE's preferred Alternative 4
and recommended acceptance of Alternative 6. She stated,
"The Corps' preferred alternative is also not consistent with the
recommendation of the St. Louis Site Remediation Task Force. In
its September 1996 report this task force of community
representatives recommended that soil contaminants be removed to
a depth permitting general excavation for maintenance without
concern.
Implementation of Alternative 4 would require that restrictions on
future excavation be imposed according to the Corps' own risk
analysis. Thus, the proposed plan does not excavate enough
contaminated soil to avoid these restrictions and meet the task
force recommendation. The Corps' plan also leaves its ownership
of remaining contaminated materials unaddressed in this plan.
Therefore, the cost of Alternative 4 is understated.
As the agency responsible for implementing the FUSRAP program,
and as the successor to the Department of Energy, the Corps is
obligated to remediate all MED - AEC related residues. Any
left-behind contamination remains the responsibility of the Corps.
As the Mallinckrodt facility and vicinity properties are further
developed, soils left behind under Alternative 4 will be excavated
by Mallinckrodt and other property owners and provided to the
Corps for management and disposal. These administrative and
disposal costs of the Corps are not included in the cost of
Alternative 4. Most importantly, Alternative 4 does not minimize
potential employee exposure. Remediation of more, not less,
contaminated soils at this time lessens overall worker exposure.
A-13
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Response:
...Implementation of Alternative 6 would remove contaminated soil
to a depth of 6 feel and backfill the excavated site with clean fill.
Therefore, contaminated soils likely to be encountered during
routine maintenance and construction activity would be removed.
This remediation alternative is consistent with Mallinckrodt needs,
the task force recommendation, and minimizes long term worker
exposure. "
Please refer to the Responses associated with Comments 1 and 2.
pertaining to the selection of Alternative 6 for implementation, based
on public comment.
Comment 7
Commentor:
Comment:
Father Richard Creason.
Trinity Church.
Father Creason is the pastor of Holy
Response
Father Creason opened with a brief historical overview of his
church. He emphasized how Mallinckrodt, Inc. is part of what
makes a community. He states this support for Mallinckrodt. Inc.'s
continued presence and Alternative 6 by stating,
"...I think we [Mallinckrodt and Holy Trinity Church] both strive
to be very responsible citizens in this community, to make a
contribution to the improvement to a life and the well being of all
who live here. And I think when you look at the elements that go to
constitute a community, that it's employment and housing and
education, and those things that people cherish in terms of a strong
family life. I really would like to see Mallinckrodt stay here and
continue to be that corporate citizen along with us.
I think that the choice of level 6 or Alternative 6 for remediation
would help them to redevelop that property and help to strengthen
an otherwise fragile neighborhood. And so I think that that's my
reason for saying that, and I hope you will give that due
consideration. "
Please refer to the Responses associated with Comments 1 and 2,
pertaining to the selection of Alternative 6 for implementation, based
on public comment.
A-14
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Comment 8
Commentor: Mr. Tom Bratkowski.
neighborhood
A resident of the Old North St. Louis
Comment: Mr. Bratkowski stated he would favor removal of all radioactive waste
and "We need to remove any stigma associated the Manhattan project
from north St. Louis We need to think in terms of rebuilding our
community". He stated,
"And the best way that can be achieved is not by doing the
minimum but by doing the maximum, to reinsure that every effort is
made to remove radioactive waste as deep and as far as possible.
So I think this is an investment in the future. We can 't think in
terms of cheap dollars today and long term costs tomorrow if we
ignore the opportunity to clean it up.
So I would speak in terms of Alternative 6 if that means complete
remediation of the sites as effectively as possible. If Alternative 5
is even better, even though there 's a difference in terms of millions
of dollars, I think that's money well spent, and I think face my
children with that decision without any doubt in my mind that is
money well spent."
After listening to other comments from the participants who supported
Alternative 6 he asked the question, "Does Alternative 5 mean that
Mallinckrodt would go out of business or disappear?"
It was explained to Mr. Bratkowski that Alternative 5 would not put
Mallinckrodt out of business: that it simply provides an even greater
measure of protection than Alternative 6.
Response: Please refer to the Responses associated with Comments 1 and 2.
pertaining to the selection of Alternative 6 for implementation, based
on public comment.
Alternative 5 would remove all the accessible contaminated soil whose
concentration exceeds the most stringent cleanup criteria, the
composite criteria. This approach is much more costly than
Alternative 6 with little added benefit toward human health and the
environment. The USAGE and the majority of commentors agree that
Alternative 6 has a more reasonable cost-to-benefit ratio than
Alternative 5.
A-15
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Comment 9
Commentor: Dr. Carol Prombo. Dr. Prombo has a Ph.D. in isotope geochemistry
and is a citizen of St. Louis.
Comment: Dr. Prombo opened her remarks by listing her credentials as a scientist.
teacher and a concerned citizen active in community affairs. She
. ' expressed support for funding the SLDS clean up effort, as well as other
hazardous waste sites by saying,
"I look at all of the ways that we can spend our money as a
society. I look at some of the lead contaminated sites. 1 look at
piles of lead tailings that are not contained in anywhere near what
the waste here is being controlled by. I look at the school system.
And as I say, I strongly support a cleanup of all of the local
radioactive waste sites.
And I guess this is more of a comment --my next comment is more
to our political leaders, because the laws that are being followed
here are laws that are set by Congress, you know, by the Senate
and the House of Representatives. And they are set in response to
the public. Our public perception of the hazards from radioactive
wastes is very high. We also have a number of other hazards
locally where our perception is not as high where I would like to
see an equivalent reduction of hazard. "
Dr. Prombo supported the need for cleanup action but expressed
concern about the expense of the alternatives and about disposal of the
excavated contaminated soil offsite by stating,
"...lam not in support of taking waste that was produced here and
dumping it on people with less power. And if we look at states like
Utah and Nevada and Arizona, they don'/ have as many people in
the House of Representatives as we do here.
I strongly support a cleanup that will reduce hazards to the people
of St. Louis. I would like to see it done in a cost effective manner.
I recently served on the NASA panel on the creation and planning
team for extra terrestrial materials which oversees specifically the
curation of our moon rocks. And NASA is switching from a
philosophy of spending a lot of money on one mission to a faster,
better, cheaper.
A-16
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And I hope thai some day when it comes to our hazardous waste
disposal we 'II go to a faster, better, cheaper approach, ljust wish
to say I strongly support the materials being cleaned up. It would
seem that they could probably be done in a more cost effective
manner and without dumping it on people that have less power
than we do. "
Later in the meeting Dr. Prombo made a comment that the SLDS "is
right in the thick of (he liquefaction zone". She went on to explain that
the ground in the region would behave as a liquid during a moderate or
larger earthquake, and the level of cleanup should be appropriate for
these areas where residential use is not appropriate. She stated,
"And as far as a level to which one is going to clean up, going
after every last atom of contamination-personalty I don't think
residential—expanding residential use in liquefaction areas makes
good sense for personal safety of individuals. So as far as
cleaning up to a level for industrial use, this sounds like a good use
of resources. And not going to a more stringent residential
standard for an area that's at a high risk for earthquake hazard".
In response to an individual's observation that no one has supported the
USACE's recommendation for Alternative 4, Dr. Prombo stated she
supported Alternative 4 because she wanted the "cheaper" cleanup.
Response: Alternative 4 would be the least expensive of the offsite disposal
options, however, the majority of the comments received were in favor
of Alternative 6. Alternative 6 is somewhat more costly than
Alternative 4 but the stakeholders believe that the added costs are
justified in order to provide additional protection to Mallinckrodt
workers and eliminate future liabilities associated with residual
contamination in soils. Please refer to the Responses associated with
Comments 1 and 2.
Comment 10
Commentor: Mr. Doug Eller. Mr. Eller is a resident of the area, and is employed
with Grace Hill Neighborhood Services.
Comment: Mr. Eller identified and supported Mallinckrodt as an "anchor" in the
community and supported Alternative 6 by stating,
A-17
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"/ would like to say that we arc also — and I'm speaking for
myself --I'm also in support of the alternate 6. We believe thai
it's important that we keep what few anchors that we have in our
community here. Mallinckrodt is one of the few anchors as is Holy
Trinity Church. There aren 't very many left any more. We 're
trying to develop the Riverfront Trail to become an anchor in the
community but it nowhere comes close to the impact that
Mallinckrodt has had in the community here and continues to have.
And we need to support that in any way possible. We want to make
sure that it's economically feasible for them to remain here and
that they can continue to be supportive.
They've done such things as employ people in the neighborhood.
They sponsor, underwrite events within the community. They work
at bringing people together and helping to problem solve when
they're sometimes fragmented. And the list goes on to the point
that it would be a grave loss to lose something as valuable as
Mallinckrodt here.
So we want to —especially me — want to make sure that we have
this understood, that we support Alternative 6. "
Mr. Eller also commented that the meeting was not well publicized in
community and that the "didn't get any notification of meeting today
except at the last minute". As a result he "observed not many residents
were present at the meeting". He stated,
"And I know that our neighborhood is perhaps 75 or 80 percent
African American. And I don'/ see very many African American
faces here either as well as neighbors. So I think though that if
you would have more people from the neighborhood here, they
would also support the things that I 'm saying. Because anybody
coming in contact with Mallinckrodt has done so in a very positive
way ".
Mr. Eller questioned how the meeting was publicized to the local
residents. Mr. Chris Haskell, the environmental public information
specialist, responded by stating,
"The quick answer is we did the standard things, sent out press
releases, notice in the paper. In fact, we 're required to put notice,
and we, in fact, did. And then also Anna from the Mayor '_s office,
I thanked her for the suggestion of using a service that drops fliers
around the community. I've never used that before and I'm
A-18
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Response:
regretful to hear it didn 't work. Sorry. We did contract \\ith this
firm and \ve '11 look into whether or not they, in fact, dropped those
fliers. 2.000 fliers were distributed. That's their minimum, in
fact, and we put it together and got it to them. And thanks for the
feedback".
We 're required to put a so-called legal notice. That's with the
fine print. It's hard to read, granted. Then there was also an
advertisement too in the St. Louis Post-Dispatch. Plus other
papers too but primarily we looked to the Post-Dispatch."
Mr. Eller responded to Mr. Haskell's answer by stating
"I just feel again if there would have been a better notification of
the residents in the neighborhood - I know there's a lot of very
involved people - that there would have been a better turnout
tonight and you would have heard a lot more from the people that
this is actually affecting. That's my only comment. I think fliers
aren 't a bad idea. I think it might have been a bad idea to hire
whoever you hired to have done that".
Discussions continued about the limited degree of advance notice
possible because of the "problems with date changes." Mr. Eller
reiterated his concern about residents not being aware of the meeting by
stating
"If it's important to hear the residents in this whole process I
would recommend for the record that you hold another one with a
better beginning than what happened tonight".
Please refer to the Responses associated with Comments 1 and 2,
pertaining to the selection of Alternative 6 for implementation, based
on public comment.
Comment 11
Commentor: Mr. Frank Muehlheausler, Mr. Muehlheausler is the principal of the
Clay School, the Clay Community Education Center.
Comment: Mr. Muehlheausler spoke of the contributions that Mallinckrodt, Inc.
has made to his school, both with their financial gifts and the volunteer
services of their employees. He described how his school had evolved
A-19
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Response:
from one that was in trouble to a school the neighborhood is proud of.
He credits Mallinckrodt for helping bring about the change by saying
"What I'm getting to is this, partnership has played a big role in
changing the school culture. And to a certain extent this
neighborhood culture. 1' ve been here for 13 years and I live in the
city. I' ve seen an evolution in this school because of partnerships
like Mallinckrodt Chemical. They developed the CAP program
which brings a lot of partners together from the community and we
talk about issues.
And I think that Mallinckrodt is very responsible. And that's what
scares me. Because I see this whole issue of being one where
Mallinckrodt has to be responsible to their business, they have to
be responsible to their stockholders. And they will, I'm sure they
will. Everything I know about these people from Mallinckrodt
makes me believe that they are responsible.
That if they can't develop that property the way they want to.
they 're going to be responsible for their stockholders and they 're
going to move some place else. And that scares me. Because if we
lose Mallinckrodt we lose an anchor in this neighborhood just like
Doug said. And an anchor that's been here for a long time
I could go on and on about the involvement Mallinckrodt has had
with not only this school but within the community. And it would
be a loss, it would be a tremendous loss if they were to move.
...But it's very important to us that Mallinckrodt remains in this
community and that's why I 'm saying No. 6 to keep Mallinckrodt
here."
Please refer to the Responses associated with Comments 1 and 2.
pertaining to the selection of Alternative 6 for implementation, based
on public comment.
Comment 12
Commentor: Ms. Judice Green. Ms. Green is a resident of Hyde Park.
Comment: Mrs. Green stated her desires for the preferred alternative to be changed
to Alternative 6 and questioned what effect the contamination may have
had on the health of residents. She also expressed concern over the
A-20
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publicity of the meeting, agreeing with earlier comments that another
meeting should be held so those unaware of this meeting may have an
opportunity to speak. She stated,
"And when I came in here I was quite taken because I wasn ' t
expecting this. I didn't know what really to expect when I
received a notice. And I didn 't receive a notice until yesterday.
So it didn '(make it in this neighborhood until yesterday. And that
was the 20th. Today is the 21st. So I really didn't gel a chance to
inform a lot of my neighbors. I don't know how many people I
saw. I felt that there was interest, some serious interest. I needed
to come out. If no one else came out then I needed to get the
information to take back to my neighbors.
I agree with this gentleman here who made a comment that
another forum should be made available to people, for the
residents. Like I said I didn 't receive notice until yesterday. And I
think that was very short. And it wasn 't put in the community or
any organizations like the Hyde Park Lions, through measures like
that, for the information to be presented. I'm kind of • I'm sort of
offended to a certain extent, you know, because I wasn't informed
in time. But for my understanding since I' ve been here tonight I
would be for the Alternative 6 for greater measures taken of
cleaning up this contamination because I am greatly concerned
because I have a daughter that I have raised in this area, and also
I'm concerned about what are the effects this contamination has
already had, if any. So that is also a question.
And also I agree with the gentleman in that there should be an
extended date if possible. That's my great concern. Because like I
said, the meeting that - the means that you all have taken to give
out this information, I'm disappointed, very disappointed. "
Response: Please refer to the Responses associated with Comments 1 and 2,
pertaining to the selection of Alternative 6 for implementation, based
on public comment.
The radiological contamination can only result in a health effect if an
individual is exposed through direct contact with the material
(ingestion or inhalation of the material) or spends an extended time in
close proximity to the material (direct gamma exposure).
A-21
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Because the MED/AEC materials are confined to the Mallinckrodt site
and vicinity properties, and are generally not accessible to the general
public, it is unlikely that exposure has occurred to member of the
general public. Thus health effects to individuals living in the general
area are not expected.
Comment 13
Commentor: Ms.' Linda Ellenburg. Ms. Ellenburg is an employee of the
Mallinckrodt, Inc. and a resident of the area.
Comment: Ms. Ellenburg expressed her support for the neighborhood and
Mallinckrodt, Inc. In comment to the earlier statements pertaining to
meeting pre-publicity, she indicated she had received notice of the
meeting from a flyer sent to her home.
Response: No response statement is necessary.
Comment 14
Commentor:
Comment:
Response:
Ms. Debbie Eisenbraun. Ms. Eisenbraun is a resident of the Old North
St. Louis.
Ms. Eisenbraun expressed her support for the complete cleanup
associated with Alternative 5 and questioned the consequences of not
cleaning it up. He stated,
"/ know 15 years ago when my kids were young and they had
detectable lead levels, the health department told us they weren 't
within a treatable range. But since then the kids who come up with
that same level of lead are treatable. You know, the treatment
range has changed.
And I'm concerned about, similar to Tom Bratkowski, I'm
concerned why not clean up at all. I mean what happens if in 5 or
10 years the problem, you know, range expands? Are we taking a
risk of not cleaning it all up? "
Please refer to the Response associated with Comment 8, supporting
Alternative 5 as the preferred alternative.
A-22
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Comment 15
Commentor:
Mr. Dennis Chambers. Mr. Chambers is a certified health physicist for
the USAGE.
Comment: Mr. Chambers responded to the concerns regarding risk by stating.
"With respect to the residual risk issues, the issues on the site, the
allowable contamination going to be remaining there is being kept
down to levels that are protective of the population, the workers
there at the site as well as the environment.
So we will minimize any effect on the personnel on site, let alone
personnel off-site. And the levels are sufficiently low that they will
meet the EPA risk criteria for the remediation and will be
protective of the population. "
Response: Mr. Chambers comment was a response to an earlier comment. No
additional comment is necessary.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998)
Comments received 05/07/98, MDNR * denotes major comments/key issues
Comment No.
Comment
Response
Lcller from
Stephen
M ah food -
Dept. of Natural
Resources
>
NJ
The Missouri Department of Natural Resources has reviewed the Corps' Feasibility Study
and Proposed Plan (FS/PP) which addresses removal of radioactive waste material at the St.
Louis Downtown Site (SLDS) and associated vicinity properties. This letter summarizes our
review and is intended to supplement the testimony we presented at the April 21, 1998,
hearing. Please consider this letter part of the official hearing record.
I applaud the Corps for moving forward with the cleanup of contamination from the nuclear
weapons production era at SLDS. Based upon our experience, the key to a successful
cleanup is community support and a remediation strategy founded on reasonably available
scientific and technical knowledge. I urge the Corps to consider the following five issues in
order to insure a successful cleanup at SLDS.
First, the vicinity properties need to be remediated to 5/15 pCi/g for Radium and Thorium
combined, and SO pCi/g for Uranium 238 to depth. This will insure that these properties are
restored and economic hardships on (he property owners are minimized.
Second, we strongly encourage the Corps to evaluate and implement measures to protect
groundwater resources at SLDS. The department is unwilling to concede (hat groundwater in
this area will never be used as a water supply. I'o do so would abdicate our responsibility to
safeguard groundwalcr for future generations. Even though the groundwater is not currently
used as a drinking water source, the studies we have seen to date do not eliminate the
possibility that is could be used in the future if the radionuclides and other chemical
contaminants from nuclear weapons production are removed. We recognize thai the cleanup
of contaminated soil may reduce the risk to groundwater. Therefore, if the Corp cannol
reasonably address the groundwater issues without delaying this Record of Decision,
groundwater should be the subject of a separate Record of Decision.
Third, we believe that the cleanup should address all chemical and radionuclidc
contamination that resulted from weapons production at this site. This includes
Protactinium, Actinium, organic compounds and toxic metals. To do otherwise would not
restore these properties to a useful condition. The FS/I'P and supporting documents do not
contain sufficient data for the department to determine whether the proposed cleanup will
address all contaminants. We will need (o work with Corps staff to answer these questions.
The USACE agrees that the vicinity properties should he
remediated using (he 5/15 and 50 pCi/g criteria.
The L/SACE believes that the proposed remedy will prevent
further degradialion of groundwater at SLDS, and provide
for protection of human health and the environment.
The USACE agrees that the cleanup should address
chemical and radionuclide contamination (hat resulted from
weapons production activities at this site. However, (he
USACIv authority to remediate is limited to those areas and
contaminants which can be specifically linked to
MED/AEC activities.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/07/98, MDNR * denotes major comments/key issues
Comment No.
Letter
(continued)
1*
2
3*
4*
PP/§1
4-25
Comment
Fourth, we understand that (he Corps is planning to issue a separate Record of Decision for
the inaccessible soils in the vicinity properties. However, the department and the vicinity
property owners need to be assured that human health and the environment will be protected
until these soils can be fully remediated. We would also benefit from a more detailed
description in the SLDS FS/PP regarding how the Corps intends to address the cleanup of
inaccessible soils.
Finally, it is very important for federal agencies to comply with state environmental
requirements in conducting their cleanup activities. This allows the state lo reassure
Missouri citizens that the federal government is subject to the same environmental standards
as they are. It appears that the list of state "Applicable or Relevant and Appropriate
Requirements" (ARARs) identified in the FS/PP is a significantly shorter list than the Corps
provided in previous draft documents. We will need to clarify with Corps staff whether some
requirements have been inappropriately removed.
1 appreciate the Corps' assistance in expediting the cleanup of the St. Louis Downtown Site.
1 trust that you will find our comments useful in proceeding with a cleanup that the Corps,
the department and the public can all support. Thank you for the opportunity to comment.
The FS/PP should clearly delineate the areas at (he St. Louis Downtown Site (SLDS) which
are covered by it. The St. Louis Task Force and MDNR have recommended the Vicinity
Properties (VPs) be cleaned up to a 5/15 level at any depth.
The FS/PP states thai VPs will meet a dose limit of 15 mrem/yr. The Department requests
(hat a site-specific, isotope-specific limit be used as the controlling metric, not a dose limit.
States that only approved off-site borrow would be used to fill in the excavation done 4 or
6 feet across SLDS and the VPs. The FS/PP should include information on backfill for
below 4 to 6 feet.
Currently the FS/PP for SLDS does not discuss water management. Water management
issues, e.g., surface water and groundwater, must be included in any remedy for SLDS. The
Department does not need to see all the detailed plans for water management in the FS/PP
but some discussion by the USACE is necessary.
Response
The USACE intends to develop institutional controls and a
long term monitoring plan as part of the remedial design
process.
The FS was revised lo reflect only those regulations and
statutes that were "applicable" or "relevant and
appropriate" for establishing a cleanup. The ARARs arc
modified from the FS/PP to add Action Specific ARARs on
Table 7-2.
Thank you for your comments and the support from your
staff during development of the FS/PP.
Agree.
The FS/PP states that cleanup will result in conditions
which satisfy CERCLA risk requirements. Isotope specific
guidelines that will be used as controlling values for these
guidelines are based on meeting the CERCLA risk
guidance (i.e., 3 x IO"4 for a radiation site).
Below criteria soil will not be used as backfill at the VPs.
Only approved borrow from offsite will be used at the VPs.
At Mallinckrodt, material below the Al.ARA criteria could
be used as backfill below 4 to 6 feet in depth.
Some discussion is provided in the detailed analysis of
alternatives under water quality/resources. Detailed plans
for water management would be developed during design
phase. Additional information on water management plans
will be available in the remedial design documentation.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received OS/07/98, MDNR * denotes major comments/key issues
Comment No.
5*
6
7
8
9
10
II*
PP/§/H
4-3, last \
4-24
5-16
•
Comment
SLDS is located in an area that has been heavily industrialized Tor many years. However,
continued degradation of groundwater is not justified on this basis. Although groundwater
may not be currently used as a source Tor drinking water, its eventual use as a water source
must be considered. The quantity or groundwater needed for a public water supply is available
in the alluvial material in the vicinity of SLDS. The groundwater may not necessarily have
been of potable quality prior to human impact. However, with standard treatment (such as
softening, disinfection, and filtration), the alluvial groundwater must be considered a source of
public drinking water and associated risks should be evaluated. Any remedial action objective
considered for this site should include efforts to eliminate the potential for radionuclides or
other contaminants to adversely impact the portions of the alluvium useable as a water supply.
A groundwater monitoring system must be designed and a monitoring program implemented
that ensures the detection of potential contaminant releases. It should also ensure that
groundwater is evaluated on a regular basis to maintain representative, reproducible water
quality information for each hydrologic unit.
USAGE needs to include a description in the FS/PP of how ground water and surface water
treatment will be done for contaminated water encountered during remedial activities at SLDS.
The Department would disagree with much of this paragraph, specifically "Alluvial sediments
beneulh the site is not considered a potential source of drinking water due to its poor water
quality." See statement 5 above.
Slates that because SLDS is in an area expected to remain highly industrialized, agreements
will be negotiated to restrict the installation of wells within specified areas to prevent
unauthorized use of groundwater. The FS/PP should include a better description of the
institutional controls to be used at SLDS, e.g. area of restriction, time, etc.
The aquifer below Mallinckrodt may not currently be used as a potable water source, but it
must be looked at as a possible commercial usable water source. "Commercial" could also
include a public water drinking system along with process water. See Statement 5 above.
The FS/PP should include a detailed map which shows the area to be affected by the well
installation restriction. This makes the water unusable, which is in conflict with the desires
of the Department. See Statement 5 above. The VP owners will be negatively affected by
such a restriction, which is of grave concern to (he Department
The Department requests that off-site migration of contaminants in groundwaler be addressed
in this FS/PP and Record of Decision, or addressed as a separate operable unit.
Response
Further measures will be taken to protect, human health and
the environment if MKD/AEC contaminants are detected
above MCLs and exceed site background. Additional
monitoring wells will be installed during implementation of
the remedial action. A groundwater monitoring system wil
be designed and a monitoring program implemented that
ensures the detection of potential contaminant releases.
Water Quality/Resources section in each excavation
alternative acknowledges need for surface and groundwater
management. Detailed description will be developed
during design.
See response to statement 5 above.
Specific details of institutional controls such as the area
included would be developed during design. The time
frame would be until MED/AEC COCs no longer present a
hazard.
See reply to statement 5 above.
Well restrictions could make provisions for requiring
treatment to specific criteria if water is drawn. Criteria
could be specified for both consumptive and non-
consumptive use.
Perimeter wells will be included in monitoring program.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/07/98, MDNR * denotes major comments/key issues
Comment No.
Comment
Response
12
The FS/PP should contain information on further investigation and/or characterization of
groundwaler contamination at SLDS, specifically any groundwater monitoring which is to be
done along with institutional controls.
Further investigation of groundwater. contamination at SLDS
is planned. This information will be provided to the MDNR
as characterization plans are developed. Institutional
controls plans will be developed during remedial design.
It is unclear what designations or definitions are or will be given to contaminated groundwater
(hat has migrated outside of the current FUSRAP area designations and is not co-located with
current contaminants. The Feasibility Study unilaterally declares that these conditions do not
exist. USAGE is responsible for all contaminants that are associated with A EC/MED
activities as stated in the Federal Facilities Agreement. The Department expects the USAGE
to remediate any area which has been affected by AEG/MED activities directly or by
movement of contaminants through the air and/or surface/ground water. The FS/PP should
document all investigation conducted by the U.S. Department of Energy or USAGE to
determine (he nature and extent of contamination.
All investigations to date have been incorporated by
reference in the FS/PP. Site background in the fill outside
of the area that may have been impacted by AEG/MED
activities will be determined in order to identify areas that
may potentially have been impacted by chemical
contaminants. However, because the chemicals that may
have bcen-derived from (he ore may also have originated
from the Till material or other industrial processes in the
area, suspect chemical contaminants must have plumes that
are associated with radiological AEG/MED contamination
in at least part of its extent.
14
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Under several of the remedial alternatives, groundwater contaminant sources may remain in
place in the form of inaccessible soils. The FS/PP must demonstrate that any proposed
remedial action scenarios will mitigate future groundwatcr contamination source areas where
inaccessible soils remain in place.
The inaccessible soils will be addressed as a separate
operable unit. Monitoring will continue in inaccessible
soils areas to ensure groundwater remains unimpacted.
Excavation of accessible soils will proceed as close to
inaccessible areas as feasible including shoring around
buildings rather than sloping the excavation.
15
It is unclear what the delineation is or will be between chemical and radiological groundwater
contamination from Mallinckrodt activities and MED/AEG activities. The FS/PP must
address issues which affect both Mallinckrodl and USAGE and how they plan to work
together to remediate the site.
The USAGE will remediate MED/AEG wastes pursuant to
the ROD. Once a given excavation is completed,
Mallinckrodt will be_afforded the opportunity to investigate
and remediate non MED/AEG wastes. The USAGE is
willing (o incorporate (his planning into an memorandum of
understanding (USAGE excavtion closeoul analyses will
include other results on a cost-reimbursable basis if desired).
16
There is not enough data to indicate whether groundwater contamination has or has not been
found outside of areas containing FUSRAP-conlaminated soils. The FS/PP must address
how data gaps will be handled and what affect they may have on a final remedy.
Groundwater monitoring will delect any FUSRAP materials
that may have migrated out of FUSRAP areas. Removal of
source material should prevent further degradation of
groundwater.
17
Although it has not been demonstrated, institutional controls and/or usage restrictions for
on-site groundwater usage may, indeed, be effective in mitigating on-sitc exposures to
contaminated groundwater. I lowcver, these measures do not lake off-site migrations or future
off-site exposures into consideration. Nor do these measures take into, account the potential
for future off-site uses of gfoundwaler that could influence groundwalcr flow at SI.DS.
Institutional controls would include the VPs as well as
Mallinckrodl. Hecausc the VPs extend all the way to ihc
river, there is no offsilc migration of contaminants.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
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Comments received 05/07/98, MDNR * denotes major comments/key issues
Comment No.
18
19
20
21
22*
23
pp/§/H
4- 18, 3rd 1
4-5
4-25
Comment
The Department requests that groundwaler monitoring not cease upon remediation of an area,
as is suggested in the FS.
Soil is listed as "high permeability" while the 4th D lists soil as "low permeability." This
inconsistency should be corrected.
"...potential for continued degradation of the groundwater quality is high..." While the
statement may be correct, the USACE should avoid responsibility Tor continued degradation of
any aquifer or river way in Missouri. An "applicable or relevant and appropriate requirement"
which relates to this is Missouri's anti-degradation regulation (10 CAR 20-7.03 1(2)).
Groundwaler flow directions have not been adequately characterized to determine whether
groundwater is flowing away from SLDS. The FS/PP must provide a basic understanding of
the nature and extent of contamination in all media.
It should be noted that an assessment of Natural Resource damages may be considered based
on impacts to the groundwater from MED/AEC activities.
Stales that hazardous characteristic tests would be conducted on samples of potential backfill
from each excavation. The use of below composite criteria and ALARA criteria soil as backfill
must not have a negative effect on the RCRA corrective action site investigation. The limited
hazardous characteristic testing may not adequately demonstrate that the proposed backfill
material is appropriate for re-use. The Department requests that more complete sampling for
chemicals be done on the possible backfill material to insure that it is appropriate for re-use.
Response
Monitoring would continue until it has.demonstrated (hut
source removal has adequately addressed groundwater
contamination. Thereafter, there is no reason for Ihe U.S.
Government to continue to monitor.
Agree. The high permeability soils would refer to the lower
unit and should have been specified as such. Low
permeability in the next "jj is referring to the upper unit soils.
Most recent sampling of Ihe Mississippi alluvial aquifer
indicated non COCs above guidelines. Removal of source
term will reduce the contaminant load to the aquifer.
Perimeter monitoring will show any change of post-
remediation COCs. Should monitoring indicate further risk-
based degradation (although the-USACE believes COC
concentrations will reduce in time), additional appropriate
action will be developed.
Groundwater flow directions have been determined to be
toward the Mississippi River in general. Ihis river is
undoubtedly the major influence for groundwater flow at
Ihe site and flow is generally toward the Mississippi River,
although river stages complicate ihc lower unit
groundwater flow direction. There is also a possibility that
an old stream channel may complicate flow in the lower
unit. The current site groundwaler characterization and
future monitoring should bring about a belter
understanding of flow directions.
Noted.
Agree. However, we will require a list of chemicals lo
analyze.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/07/98, MDNR * denotes major comments/key issues
Comment No.
Comment
Response
24«
The document states (hat background health effects (i.e., those associated with naturally
occurring levels of the radionuclides and melals found at the site) influence the development
of health-based cleanup criteria. This is true, but the placement of fill material on a site to
make it suitable for industrial use does not qualify it as natural occurring condition. This is
especially true if the fill material is composed of coal cinders, coal ash and other debris
material. It is appropriate to take background samples which determine the naturally
occurring levels of radionuclides and melals, but those samples should not be in an area
impacted by fill material. Accurate and appropriate background samples should be taken for
both groundwater and soil.
Lower aquifer background will be compared with
upgradienl water in the lower aquifer. The j>erched water
in the upper hydrostratigraphic unit will be compared to fill
background.
25
The residual risk assessment does not include (he appropriate or requested exposure pathways.
The Department has requested in the past that groundwater consumption be included as an
exposure pathway in the residual risk assessment. The Department again makes this request
that to include the groundwater consumption exposure pathway in the residual risk assessment.
to
It was USACEs understanding that the industrial exposure
scenario was the appropriate scenario for developing
cleanup guidelines. This scenario does not include
consumption of groundwater, but does include inhalation of
vapor and dermal exposures to contaminants in
groundwater (as might be possible during a process water
line break at an industrial facility). This understanding was
reached during discussions with DOE and MDNR before
transition of FUSRAP to USAGE, and reconfirmed during
subsequent meetings with USAGE and MDNR.
26
§2.5
Preliminary Remediation Goals (PRO) should be developed for all chemical constituents
listed on page 2-25, 2nd T. PRG's xvere developed only for "potential contaminants of
concern" (PCOC) consisting of chemicals and metals associated with the MED/AEG process
which have been detected at concentrations exceeding I » I O"6 industrial risk criteria. The
results are from sampling for chemicals, done mainly from the Remedial Investigation. The
Department requests that PRGs be prepared for the complete list of PCOC instead of basing
the list on current data because it is so limited in'nature. The Department requests that both
PCOC and PRO be listed in the FS/PP.
The USAGE is responsible for cleanup of contaminants
related to MED/AEG activities. Thus PRGs have been
established only for these PCOCs.
27
The composite criteria includes cleanup levels for Ra-226, Ra-228, Th-230, Th-232, and U-238.
The ALARA criteria is based only on Ra-226, Th-230, and U-238. The FS/PP should
explain how the cleanup criteria listed above will handle other radionuclides, i.e.. Ac-227,
Pa-231, U-234, Ra-228. The residual risk assessment groups Ra-226 with Ra-228, Th-230
and Th-232, and U-238 with U-234/U-235. The residual risk assessment approximates the
amount of Ac/Pa on Ra-226 with the radionuclide ratio used in the BRA. The Department
questions whether those ratios are appropriate. The FS/PP should justify the use of the
existing multipliers in the residual risk assessment.
Other radionuclides arc assumed lo occur at a constant ratio
with those for which measurements are available. The
ratios used in the BRA have been the multipliers
consistently used throughout the St. Louis site.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/07/98, MDNR * denotes major comments/key issues
Comment No.
28
29
30
31*
32*
33
34
35
PP/§/f
4-19
4-19
4-14
2-41
Table 3-1
Comment
USAGE needs lo also look at contaminants other than radiological, associated with MED/ABC
activities at Mallinckrodt.
The FS/PP should address types of treatment, specifically any treatment of sludge.
Slates that building materials which do not meet the surface criteria may, following crushing
to a soil-like material, meet volumetric criteria and may then be used as backfill around the
site. The Department does not consider dilution an acceptable treatment method.
The FS/PP states (hat monitoring will continue for as long as the media under the cap
requires to protect human health and (he environment. We assume the USAGE means
"indefinitely," since uranium's half-life is 4.5 billion years.
Establishment of PRGs for chemicals includes the following exposure pathways: soil; soil
ingeslion; dermal contact with soil; inhalation of suspended paniculate; ground water; and,
dermal contact with and inhalation of process water. USAGE needs lo include at a minimum
(he same groundwaler exposure pathways in the radiological residual risk assessment as those
used in the development of chemical PRGs.
PRGs for radiological constituents where included in the latest FS/PP for SLDS. The
Department requests clarification and better documentation on the establishment of these PRGs.
The FS/PP should include a detailed description including maps showing the location where
below composite criteria and ALARA backfill may be used at SLDS.
This table lists the isotopes covered by Uranium Mill Tailings Radiation Control Act
(UMTRCA) regulations. UMTRCA covers Ra-226, Ra-228, Radon, and Uranium, but not
Th-230 and Th-232 as currently listed in Table 3-1
Response
Given the K0 of metals that may have been associated with
MED/AEG ores, it is expected that MEDCAEC
contaminants are co-located with radiological
contaminants.
Treatment of sludge would be identical to treatment of soils
excavated from beneath the water table: dcwater and
dispose.
Text also slates "if regulatory approval can be obtained". It
is not dilution to crush the materials and apply volumetric
criteria rather than surface criteria. Dilution would involve
the addition ofclean material to increase the total mass
relative to the mass of contaminants. Crushing the rubble
does not add any new material to the total mass.
True. In 4.5 billion years the concentration of U-238
would be one-half what it is today. In 4.5 billion years the
concentration of heavy metals will be unchanged if the site
is left undisturbed. Five year reviews will be included in
the remedy.
The maximum radiological contamination in groundwaler
samples taken from the deep aquifer is about 10% ofthc
proposed MCL for uranium.
PRGS were calculated using RAGS Part D guidance. A
copy of the calculation package for ihc PRGs will be
submitted for MDNR review.
In Alternative 6, only approved borrow from offsitc will be
used as backfill at the Vl's. Where excavations exceed 4-6
feel, soil below AI.ARA criteria could be used as back 11 II
Only approved offsitc borrow would be used above Ihc 4-6
fool depth.
Table 3-1 referenced DOC Order 5400.5 as well as
40CFRI92
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/07/98, MDNR * denotes major comments/key issues
Comment No.
36
37
38
39
40
41
42
PP/§/1
3-19
4-14
Appendix
C
Comment
The Sum of the Ratios (SOR) example does not include Ac, Pa, Ra-228, etc. Please explain
why the SOR does not include the other radionuclidc isotopes and how SOR is used during
remedial activities.
The FS/PP should provide a detailed list of what buildings or structures are led to be
decontaminated at Mallinckrodt. Building materials which do not meet the surface criteria
may (following crushing to a soil-like material) meet volumetric criteria and could be
considered as backfill around the site, if regulatory approval could be obtained.
The Department docs not believe that dilution is an appropriate treatment method for either
soil or groundwater. Therefore, we would disagree with a plan (o allow groundwaler flow
through contaminated soil to the Mississippi River, simply because the large volume of water
in (he river dilutes the contaminants below detection levels or levels of concern.
The USACK needs to document the contaminants of concern to be monitored with respect to
radiological and chemical analyses.
The USAGE should clearly document whether the concentrations in Table C-3 include other
radionuclides.
The USAGE needs to clarify whether this FS/PP is intended to apply to radionuclides and
chemicals both in soil and in groundwaler. Please also explain how this FS/PP fits into the
overall cleanup plans for the SLDS.
The PP deals only with radioactively contaminated soils. Chemical constituents associated
with DOE's former processing activities should be addressed in the FS/PP.
Response
The SOR uses the isotopes actually measured at the site.
Other radionuclides were accounted for by assuming a
constant ratio to the "indicator" isotopes. Concentrations
used in the SOR equation were developed on the basis of
dose assessments that accounted for all isotopes in (he
decay chain. The SOR will be used as a tool to help direct
remediation activities. Post remedial action doses and risks
will be calculated using actual sample data (including
Ac-227andPa-23l).
Building K has already been decontaminated and will be
demolished. Building 30 was discovered to be
contaminated during the RI, but subsequent renovations
may have decreased surface contamination. There may be
none left, or there may also be some as yet undiscovered
surfaces in other buildings
The situation described is what is currently happening. The
proposed remedial action would mitigate this situation and
result in no further degradation of this system.
COCs include U-238, U-235, Ra-226, Th-232, and decay
progeny. Chemical COCs include Ni, Cu, Cd, U, and As.
For dose and risk calculations, all isotopes in the uranium
series decay chain below U-238 arc included as well as
those in the actinium and thorium decay chains below
U-235 and Th-232. Only the key indicator radionuclides
are shown in the tables. 1 lowevcr, the complete decay
series for each indicator nuclide have been included in all
calculations as documented in the AI.ARA analysis
calculation package.
The remedy is intended to apply to MED/AEC
radionuclides and to MlvD/AEC chemicals which are
believed to be entirely co-located with the radionuclides in
both soil and groundwater. Source removal is expected lo
remedy groundwater Continued monitoring will verify
success.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/07/98, MDNR * denotes major comments/key issues
Comment No.
43
44*
45»
46
47
48
49
50*
PP/§/1
4-25
Appendix
A
4-7
5-34
Comment
The subsurface in the FUSRAP areas has not been adequately characterized at this time with
regard to the nature and extent of radiological and chemical contamination in soil and
groundwater. Hence, this information will be needed in order to assure that potential
contaminant exposure pathways and receptors can be identified to the extent necessary to
support (he soil clean-up levels, institutional controls and exposure assumptions presented in
the PP.
States that institutional controls would remain in place to insure continued prolectiveness
until a remedy for inaccessible soils is determined. The Department requests clarification
that the inaccessible soil will be treated as a separate operable unit, and that the FS/PP for
inaccessible soil will address how they will be handled by the federal agency in charge of
long term operation and maintenance of the FUSRAP sites.
The FS needs lo include a complete list of Applicable or Relevant and Appropriate
Requirements (ARARs). along with a detailed analysis. The January 1998 version of the FS
contained a more detailed list than the March 1998 version. A draft list of additional ARARs
which were not included in the March 1998 version of (he FS/PP have been attached with
these technical comments. 1'he detailed analysis should explain why an ARAR does or does
not apply lo SLDS.
SLDS is not an "official" NPL site under CF.RCLA. Therefore, the Department recommends
that the USAGE submit permit equivalent applications will allow the Department lo establish
ARARs for SLDS.
Disposal of waste al Mallinckrodt through excavation, consolidation and capping would not
meet ARAR's for Missouri. (Solid Waste Regulations)
The FS/PP does not address protective measures for on-site workers, (he public, and the
environment during remedialion activities at SLDS. The Department requests a general
description of (he protective measures to be implemented by the USAGE or its contractors
during the remedialion activities.
Clean-up criteria should be determined for groundwater below or down gradient of the site,
which has been shown in previous assessments and reports to be contaminated.
USAGE should clarify Ihe use of the 30-year lime frame and specify lhal it is only used for
cos! estimates, not for establishing a lime period for walking away from the site
Response
The alternatives and (heir evaluation under the criteria for
selection would not be likely lo change If additional
characterization data were available. Additional data
would still not permit differentiation between site
background and AEC/MED melals. The ALARA analysis
was sufficiently conservative to ensure safe levels
following cleanup even if the actual site mean is higher
than currently believed.
Inaccessible soils will be treated as a separate OU. Remedy
documentation for the inaccessible soils will specify how
they will be handled in terms of long-term O&M (if any).
The FS was revised to reflect only those regulations and
statutes that were "applicable" or "relevant and
appropriate" for establishing a cleanup under GERGLA.
USAGE is addressing SLDS as a CERCI.A site via (he
NGP, as such all ARARs should be presented in (he Record
of Decision.
This is additional reason for selection of an alternative that
features offsite disposal.
Detailed health and safety procedures will be developed
during design process and published in the site-specific
Health and Safety Plan.
PRGs were evaluated for chemicals in groundwater.
However, Ihe proposed remedy involves use of source
removal to levels sufficient to prevent further degradation
of groundwatcr due lo MED/AliC contaminants of concern
Agree. Ihe 30 yr. period is used as indicaicd. Long term
monitoring and instiliilion.il controls would be developed
based (in conditions after remedial action
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Commend received 05/07/98, MDNR * denotes major comments/key issues
Comment No.
51
52
53
54
PP/§1
5-16
ES-3
4-9, Last U
Comment
Slates that monitoring would include sampling to ensure that the remediation was adequate
to protect human health and the environment as determined by risk assessment. The Record
of Decision should document what will be monitored at SLDS.
The USAGE needs to clarify in the FS/PP how contaminant exposure pathway scenarios and
concentration levels were derived when the site-specific residual risk assessment was
performed based on the limited groundwater characterization at SLDS.
Last paragraph needs appropriate spacing between words.
Waste has already been shipped to Utah from SLAPS and North County Vicinity Properties
so the requirements listed here have been addressed in the past.
Response
ROD will include general description of contaminants to be
monitored. , i ' .
The groundwater pathway is a very minor exposure
pathway in the industrial exposure scenario used to develop
cleanup guidelines.
Agree.
True. Implcmentability should have taken into
consideration that route planning and spill control plans
have already been developed.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/07/98, MDNR Hazardous Waste Program
Comment No.
pp/§/H
Comment
Response
• Letter from
Cindy Kemper -
Hazardous
Waste Program
The Missouri Department of Natural Resources' Hazardous Waste Program is hereby
transmitting to you a copy of a letter to Mallinckrodt, Inc. regarding corrective action being
undertaken pursuant to the Missouri Hazardous Waste Management Facility Permit issued to
Mallinckrodt on September 19, 1997. Several of the issues raised in this letter relate to the
division of responsibility between Mallinckrodt and the U.S. Army Corps of Engineers for
investigation and remediation of environmental contamination both inside and outside of
FUSRAP areas at the Mallinckrodt facility. Inasmuch as the resolution of these issues bears
directly on the site-specific corrective action requirements to which Maliinckrodt is subject,
we are hereby requesting that the Corps formally respond to the issues raised in the enclosed
letter as they may relate to the proposed Feasibility Study and Proposed Plan.
Thank you for your consideration in this matter. If you have any questions concerning the
enclosed letter, please do not hesitate to contact me or Richard A. Nussbaum, P. £., R. G , of
mv staff. 31(573)751-3553. :
Many of the general issues raised in this letter from MDNR
to Mallinckrodt (Attachment A-1) are similar to or the same
issues raised by MDNR in the following detailed comments
on SLDS FS/PP (e.g. use of site-specific risk assessment to
develop cleanup guidelines, characterization and future use
of ground water, etc.) These issues are addressed in the
responses to specific comments on the SLDS FS/PP.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (January 1998 Issue)
Comments received 05/07/98, MDNR * denotes major comments/key issues
Comment No.
Comment
Response
I
Previous groundwater monitoring and sampling activities at the site have been infrequent and
sporadic. A baseline groundwater characterization was conducted in late 1997 and early 1998
at SLDS. The purpose of the characterization was to collect current baseline water quality
data from existing groundwater wells to use as a basis for evaluating future remedial actions at
the site. The information provided in this groundwater characterization was to be used for
determining the adequacy of subsequent sampling and monitoring activities and should be
evaluated as the baseline in which future remedial activities will be judged. Future
characterization activities should be linked to site specific remedial scenarios using the data
collected from this sampling effort.
Information presented in the FS is based on historic groundwater monitoring at SLDS. The
Department has not.had the opportunity to review the results of the baseline sampling and data
collection or the information contained therein. Therefore, the following comments on
groundwater should be considered preliminary until the characterization data has undergone
full review. It is likely that review of (he groundwater characterization will generate further
comments on the FS.
As noted, additional groundwaler characterization is
planned, particularly with regard to non-radiological
constituents. While the proposed remedy is not dependent
on additional groundwaler characterization, the results
from the additional characterization will be used to help
design suitable institutional controls and the long term
monitoring program.
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ES-4
fable ES-I states that none of the VP groundwatcr monitoring wells exceed applicable
contaminant levels. Based on the information provided in this document, wells BI6W06S and
B16W06D are the only wells that can be identified within VP boundaries. The Department
requests that a map be included in (he FS/PP that identifies all the groundwatcr monitoring
wells located within VP boundaries.
No additional wells are available. The final version of the
FS and PP have been issued. No further revisions are
planned. However, the map requested is available in the
draft Groundwaler Characterization Report of1997/1998
Baseline Data for the Si. Louis Downtown Site.
ES-8
The Alternative 4 description in Table ES-4 mentions disposing of soil at an on-site disposal
cell at SLAPS. This disposal option is not advanced within the Feasibility Study.
Furthermore, this disposal method is not presented in the Proposed Plan. If this soil disposal
option is being retained for consideration, it should be specifically discussed as part of a
Remedial Alternative for SLDS soils and included in the Alternative Analysis portions of the
Feasibility Study. However, this option clearly would not meet several State laws and
regulations, one of which prohibits locating a disposal facility in a flood plain.
This statement was in error. The final FS (April) has
corrected this error.
ES-9.
Line 32
The FS/PP should document all conclusions made within it. The Department requests more
information to verify that contaminant leaching to groundwater is currently negligible.
Supporting evidence is available in the aforementioned
Groundwatcr Characterization Report. Shallow wells in
the upper hydrostratigraphic zone contain high levels of
uranium while the five wells completed in the lower
hydrostratigraphic zone had only 2 detections of uranium
at 0.34 and 2 ug/l.. The maximum delected value is 10%
of the proposed MCI. for uranium
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (January 1998 Issue) (continued)
Comments received OS/07/98, MDNR * denotes major comments/key issues
Comment No.
Comment
Response
ES-9.
Line 42
Alternative 4 does not propose the removal of inaccessible soils. Therefore, in locations
where inaccessible soils will remain in place, the source for potential future groundwater
contamination below the water table exists.
A remedy for inaccessible soils will be, presented in future
documentation. The volume of accessible soil is much
greater than that of inaccessible soils, thus the problem
will be greatly reduced pending a final decision for
inaccessible soils. In addition to the smaller volume,
much of the inaccessible soil is under buildings where
infiltration of rain water through contaminated material is
intercepted by the structure.
2-11,
Line 41
The hydraulic conductivity of the upper hydrostratigraphic unit is reported as 9.9 * 10* cm/sec.
Limited geolechnical soil testing has been performed at this site. One variable-head permeability
test was conducted within the upper hydrostratigraphic unit: Given the heterogeneous nature
of the unit, one permeability measurement is not necessarily representative of the geologic
characteristics of this unit. The hydraulic conductivity of this unit should be reported as a
location-specific measurement, or an average hydraulic conductivity should be reported, based
on information obtained from more than one permeability lest.
Agree. This hydraulic conductivity value is a localion-
specific measurement.
2-13, Line 2
It is difficult to establish the relationship between the upper hydrostraligraphic unit and
fluctuations in the Mississippi River stage. The hydrograph analysis that is presented in the
Remedial Investigation Report lakes into account only four wells open to the upper unit. The
nearest of these wells is over one-half mile upgradient from the river. Given the hydrograph
information, .it is not obvious that water stages in the river significantly affect water levels
measured in the four upper-unit wells. Furthermore, there is no information on how the river
stage might affect the upper unit at locations closer to (he river, since data from the upper-unit
monitoring wells that are closer to the river were not used in the hydrograph analysis. That
information, if available, may be used to establish the relationship and hydraulic connection
between the two hydroslratigraphic units and the river.
Agree. The relationship between the Mississippi River
and the upper unit have not been well defined. However.
the relationship will be belter defined during planned
additional groundwater characterization efforts at SI,OS
2-13,
Line 18
The document discusses two distinct alluvial hydrogeologic zones- an upper unit and a lower
unit. It is reported that measured water levels in the two units can differ as much as 30 feet.
Figure 2-5 shows monitoring well locations, water level measurements, and groundwater flow
directions. However, this potentiometric surface map was constructed using water level
measurements from both the upper and lower hydroslratigraphic units. This figure does not
represent groundwater flow direction in either hydrostratigraphic unit. Furthermore, the
difference in water level measurements is derived from shallow wells in the western portion of
the site where the lower hydrostratigraphic unit is absent, and from deep wells near the river,
where the lower hydrostratigraphic unit is the thickest.
Potentiomctric surface maps should be unique to the alluvial unit from which water levels
were measured. Differences in water level measurements should be location comparative and
site-wide. This information should appear in the I;S as separate add distinct maps, and the text
should contain a discussion about each hydro.slraligraphic unil.
Agree. Figure 2-5 was deleted from the final FS
published in April.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (January 1998 Issue) (continued)
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Comment No.
9
10
II
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2-30, Line 5
2-34,
Line 25
2-34,
Line 25
2-34,
Line 32
2-36,
Line IS
Comment
The Department requests (he USAGE include information in the FS/PP as to where the
(richloroethylene (TCE) was stored and used at SLDS.
It has been determined that high water stages in the Mississippi River contributed to the
mobilization of thorium and radium detected in the sediment. The Department requests that
the movement of contamination and transport media be documented in the FS/PP, e.g., how
sediments in the river became contaminated with Th-230 and Ra-226.
Furthermore, it is unlikely that the periods of high water between 1988 and 1992 are the only
instances where contaminants have been mobilized from the river sediment. Therefore, it is
assumed that contaminants are migrating to the river sediments from an upgradient source and
are periodically being mobilized by high water stages. The FS/PP should also document in
detail all investigation conducted by the US Department of Energy or USAGE on the nature
and extent of contamination. (See Comment 1 1 )
The document states that high water in the Mississippi River mobilized the Ra-226 and
Th-230 previously detected in (he river sediments. The FS/PP should document whether the
sediment contaminated with radionuclides was mobilized by high water and removed, or
whether the radionuclides themselves were mobilized from the sediments. It should also
explain how high water is expected (o continue to mobilize the thorium and radium previously
detected in the sediment. (See Comment 10)
The FS/PP must indicate in which groundwater wells were elevated metals detected to aid in
understanding nature and extent of contamination. Levels of fluoride and VOCs, and
corresponding groundwater wells, should be indicated as a map attachment in this document.
The possibility of an open jointed and leaking sewer creating an accumulation of contaminated
sediment off-site does exist. Although sediments in (he system -have probably been scoured
away, (he sewers would have deposited contaminants in the soils around the lines, and
contamination would not necessarily be found exclusively in those sediments remaining in the
utilities.
Response
Such information is not presently know.n. In the event
such information is discovered during the RD/RA phase,
it will be addressed.
Detailed information on investigations on the nature and
extent of contamination is contained in the Rl and Rl
Addendum reports which are part of the Administrative
Record. The FS only summarizes the information in these
reports.
Because of the low solubility of radium and thorium
compounds it is likely that the contamination was
transported along with the sediment. 1 lowcver, there is no
way to prove this after (he fact. Additional tests of
chemical form of the radionuclides is planned as part of
the SLDS characterization effort.
This information is available as part of the SLDS
groundwater characterization report.
No areas have been located in which this occurred. If
such areas are discovered during remedial activities, they
will be remediated. However, no further characterization
is planned to locate these areas in advance.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (January 1998 Issue) (continued)
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Comment No.
14
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16
17
18
19
20
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2-39, Line 6
2-41,
Line 18
3-17,
Line 16
3-17.
Line 33
4-3, Line 1
4-3, Line 8
4-3, Line 24
4-3, Line 26
Comment
The permeability of (he alluvial sediments is not known. Although the upper hydrostratigraphic
unit likely exhibits lower permeability than the lower hydrostraligraphic unit, only one
permeability test has been conducted within the upper hydrostratigraphic unit at this site.
Three permeability tests have been conducted in the upper portion of bedrock. There have not
been permeability tests done on the lower (likely more permeable) alluvial hydrostratigraphic
unit. The statement that groundwater in the alluvial aquifer is controlled by low permeability
materials is, therefore, misleading. (See Comment 6)
The statement that only limited groundwater data was available from SLDS during the
Baseline Risk Assessment (BRA) suggests that new groundwater data has been provided since
the BRA was developed. Any new residual risk assessment should be based on the most
current data available. The Department requests to review any data that becomes available
during the FUSRAP project.
The potential for future groundwater degradation due to the industrial future-use scenario docs
not preclude protection of ground walcr as a resource. Numerous factors should be taken into
account in determining which groundwater protection and remediation activities will be
implemented at this site. These factors include (he degree to which groundwater has suffered
or will suffer degradation due to historic MED/AEC activities at this site.
The document stales: "If contaminants in groundwalcr reach the Mississippi River, they are
below drinking water MCLs." The USACK will need to clarify the meaning of this assumption in
the FS/PP. No modeling on the data has been presented which supports this statement.
Again, this hydraulic conductivity information is the result of one permeability lest in this
unit. (See Comments 6 and 14)
The text should be corrected to read "BI6W07D." Well BI6WOI 7D does not exist.
Very little information exists about the hydrologic properties of the alluvial sediments at SLDS.
The USAGE should document how the groundwater discharge was measured in the FS/PP.
The documentation can include simply the reference of a standard method if documentation is
available publicly.
The siatcmenl that the saturated bedrock beneath the site has not been penetrated is nol
correct. The bedrock at the SLDS site has been penetrated with groundwaler wells. Wells
BI6WOIS and BI6W04S are partially screened in the upper portion of the bedrock.
Response
Agree. This sentence is poorly worded. This situation is
appropriately worded for (he upper unft.
A draft of the groundwater characterization report has
been provided to (he stale. The data were not available in
time to incorporate new risk calculations into the FS. The
residual risk assessment conducted after remediation will
incorporate the most current data available.
Agree, however the proposed remedy will prevent further
degradation by MED/AEC materials through source term
removal.
The very low flow rale in the groundwater relative to the
very high flow rate of the Mississippi will dilute
contaminants in the groundwaler to below detection
limits.
Acknowledged.
Agree. The text should read "I3I6W07D".
Agree. A basic equation was used to determine
approximate permeability and discharge rate in the Kl.
The method was not referenced. To check this result, a
back-calculalion was performed lo determine the
permeability factor used; permeability was determined to
be within the published limits for this soil type.
Agree. The April 1998 version of the FS was revised to
slate the saturated bedrock has not been penetrated mure
than 4m ( 1 3 ft) with a well.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (January 1998 Issue) (continued)
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Comment No.
22*
23*
24
25*
26*
27
28
29
pp/§/1
4-3, Line 35
4-24,
Line 10
5-17,
Line 22
5-30,
Line 32
5-31. Line 5
5-42,
Line 21
5-53,
Line 34
5-54,
Line 46
Comment
The text suggests that, due lo the large volume of Ihe river relative to groundwater discharge.
no impacts lo the water quality of the Mississippi River can be expected. Although groundwater
discharge to the river will effectively reduce contaminant concentrations, dilution is not
considered a groundwater treatment alternative.
The Department is unaware of any groundwater modeling of the St. Louis site. It may be
appropriate that some type of groundwater model be developed for SLDS. Any groundwater
model that is developed for SLDS should be reviewed by the Department.
The USAGE'S proposed sampling and monitoring of groundwater should be presented in
greater detail in the FS/PP.
The document states that annual monitoring would include ten groundwater samples. There
are currently 1 7 groundwater monitoring wells at SLDS. Ten samples per year would not be
considered an adequate monitoring program. Furthermore, the baseline groundwater
characterization could present data that might be pertinent in determining sampling frequency
and numbers of samples to be taken. There is also the possibility that additional groundwater
monitoring wells will be required at SLDS or the VPs.
This alternative does not take into account potential groundwater contamination from soils
that are -inaccessible and remain in place. The potential for contaminant migration into
groundwater. would exist until all access-restricted soils can be removed.
Alternative 5 states that the potential for contaminant infiltration leaching into groundwater
would exist until all access-restricted soil is removed and that groundwater quality would
eventually improve over baseline conditions. Alternative 4 should also discuss the effect on
groundwaler, where these conditions will remain a factor in potential future groundwater
contamination at this site.
The document states that implementation of Alternative 4 would remove the source of potential
future groundwater contaminants from below the water table. However, Alternative 4 leaves
approximately 32,000 yd' of contaminated soil in place, which could function as a potential
source of future groundwaler contamination. This should be explained in the FS/PP with
some detail.
Alternative 4 would not achieve (he same groundwater protection as Alternatives 3 or 5.
Alternative 4 leaves approximately 32,000 yd' of contaminated soil in place, which could
function as a source of potential future groundwaler contamination. The document should
discuss this.
Response
Agree.
The reference lo groundwater modeling was deleted from
the final revision issued in April.
Should Alternative 3 be selected, a long-term monitoring
plan would be developed during the design phase.
Deleted reference to the number of groundwater samples.
Monitoring plan would be formulated during design.
The final FS issued in April separates the inaccessible
soils into a separate operable unit. Inaccessible soil
locations would be assessed as part of the monitoring
program until a remedy is selected. Surface water would
be monitored as well.
Inaccessible soils were removed from the scope of this FS.
The final version of the FS was issued in April. The soil
left in place would be below the AI.ARA criteria. The
soil removed would contain Ihe highest concentrations of
radionuclides and is therefore the most likely to contribute
(o groundwaler contamination.
Acknowledged. Alternative 4 is less protective of
groundwater than the other excavation alternatives.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (January 1998 Issue) (continued)
Comments received 05/07/98. MDNR * denotes major comments/key issues
Comment No.
Comment
Response
30
The Missouri Department of Health (MDOII) offered assistance to SAIC in determining
clean-up criteria for this site by offering information on current Risk Assessment Guidance for
Superfund (RAGS) methodology, modifications, and accepted default values. To promote and
expedite the determination of health protective clean-up criteria, MDOH also offers to answer
any assessment questions SAIC may have during their in-house revision process.
We appreciate the efforts of MDOII and MDNR in
reviewing the SLDS FS to help meet the tight FFA
milestone schedule.
31
It is still unclear as to the target dose to be achieved at this site. As presented, there has been
no agreement between using EPA's starting point of 15 mrem/yr and NRC's starting point of
25 mrem/yr. The "Concentrations Producing Target Limits for SLDS Radionuclides..." tables
presented to our office, however, show comparisons to the NRC limit of 25 mrem/yr Please
include comparisons and subsequent clean-up criteria for the target dose of 15 mrem/yr.
The EPA target limit was set to 15 mrem/yr as a level that
would fa!! in the !0~* to 10"* risk range considering only a
generic conversion factor for gamma radiation. The site-
specific ALARA analysis and exposure pathways found
that reduction below 25 mrem/yr for (he isotopes at SLDS
reduced the incremental lifetime cancer risk to the I0~* to
IO"6 range for future industrial land use.
32
If pending documentation is determined to be correct, the approaches utilized in Attachment C,
SLDS ALARA Analysis, appear to be protective of industrial exposure from radionuclides in
the soils at this site. MDOII has yet to review the calculations and references on which the
conclusions in this attachment were based, Final comments as to the proteclivcness of the
approach presented will be submitted after review of the documentation.
The complete ALARA analysis calculation package was
submitted to MDNR in February, 1998
33
All Chemicals of Concern (COCs). excluding radiological aspects, should be assessed using
RAGS. Part I), methodology. This would include determining a clean-up level for VOCs,
SVOCs and inorganics. MDOII would request that uranium be included in (he chemical (oxicity
analysis, as it has been found to have to have greater risk from toxicity than radioactivity in
past assessments. The level determined should take into account the ingestion, inhalation and
dermal contact pathways. This should be done for industrial exposure to surface soils and
subsurface soils.
Agree. These methods have been incorporated for
development of the PRG tables published in the April
version of the FS.
34
Although presented in the review meeting as a risk driver, radon is not discussed in
Attachment C. Discussion as to the reason for its exclusion and any plans to monitor radon
levels should be included in the text.
Radon is regulated separately from other radionuclides.
Outdoors, radon concentrations arc negligible due to rapid
dispersion into the atmosphere. Indoors, the concentration
is dependent on ventilation of the structure. A section
discussing potential indoor worker exposures to radon was
added to the ALARA assessment in the April version of
the FS.
35
Cleanup criteria should be determined for groundwater below or downgradicnt of the site,
which has been shown in previous assessments and reports to be contaminated.
I'RGS were evaluated for chemicals in groundwatcr.
However, the proposed remedy involves source removal
to levels sufficient to prevent further degradation of
groundwaler due to MKD/AHC constituents
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (January 1998 Issue) (continued)
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Comment No.
36
37*
3S
39
40
41
PP/§1
Appendix C
Appendix C
Appendix C
Comment
MDOH suggests utilizing the Jury model Tor determination of the volatilization factor. EPA
Region VII is requesting that risk assessments and preliminary removal goal documents use
this method. The use of this model in the next revision would expedite the review process.
Complete inclusion of all exposure variables used, in addition to justification of the use of any
non-default values, would assist the reader and prevent delays due (o further revisions.
The hours worked per year by an industrial worker should be increased to 2 1 25 in the
determination of the Fraction of Time Outdoors variable.
Ground water consumption was not used as a pathway in the residual risk assessment. The
FS/PP should clarify why the groundwater consumption was not included in the residual risk
assessment for radiological constituents.
The Department requests that the location and time frame for the background sampling to
determine the background levels for radionuclides which were used in the risk assessment be
included in the FS/PP. (Ra-226 0.9 pCi/g, Th-230 1.5 pCi/g, Th-232 1.0 pCi/g, U-238
I.I pCi/g) Background levels for groundwater also needs to be included in the FS/PP.
The Department recommends that the multiplier for Ac-227 and Pa- 2 3 1 used in the residual
risk assessment be based on validated data for Ac-227 and Pa-23 1 from the SLAPS West End
Excavation or results from Westlake Landfill Remedial Investigation. The multipliers used in
the BRA can be used again if USACE verifies that the multiplier from the BRA is correct for
the site with validated data. This work must be done before excavations are completed in
order to avoid the possibility of going back to remove more soil after the project is complete
because the data from the excavation used in the final residual risk assessment shows that the
risk exceeds the appropriate risk levels (
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (January 1998 Issue) (continued)
Comments received 05/07/98, MDNR * denotes major comments/key issues
Comment No.
Comment
Response
42
In (he Summary of Radionuclides in Soils (ables, several constituent concentrations could not
be distributed due to low number of detects (footnote D). However, a 95% UCL seems to be
presented for these constituents with the mentioned footnote. For example, in the Summary of
Radionuclides in Soils (No Removal), the exposure concentrations for Th-232 and U-238 in
Plant I Waste should be the maximum detected (6 pCi/g and 160 pCi/g, respectively) due to
the low number of detects. In the Summary of Radionuclides in soils (SQR>I Removed in
Top 8 Feet and Labeled as Waste), the exposure concentrations for Th-232 and U-238 in Plant I
Waste should be the maximum detected (6 pCi/g and i60 pCi/g, respectively) due to the low
number of detects. The exposure concentration in Plant 2 After Removal for U-238 should be
the maximum detected (35 pCi/g) due to the low number of detects. In the Summary of
Radionuclides in Soils (SOR>I Removed in Top 2 Feet with SOR>I Removed and Labeled as
Waste), the exposure concentrations for Th-230, Th-232 and U-238 in Plant I Waste should
be the maximum detected (230 pCi/g, 6 pCi/g, and 160 pCi/g, respectively) due to the low
number of detects. If these values are in error, please correct. If the values are correct, then
the footnote should be omitted.
Exposure concentrations were estimated per RAGS
guidance. -This includes using reported vahles for all non-
detccls and using the smaller of (he maximum value and
the UCL,,. In the 6/160 example given, there are six
results but only one detect for U-238 and three delects for
Th-232. The UCL,, values were estimated using reported
values (usually the detection limit). Because the estimated
UCL,, was less than the max, the UCL,, was used.
43
In (he Radionuclidc Concentrations by Cleanup Option and Exposure Unit table, U-238 is
listed as having an exposure concentration of 1.1 pCi/g at Plant I in the SOR>I lo 8 A
column, ycl (he Summary of Radionuclides in Soils (SOR>I Removed in Top 8 Feel and
Labeled as Waste) does not list the exposure concentration for U-238. The only value listed
for U-238 at Plant I is 4.0 pCi/g for a mean concentration. Please explain.
The exposure concentration (RME) was determined by
subtracting background from (he UCL,, concentration.
When there were no data to use in a UCL,, calculation,
background was inserted as a place holder, background
was inserted so that once background was subtracted, a
final concentration of zero, the actual value listed in the
database, would be obtained.
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MDNR COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY/PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (January 1998 Issue) (continued)
Comments received 05/07/98, MDNR * denotes major comments/key issues
Comment No.
pp/§/|
Comment
Response
44
In the Dose Estimates Tables, MDOII checked Che accuracy of (he calculations and found
small inconsistencies in the values calculated. For example, in the Remove SOR>I (top 8 ft),
6" Cover, Plant I table, the risk forPa-231 should be 1.9 x 10'and the risk for Th-230 should
be 1.5 x 10"* for the Year 1000. This leads to a total risk at year 1000 of 4.8 x IO"6, instead of
the listed 5.1 x 10"6. Although there were similar errors throughout these tables, the errors are
not significant enough to warrant major concern. The 6" cover alternative risks in the 15/40/100,
50/100/150 and the 100/200/300 should be increased by 0.00001 to 3.0 x 10" and 4.3 x 10",
respectively, for Plant 2. The 6" Cover alternative risk in the 200/400/600 should be increased by
0.00001 to 2.7 x 10"* for Plant 6A. The 6" Cover Alternative risk in the 15/40/100 should be
increased by 0.00001 to 5.8 x 10' for Plant 6B. The No Cover alternative risk in the Remove
SOR>I should be increased by 0.00001 to 8.7 x |05 for Plant 6C The No Cover alternative
risk in the Remove SOR>I, 15/40/100, 50/100/150 and the 100/200/300 should be increased
by 0.00001 to 2.3 x |Q", 2.3 x |0", 9.6 x 10" and 9.6 x 10", respectively, for Plant 7. The 6"
Cover alternative risk in the Remove SOR>I and the 15/40/100, 50/100/150 and the
100/200/3000 should be increased by 0.00001 to 3.5 x 105 and 3.5 x 10s, respectively, for
Plant 7.
Small differences such as identified here may be
attributable to a number of causes. New updated versions
of RESRAD appear frequently. Different versions of the
model may account for these differences, or small
variations in input parameters.
Dose to source and risk to source ratios were computed
using RESRAD with estimated unit concentrations for
each radionuclide. These values were then imported into
a spreadsheet for subsequent concentration calculations.
This approach vastly simplified the assessment.
However, using spreadsheets to estimate dose and risk can
introduce roundoff error that may not appear by using
RESRAD exclusively. This error can be propagated
through multiple calculations and result in slightly
different answers. This is one reason that slight
discrepancies have occurred. Please also note that the
RESRAD output, on occasion, contains roundoff error
such that the doses or risks from individual pathways do
not sum to the total dose or risks. These sources of error
are usually minor and, when considering (he multiple
levels of conservatism built into each modeled dose or
risk, are insignificant.
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998)
Comments received 05/8/98, Mallinckrodt
Comment No. [
Comment
Response
General
Mallinerokdt
Lctlcr
Mallinckrodl appreciates (he opponunily Co review the Feasibility Study and Proposed Plan
for the St. Louis Downtown Site. Mallinckrodt commends the U.S. Army Corps of Engineers
for its efforts in moving this project forward. Mallinckrodt, like the Corps, is looking
forward to :hc timely completion of a practical remedial program which protects the public,
current and future employees and property owners, and the environment while providing for
continued operation, maintenance, and development of Mallinckrodt's manufacturing
activities. As discussed in the attached, Mallinckrodt encourages the Corps to select and
implement Alternative 6.
Alternative No. 6 will remediate contamination to levels which are protective of human
health and the environment. It will remove contaminated soils likely to be encountered
during routine maintenance and construction activity and therefore will allow cost-effective
operation, maintenance, and development of the facility by current or future properly
owners. It is therefore consistent with the St. Louis Site Remediation Task Force
recommendations. As this alternative will provide clean borrow in future development
areas, excavation for site maintenance and development may proceed with significantly
lower risk of encountering contaminated soils. It has increased long term effectiveness and
permanence than Alternatives 1-4. In addition. Mallinckrodl and Federal Government costs
for the management and disposal of contaminated soil generated during facility maintenance
and development will be greatly reduced when compared to all other alternatives except No.
5. Implementation of Alternative 6 is also endorsed by Federal, State, and local government
representatives and officials as well community leaders and residents.
Mallinckrodl will be pleased to review our comments with you and your staff and answer
any questions you may have. Please contact Robert Boland at 314-654-6170 if you have
any questions or comments.
After consideration of public comment, the USAGE has
selected Alternative 6 for implementation.
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
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Comments received OS/8/98, Mallinckrodt
Comment No.
PP/W
Comment
Response
Introduction
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Mallinckrodt Inc. (''Mallinckrodt") recommends that Alternative No. 6 be selected as the
preferred remedial action at the St. Louis Downtown Site (SLDS). It will impose less
restrictive use-limitations on Mallinckrodt and future property owners. Alternative No. 6
will remediate contamination to levels which are protective of human health and the
environment. It will remove contaminated soils likely to be encountered during routine
maintenance and construction activity and therefore will allow cost-effective operation,
maintenance, and development of the facility by current or future property owners. It is
therefore consistent with the St. Louis Site Remediation Task Force recommendations. As
this Alternative will provide clean borrow in future development areas, excavation for site
maintenance and development may proceed with significantly lower risk of encountering
contaminated soils. It has greater long term effectiveness and permanence than do
Alternatives 1-4. In addition, Mallinckrodt and Federal Government costs for the
management and disposal of contaminated soil generated during facility maintenance and
development will be greatly reduced when compared to all other alternatives except No. 5.
The following paragraphs provide general and specific comments on the Feasibility Study and
Proposed Plan and support the selection and implementation of Alternative 6 by the Corps.
After consideration of public comment, the USAGE has
selected Alternative 6 for implementation1. '
A. Mallinckrodt's Significant Investment in and Contribution to St. Louis
Mallinckrodt is a St. Louis-headquartered company with global operations. Mallinckrodt's
economic presence in Missouri is significant and growing. Mallinckrodt's St. Louis area
facilities have approximately 2200 employees with a total payroll of approximately $150
million. In 1997, Mallinckrodt paid a total of $6 million in state and local property, business,
and income fees and taxes. Over the past 10 years, Mallinckrodt has installed $370 million
in new manufacturing and support facilities in the St. Louis area. $200 million of this
investment was at the St. Louis Plant. Employment at the St. Louis Plant has increased by
300 over this period. As a result of these St. Louis Plant investments, an estimated 450 jobs
and an economic "output" benefit of $165 million were created in the local economy.
Mallinckrodt1 has shown a commitment to the City of St. Louis and the St. Louis area through
continued investment and expansion at the St. Louis Plant. Our plant's location in North
St. Louis helps stabilize this area. In addition, Mallinckrodt is an active corporate citizen in
this neighborhood through its ongoing work with Grace Hill Settlement House, Hyde Park
Neighbors, Clay Community Education Center, and The North Broadway Business
Association.
The importance of Mallinckrodt's operation to the
economic stability and development of the downtown area
is recognized by the USAGE.
1 Ih
slake
s I'lanl and downtown vicinity pioptrlics contain approximate!) one third of the
n the S(M.ouis Site FU3RAP program
Uilal volume nl Si l.iiuis Sue conlumiiutcd materials
Ilieri'lme. Nl.illiiit.kii
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/8/98, Mallinckrodt
Comment No.
PP/§1
Comment
Response
-
SO
B. Under FUSRAP and the Federal Facilities Aerttment. the Corps Must Remediate
All MED/AEC-Related Contamination.
As DOE's successor with responsibility for implementing the FUSRAP program, the Corps
is obligated under FUSRAP and the Federal Facilities Agreement (FFA) to remediate all
MED-AEC related residues • including both accessible and access-restricted materials. The
presence of these contaminants hinders use and continued development of manufacturing
operations at the St. Louis Plant.
The Downtown site remediation plan must recognize that Mallinckrodt has an active
manufacturing facility and that site operations will continue and expand after completion of
the work. Remedial criteria and institutional controls which are appropriate for dormant
land are not applicable and appropriate for this expanding industrial site. Alternative 4 does
not adequately address the issues associated with an active plant site. To continue
development, Mallinckrodt must be able to excavate for the construction of new facilities
and for the maintenance of those that are now being operated without having each new
construction or maintenance project, no matter how small, become a remediation project.
Consistent with the United Stales' obligation lo address all MED/AEC contamination under
the FUSRAP program, several activities have recently been completed including: remediation
of soils at City Block 1201, demolition of the 50 Series buildings, decontamination of
surfaces in K building, and demolition of former uranium processing buildings in Plants 6
and 7. See FS at p. 2-47. To facililale these FUSRAP remedial activities, Mallinckrodl has
relocated ongoing operations, utility systems (gas, water, power), and demolished structures
at a cost of approximately $7 million. Mallinckrodt anticipates working with the Corps to
facilitate remedial activities in the future.
After consideration of public comment,, the USACK has
selected Alternative 6 for implementatian Alternative 6
reduces the need for future studies, designs, and remedial
actions over Alternative 4. The USACE looks forward lo
maintaining a continued relationship with Mallinckrodt thai
supports the needs of all parlies to maintain operations and
provide cost-effective remediation.
11. The Corps Should Select Remedial Alternative 6'
Mallinckrodt recommends that the Corps select Alternative 6. Implementation of
Alternative 6 would remove contaminated soil to a depth of 4 to 6 feet and backfill Ihc
excavated site with clean fill. Contaminated soils likely to be encountered during routine
maintenance and construction activity would be removed thereby eliminating a primary
exposure risk which Alternative 4 fails to address. Alternative 6 is more consistent with
CERCLA guidance than Alternative 4, is more protective of human health and (he
environment than Alternative 4. and minimizes long term worker exposure which is
underestimated in the Corps' analysis of Alternative 4. In addition. Alternative 6 better
addresses actual site conditions including Mallinckrodl's plans for future development and
is consistent with the recommendation of the Si. l.ouis Site Remediation Task force.
After consideration of public comment, the USACE has
selected Alternative 6 for implementation
Since Ihc I'S and the I'ropo.icd I'bn aic ba.scd on the same anal)sis. MjllmckroJl s comments also apply lo Ihc 1'ioposed Plan
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/8/98. Mallinckrodt
Comment No.
(continued)
>
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pp/§/1
page 5-2
Comment
In comparing Alternative 4 to Alternative 6, CBKCLA requires the Corps to apply the
following criteria:
• Threshold Criteria
- overall protection of human health and the environment; and
- compliance with ARARs.
• Balancing Criteria
- long-term effectiveness and permanence;
- reduction of volume, toxicity, and mobility through treatment;
- short-term effectiveness;
- implementability; and
- cost.
• Moifying Criteria
- stale acceptance; and
- community acceptance.
As Alternative 6 includes excavation of contaminated soils which will be encountered
during plant maintenance and development, it will be more protective of human health and
the environment and will provide for more cost-effective operation, maintenance, and
development of the site. It therefore belter satisfies the Threshold Criteria objectives of
protection of human health and the environment and of establishment of remedial criteria
which are applicable, relevant, and appropriate for the continued use and development of an
industrial facility.
Alternative 6 also better satisfies the objectives of Balancing and Modifying Criteria than
does Alternative 4. The removal of soils which will otherwise be disturbed by continued
industrial activity at the facility will increase the long term effectiveness and permanence of
the remedy when compared (o that provided by Alternative 4. As Alternative 6 requires the
establishment of fewer institutional controls and restrictions on site activities, it has
increased implemenlability than Alternative 4. As described below, the long term costs of
Alternative 6 are no greater, if not less, than those of Alternative 4. Lastly, implementation
of Alternative 6 is supported by Federal, slate, and local officials as well as local
community residents.
The following paragraphs further demonstrate lhat the required comparative analysis favors
selection of Alternative 6.
Response
After consideration of public comment, the USACH has
selected Alternative 6 for implementation.
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/8/98. Mallinckrodt
Comment No.
PP/§/1
Comment
Response
A. Alternative 4 Poses More Risk than Alternative 6
The Corps' risk analysis shows that potential exposures to employees and construction
workers may exceed Nuclear Regulatory Commission rules for site cleanup unless
unrealistic restrictions on excavation (and hence future plant development) are imposed.
These restrictions would include prohibitions on excavation at the St. Louis Plant. This is
unreasonable at an active plant. Such restrictions on future excavation are not required by
Alternative 6.
The FS is in error when it fails to identify the exposure pathway of a construction/industrial
worker digging in soil as important. Excavation for plant maintenance and development is
a routine activity at the St. Louis Plant and represents the primary route of worker exposure,
particularly for those alternatives, such as Alternative 4, which leave contaminated soils at '
depths of six feet or less. The baseline risk assessment (BRA) identified that potential
health impacts at the Si. Louis Plant are highest- for the construction worker. In addition,
the potential for adverse impacts on human health and the environment is increased since
these future excavation projects will not be implemented as part of a single remedial effort
as would occur under Alternative 6.
To properly address this recognized risk to maintenance and construction workers, removal
of MED/AEC contamination which restricts or impedes the current and future operation,
maintenance, and development of the site must be included as a remedial objective and the
effectiveness and implemenlabilily of a remedial alternative must be evaluated on the basis of
how well the alternative accommodates current and future plant operations and development.
Future excavation activities would not be prohibited under
Alternative 4, but would require implementation of safely
measures to assure adequate worker protection. A Her
consideration of public comment the USACE has selected
Alternative 6 for implementation.
The FS ALARA assessment fully evaluated the
construction/industrial worker under a variety of cleanup
scenarios. The industrial/worker scenario was modeled as a
worker who works at the site and digs into contaminated
soil during a portion of the year. This worker scenario was
based on site-specific information, including input from
Mallinckrodt. Doth dose and risk assessments arc provided
in Appendix C of the FS.
As stated in the FS, the distribution of radioactive
contaminants at the SLDS is very similar to the distribution
of contaminants at a typical UMTRCA site. The USACE
did not intend this comparison to extend to work activities
conducted at the SLDS. Per EPA's OSWER Directive No.
9200.4-18. "Establishment of Cleanup Levels forCERCLA
Sites with Radioactive Contamination", cleanup of
UMTRCA sites "is consistent with the minimally accepted
dose limit of 15 mrem/yr effective dose equivalent (EDE)
under a residential exposure scenario for Ra-226, Ra-228,
and Th-232, and is much mure stringent for all 4
radionuclidcs " After consideration of public comment.
Alternative 6 has been selected for implementation.
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/8/98, Mallinckrodt
Comment No.
Comment
Response
>
ro
B. Site Appropriate ARARs favor Alternative 6
The FS study (see, e.g., p. 3-20, Table 3-3) does not appropriately consider soil removal
requirements associated with the future use of the property in establishing ARARs and
remedial objectives, specifically the need to:
• Provide for and allow future industrial use and development of the facility.
• Minimize the administrative and financial burden of managing contaminated soils
excavated during site maintenance and development.
• Minimize the administrative and financial burden of managing radon exposure from
access-restricted soils beneath existing and new site structures.
In selecting ARARs and evaluating risks, the FS fails to recognize that site operations will
continue and expand after completion of the work. The Corps mistakenly applied remedial
criteria and institutional controls which are appropriate for unused land but which are not
applicable and appropriate for this industrial site. Because the site is actively being .
developed, the ARARs must take into account excavation for the construction of new
facilities and for the maintenance of those that are now being operated.
Mallinckrodl believes that UMTRCA (40 CFR 192) is not appropriate for soils in an active
facility. See FS at p. 3-20, Table 3-3. The Corps is simply wrong when it states that the
St. Louis Plant is similar to "inactive" uranium processing sites where these standards
apply. See FS at p.3-9. The St. Louis Plant is anything but inactive particularly when it
comes to ongoing excavation activities for maintenance and construction. Hence, these
standards are not appropriate for this site.
Failure of the Corps to effectively address the management of soils containing above-
background radioactivity which will be routinely excavated during ongoing plant maintenance
and anticipated future development is a significant shortcoming of the FS. The Corps has .
not considered how effectively remediation alternatives allow continued operation,
maintenance, and development of Mallinckrodt's manufacturing activities and facility, nor
did the Corps consider the effectiveness of the Alternative for addressing the management
and disposal of excavated soils during these activities. Since these points were not considered,
the evaluation of Alternative 4 is incomplete. Alternative 4 would be very difficult to
implement at an active site and impossible to implement cost-effectively at an expanding site.
Alternative 6 has been selected in response to public
support. ' '
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/8/98, Mallinckrodt
Comment No.
Pp/§/U
Comment
Response
(continued)
Rather than addressing contaminated soils on a continuing and ongoing basis as the plant is
maintained and developed, it is more reasonable and practical that the Corps remove all soils
containing elevated radioactivity which will likely be encountered during plant maintenance
and development at this time and in so doing minimize (he burden and cost of management
in the future. Mallinckrodt believes the use of clean cover as well as clean nil within the
construction/excavation zone (depth of 4-6 feet, depending on location) will best minimize
potential doses and risks to construction workers and workers or the public exposed to
excavated soils, both on-sile and off-site. Removal at this lime will minimize the potential
for mismanagement at some point in the future. Alternative 6 accomplishes this. In addition,
both DOE and the St. Louis Site Remediation Task Force embraced this concept. Isolation
from radioactive materials by providing clean fill in the excavation zone is the most practical
and workable approach for remediation at the St. Louis Plant. If such isolation is not provided,
the institutional controls envisioned by Alternative 4 will be violated and the Corps will be
continually and repeatedly managing soils containing above-background radioactivity, or
development at the plant could be severely curtailed. See page 4-9, paragraph I.
The plan does not identify elimination of the potential for direct contact when contaminated
soil is brought to the surface by subsurface excavation and subsequently managed for
disposal as a remedial objective. See Page 3-29, paragraph 4. This situation will occur
whenever excavation is performed for facility maintenance or development. This pathway
has the potential to expose excavation workers, Mallinckrodt employees and contractors
working around the excavation area, and employees of waste transportation and disposal
firms who handle the excavated materials. Failure of a remedial alternative to eliminate
such exposures will increase the potential for worker exposure during facility maintenance
and construction and reduce Mallinckrodt or future property owner's ability to cost-effectively
operate, maintain, and expand the facility.
Alternative 6 would excavate soil containing more than 5 pCi/g to 6 inches deep and subsoil
containing more than 15 pCi/g to 6 feet deep in some areas and to 4 feet deep in other areas
of the St. Louis Plant. Only approved (non-contaminated) earthen fill would be used to
backfill. This remediation strategy would allow industrial use of the St. Louis Plant without
prohibition against disturbing land'shallower than 4 or 6 foot below grade. Restrictions
when excavating deeper than 4 or 6 feet, restriction against ground water withdrawal, and
provisions to manage excavation into currently inaccessible areas are expected and are
acceptable to Mallinckrodt.
To a depth of 4 or 6 feet. Alternative 6 would resolve the incompatibility between
Alternative 4's proposed restriction against disturbing land at the St. Louis Plant and
Mallinckrodt's need to maintain and change its operations. Alternative 6 also reduces the
need for future radiation protection and contaminated soil disposal accompanying
subsurface utility work, foundation construction, and grading on-stle.
Approved earthen fill would be used to backfill to depths
above 4 to 6 feet. Deeper excavations could be backfilled
using material that is below ALAKA.
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
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Comments received OS/8/98, Mallinckrodt
Comment No.
PP/§/H
Comment
Response
(continued)
Moreover, under Alternative 4, there appears lo be no safeguard during remediation against
excavating radioactivity concentration in soil greater than remediation criteria, then mixing
it to less than composite criterion, and depositing it back onto the site. Although (hat might
be effective in reducing residual radioactivity concentration over larger area, it might be
much less effective in reducing site-wide inventory of residual MGD-AEC material. And
the lower concentration, higher volume soil might still have to be dealt with in the future.
Whereas Alternative 4 depends on restriction against disturbing the remediated site to meet
ARAR, Alternative 6 is better able to meet ARAR for industrial use. Thus, Alternative 6 is
the preferred alternative.
C. The Corps has Underestimated Alternative 4 Costs
The Corps has not considered all the costs associated with implementation of Alternative 4.
As the Mallinckrodt facility and vicinity properties are developed, soils in the near-surface
building zone will be excavated by property owners and provided to the Corps for
management and disposal. In analyzing Alternative 4 in the FS, the Corps addressed neither
Mallinckrodt's nor the Corps' administrative or remedial costs of managing these soils in
the future. This soil removal will occur during utility maintenance and facility development
(foundations, sewers, elevators, etc.). The actual costs for excavation and disposal of
contaminated soil above free release criteria will be incrementally increased over those
estimates for the planned remediation because of (he smaller volumes handled and the cost
and availability of support staff resources to plan, implement, and coordinate disposal
activities. As a result, the purported savings recognized by leaving these contaminated soils
in-place are exaggerated and, at best, temporary. The Corps implicitly recognized the future
costs associated with Alternative 4 when, in analyzing Alternative 6, it said: "Alternative [6]
focuses on reducing the need for future studies, designs, and remedial actions, in addition lo
protection of human health and the environment relative to Alternative 4." FS at p. 4-25.
The Corps proposes to allow soils with concentrations 30 times higher than the appropriate
limit to remain after excavation. See FS at p. 3-10, fn. c. This will result in increased
exposures to maintenance and construction workers and increase the cost and complexity of
management and disposal of excavated soil. As such, exposures and costs associated with
those alternatives which leave contaminated soil in the construction zone are underestimated.
The USAGE agrees that Alternative 6 will reduce the need
for future studies, designs, and remedial actions for residual
soils relative to Alternative 4. Afler consideration of public
comment, the USAGE has selected Alternative 6 for
implementation.
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
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Comments received OS/8/98, Mallinekrodt
Comment No.
7
(continued)
8
pp/§/U
Comment
To appreciate the substantial future costs of soil removal which the Corps ignored in
evaluating Alternative 4, during the past three and one half years, Mallinekrodt has spent
approximately $660,000 (roughly $!90,000/yr) managing soil which contains MED/AEC
residues. These soils were generated during routine operation and maintenance and by
minor construction projects. DOE look possession of most of the soil and the Corps is
obligated to lake the remainder. Mallinckrodt estimates that it will generate approximately
340 cubic yards per year of soils containing MF.D-AEC contamination through future
routine operation and maintenance activities, and spend approximately $!95,000 per year
for heaiih-physics support and soil management and storage. The presence of radioactivity
in soils also increases the cost and complexity of site construction. During a typical
construction project, Mallinckrodt will incur approximately SI 50,000 in increased design,
coordination, and contractor costs. Fifteen hundred to two thousand cubic yards of soil will
be excavated during a typical major construction project such as installation of a new
manufacturing or support structure. Based on recent experience, Mallinckrodt will spend
approximately $400,000 per project to analyze, store, and deliver these soils (o the Corps if
construction is performed in an area containing FUSRAP contamination. Therefore, the
presence of soil contamination increases the cost of major construction projects in areas
containing FUSRAP contamination by approximately $554,000 each. Based on past
history, Mallinckrodt assumed implementing eight development projects in areas containing
MED-AEC contamination over the 30 year cost evaluation period.
Over the 30 year period evaluated in the FS, Mallinckrodt will experience increased costs of
approximately SIO million (1998 dollars) to manage the contaminated soils which will
remain on site if Alternatives 1, 2, 3, or 4 are implemented by Corps. Over the same period,
the Corps will spend approximately $1 1 million (1998 dollars) for the management,
transportation, and disposal of these soils. These expenditures were not taken into account
•in evaluating Alternative 4. When these additional costs of future soil handling arc taken
into account, there is no cost justification for selecting Alternative 4 instead of Alternative 6.
D. Alternative 4 Would Limit Future Development of the Site to the Detriment of the
Surroundine Community
The adverse impacts on the community, as well as Mallinckrodl, arc not justified by the
purported short term savings achieved by Alternative 4. Since 1980. City of St. l.ouis
employment has declined in (he services, manufacturing, and military industries. In
contrast, during this period, Mallinckrodt employment increased by approximately 100.
Further growth and the associated increased employment and community benefits arc at risk
if Mallinckrodl is unable to continue expansion in a cost-effective manner due to (he
presence of FUSRAl' residues left behind by Alternative 4.
Response
i '
The importance of Mallinckrodt's operation to the
economic stability and development of the downtown area
is recognized by the USACE. After consideration of public
comment, the USAGE has selected Alternative 6 for
implementation.
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/8/98, Mallinckrodt
Comment No.
Comment
Response
8
(continued)
Over the past ten years, Mallinckrodt has made capital investments of approximately $200
million for installation of new manufacturing facilities and upgrading of existing processes
at the St. Louis Plant. Mallinckrodt has constructed state-of-the-art laboratory, maintenance,
and warehouse facilities to support pharmaceutical manufacturing operations on previously
remediated property. Mallinckrodt anticipates constructing new manufacturing facilities
when other areas are fully remediated. Thus, continued remedial activities at the St. Louis
Plant will provide immediate economic benefit to the St. Louis area. Over the next five years,
Mallinckrodt anticipates a further capital investment of $120-150 million at the St. Louis
Plant. Mallinckrodt hopes to install approximately $30 million of this new capital in areas
remediated under FUSRAP. However, if Alternative 4 is selected, Mallinckrodt will be
unable to construct new manufacturing facilities in these areas without encountering FUSRAP
contamination. This creates a financial burden on development at the St. Louis Plant.
Elimination of future Mallinckrodt costs and restrictions which would impede operation,
maintenance, and future development of the site are best addressed by adopting Alternative 6
which provides for clean fill to depths ranging from four to six feet.
E. Alternative 6 is Preferred by Government and Community Leaders.
Alternative 4 is not consistent xviih the recommendations of the St. Louis Site Remediation
Task Force. In its September 1996 report, this task force of community representatives
recommended that soil contaminants be removed to a depth permitting general excavation
for maintenance without concern. Because it includes removal of contaminated soils likely
to be encountered during routine maintenance and construction activity, Alternative 6 is
consistent with the Task Force recommendation. In addition to support by Mallinckrodt,
implementation of Alternative 6 is supported by Missouri DNR, City of St. Louis Mayor
Harmon, St. Louis County Executive Westfall, and the St. Louis Congressional delegation.
Implementation of Alternative 6 is also supported by numerous community leaders and area
residents, several of whom voiced their support at the public meeting held by the Corps at
Clay School on April 21. 1998.
After consideration of public comment, the USAGE has
selected Alternative 6 for implementation.
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/8/98, Mallinckrodt
Comment No.
PP/§/1
Comment
Response
10
F. Requirement for Long Term Commitment
The FS provides: "inaccessible soil will be addressed at a later date when an appropriate
remedy that minimizes disruption of active facilities has been identified." FS at pp. 1-5; 4-1.
However, the Feasibility Study and Proposed Plan fail to address how the Corps will take
responsibility for the long term management of contaminated soils which are not removed
by the cleanup. The Corps, DOE, or another Federal Government entity must establish a
long term commitment to Mallinckrodt for management and disposal of residual materials if
MED-AEC materials are left on site following remediation. In contrast to the Corps'
inaccurate suggestion (hat there is uncertainly concerning the source of radionuclides at the
St. Louis Plant (FS at ES-3), the MED/AEC operations caused by far the bulk of the
radioactive materials processed at Mallinckrodt.3 It would be inappropriate and inequitable
to shift the burden of dealing with MED/AEC contamination to Mallinckrodl. The
congressional intent of FUSRAP was to relieve property owners of this burden. Moreover,
the United States is contractually obligated to Mallinckrodl to address all contamination
related lo MED/AEC uranium processing. Future responsibility must be acknowledged at
ihis lime lo ensure (hat contaminated soils do not become a burden to future property
owners or present a risk lo human health and the environment when they are disturbed
during future operation, maintenance, and development of the facility.
Mallinckrodl believes that the FS must cither address remediation of inaccessible soils
which will occur at some point in the future, provide a long term commitment that (he these
soils will be addressed when (hey become accessible, or provide for remediation of these
soils now with appropriate compensation to property owners for (he disruptions caused by
this remediation. Failure of the Corps to include these soils in the FS leaves their status and
future remediation uncertain.
In addition, the FS does not anticipate and address response actions for contaminated soils
that are not now known but are discovered in the future. Mallinckrodt and future property
owners must not be burdened with the administrative and financial costs of managing such
contaminated materials in the future.
The USAGE fully recognizes its responsibilities regarding
MED/AEC contamination at Mallinckrodt, hdwever this is
not the only source of radioactive contamination at (he
facility. In clarifying the limits of the USACE's
responsibility, there was no intent to reduce the U.S.
Government's share of the obligation lo remediate
MED/AEC related contamination.
Inaccessible soils will be addressed as a separate operable
unit. Details regarding the management of these soils and
the roles and responsibilities of the various parties will be
included in subsequent CERCI.A documentation.
The Corps essentially concedes Ihis fuel in (he IS sluling "lite Ml D/AI-C opcialion comprised most ol the radioactive materials processed al Mallinckiodl " IS al p
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SIT
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/8/98, Mallinckrodt
Comment No.
Comment
Response
II
01
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G. Corps Responsible for Chemical Contamination Resulting from Uranium
Processing and For all Contamination Commingled with MED/A EC Residues
The FFA requires (he Corps to remediate all waste, including but not limited to, radiulogically
contaminated wasle, resulting from or associated with uranium manufacturing or processing
activities conducted at the St. Louis Plant as well as other chemical or non-radiological
waste which have become mixed or commingled with radiological contaminated waste
resulting from or associated with uranium manufacturing or processing activities conducted
at the St. Louis Plant. The FS expressly acknowledges the scope of the Corps' obligations
when it cites the FFA as covering:
• All wastes, including but not limited to radiologically contaminated wastes, resulting
from or associated with uranium manufacturing or processing activities conducted at the
St. Louis Plant.
• Other chemical or radiological wastes that have been mixed or commingled with wastes
resulting from or associated with uranium manufacturing or processing activities
conducted at the Si. Louis Plant.
Areas of chemical contamination from MED/AEC activities arc therefore also within the
scope of the FFA and this remedial project.
In evaluating the extent of chemical contamination for which the Corps is responsible,
characterization activities did not attempt to identify all organic compounds used in
uranium processing. See FS at p. 2-27, paragraph 4. Consequently, characterization studies
completed to date may not have identified all of the compounds used in uranium processing
which remain in the environment.
In addition, the Corps is incorrect in stating (hat "No RCRA listed compounds were used..."
The remedy (hat is implemented must account for all of the chemical contamination
associated with MED/AEC operations. See FS at p. 2-33, paragraph 3. Acids (e.g., nitric)
and organics (e.g., TCE) were used in uranium processing and are listed hazardous wastes.
In fact, (he FS lists numerous chemicals associated with uranium processing: chemicals
associated with MED/AEC materials or processes include Irichloroethylene (ICE), dicthyl
ether, inorganic compounds such as hydrofluoric, nitric, and sulfuric acids (Harrington and
Ruehl, 1959), nitrates, calcium hydroxide, caustic soda, sodium bicarbonate and carbonate,
anhydrous ammonia, graphite, and petroleum products. FS at p. 2-25.
USAGE understands that it has responsibility for chemical
contamination resulting from pas( urani«m processing for
MED/AEC. However, (hat does no( make the USACE
responsible for cleanup of all chemicals at the site (hat may
have had some incidental use during uranium processing.
This is a particular concern given the long history of the
site as a chemical manufacturing facility.
The context inwhich the statement was made was in
considering PCOCs. A substance is RCRA hazardous if it
either exhibits a hazardous characteristic or is a listed
waste. A waste is a RCRA listed waste if it can be
demonstrated that the wasle derives from a source as
specified in 40 CFR Part 261 Subpart D. None of (he
samples tested exhibited a characteristic, nor is the specific
source of potentially hazardous conslitutents known.
Therefore, no RCRA listed and no RCRA characteristic
wastes have been delected.
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/8/98, Mallinckrodt
Comment No.
pp/§/H
Comment
Response
12
III. Conclusion
As stated above, Mallinckrodt recommends that Alternative No. 6 be selected as the
preferred remedial action at the St. Louis Downtown Site (SLDS). It will impose less
restrictive use-limitations on Mallinckrodt and future property owners. Alternative No. 6
will remediate contamination to levels which are protective of human health and the
environment. It will remove contaminated soils likely to be encountered during routine
maintenance and construction activity and therefore will allow cost-effective operation,
maintenance, and development of the facility by current or future property owners. It is
therefore consistent with the St. Louis Site Remediation Task Force recommendations. As
this alternative will provide clean borrow in future development areas, excavation for site
maintenance and development may proceed with significantly lower risk of encountering
contaminated soils. It has greater long term effectiveness and permanence than do
Alternatives 1-4. In addition, Mallinckrodt and Federal Government costs for the
management and disposal of contaminated soil generated during facility maintenance and
development will be greatly reduced when compared to all other alternatives except No. 5.
After consideration of public comment, the USACE hus
selected Alternative 6 for implementation.
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A. Inadequacy of Radon Analysis
Page 3-18, paragraph 2. This statement is incorrect. Radon emissions from materials
beneath buildings 101 and K required installation of radon control measures to maintain
concentrations at acceptable values. These soils also represent exposure risks when
subsurface maintenance is performed.
The Feasibility Study proposes, "... occupancy and use restrictions and engineered control
measures would also be implemented for buildings where radon gas is a concern."
[FS 5-32]. "... use of active and passive radon control systems and adherence to worker
safety regulations will be used to maintain safe work levels for all SLDS employees."
(FS 5-29] This, as well as routine monitoring for radon gas, are additional costs to
Mallinckrodt which has not been identified.
Statement that inaccessible soils do not pose a current risk
is not incorrect. Radon control measures are currently
mitigating potential current risk. If subsurface maintenance
is performed, these soils arc no longer inaccessible.
Radon monitoring costs are included in (he cost estimates.
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/8/98, Mallinckrodt
Comment No.
PP/§/U
Comment
Response
13
(continued)
Industrial worker scenarios assumed a 2-fooi thick zone of contamination. Yet a substantial
fraction, perhaps the majority, of radon entering a building through its floor may originate
deeper than 2 feet wherever cinder fill is relatively porous and dry.
RKSRAD models radon entry into a building by assuming diffusion from ground below and
inflow of ventilation air from outside as the motives for entry. Although argumentative
perhaps, the primary motive is apparently pressure differential between interior and exterior
of the house near the ground floor caused by the chimney effect, wind, and atmospheric
pressure drop that draws in soil gas.4,5 In view of this likely deficiency in RESRAD and
RESRAD-BUILD models, the Corps should request ANL to re-examine the radon model in
RESRAD and RESRAD-BUILD. The Corps should reconsider its estimation of potential
radon exposure within a habitable building on land containing elevated Ra"6. If the Corps
proposes to rely on the RF.SRAD model to predict indoor radon progeny concentration, it
should address these concerns.
The Corps should reconsider its estimation of potential radon exposure within a habitable
building on land containing elevated Ra"' made using RESRAD or RtSRAD-BUH-D. The
State of Missouri's prohibition on the placement of radioactive materials in landfills will
increase the cost of disposal of soils containing an^ radioactivity'above background levels.
It was not considered a relevant and appropriate factor in evaluating the acceptability of
remedial alternatives.
The contaminated zone is assumed to be 2 meters thick and
not 2 feet, as indicated in the comment. Therefore, the
source depth is probably less inadequate than thought by
the commentor. "Less inadequate" is used here specifically
because, as the commentor knows, the source of radon may
be many meters away or may be limited to the top few
inches of soil depending on the geology at the specified
location. The current model assumes a conservative yet
reasonable depth of contamination.
An accurate model for predicting indoor radon
concentrations has been quite elusive and is likely to be so
for some time. If Argonne National Labs (ANL) comes up
with a new model for predicting indoor radon, it will surely
suffer the same scrutiny that their current model must
endure. The current model is considering that the stack
effect is typically a seasonal phenomenon and reverse stack
effect conditions can apply (neither of which is necessarily
a good thing).
Na/aiofT. WM -|-:ntr> h> Picssuic-dntrn I low 01 Mnlccul.ii DilluMon ' A Reassessment ol ;;:Rn Conccnlralinns Measured in an l-:nctp>-l-:i'licicnl House " 11,-alih /'/II-IH -t_5.S. n.. (. I'p
I /CC I iCO
|. RF "fieply to "Hntry% I'ressure-dnvcn riuwtir Molecular Ditlusiun1*" Health fhys^^m. no 6 PplUO'MOII Dec 1988
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received OS/8/98, Mallinckrodt
Comment No.
14
IS
16
17
18
19
20
PP/§/H
2-3 and
elsewhere
2-25. 1 3
3-8, 1 5
Table 3-1
Table 3-1
3-10, Line 37
Comment
B. The Corns Is Correct in finding Croundwater Treatment Unnecessary
Mallinckrodt concurs with (he Corps' assessment of the overall poor conditions of
groundwaler in the vicinity of the St. Louis Plant. See FS at pp. 2-36, ES-3, 2-1 1. 2-36,
2-39,3-16,4-3.
Page 2-36, paragraph 2. Residents consuming groundwatcr from on-sitc wells and produce
from home gardens is not a realistic future use scenario for SLDS. Residential use of the
property is not a reasonable future use assumption and is therefore not a reasonable basis for
evaluation of future exposures.
Uranium processing was not performed in plant 6E to our knowledge. Some portions of
plant 6E may have been contaminated by migration of radionuclides into (he area.
It is likely that Ihc presence of coal slag and cinders in fill material has resulted in the
presence of both inorganic and organic compounds in the environment (e.g., polycyclic
aromatic hydrocarbons). PA Us are not believed to be from Mallinckrodt processing, but
from the cinder fill material. Such fill material was used throughout the river front area to
raise (lie grade elevation and allow development.
Although Ihc State of Missouri has not implemented regulations which address radioactive
contamination in soil, it has issued regulations which effectively prohibit the landfill disposal
of soils containing above-background concentrations of radioactivity. This effectively
precludes the use of Missouri landfills for disposal of soils containing FUSRAP residues in
any concentrations and creates a significant burden on property owners whenever soils are
excavated for facility maintenance or expansion.
Soil Guidelines. The guidelines list is incomplete. It appears to provide only the guidelines
in 40 CFR 192 and DOE Order 5400.5. Soil criteria for the full list of MED/AEC
radionuclides to be addressed by the project and the impact of depth on criteria are not
identified.
External Gamma Radiation. 20 nR/hr is cited as a criterion in a habitable building. 1 lowever,
7.5 uR/hr exposure rate times 2000 hr/yr occupancy would produce about 15 mrem/yr,
absent any other exposure.
The DOE interpreted the equivalent of Table 3-1 to specify a surface release criterion of
5000o(min 100 cm2), ignoring the thorium criterion. How will the Corps interpret Table 3-1
surface criteria with the prospect that thorium is present? The proposed criteria do not seem
to account for potential presence of thorium scries radionuclides.
Response
Agree.
Thank you for this information.
Agree. Additional background sampling in this fill matcria
offsite is planned to enable establishment of the source of
this contamination.
Agree.
Table 3-1 addressed the primary radionuclides of concern
for this site (Ra-226, Th-230 and U-238). Other
radionuclides (e.g. Th-232 and Actinium series decay
products) will be controlled by remediation of these
primary radionuclides.
Agree. The 20 ^iR/hr limit would likely not be used as a
guideline for areas with high occupancy.
It has been our experience (o dale that thorium scries
(Th-232 + D) nuclides are a very small portion of llie
overall site radioactivity Intnl. However, the values in
Table 3-1 for thorium would he used in separate areas
where thorium (particularly Th-23'l) was the dominant
radionuclide.
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COMMENTS AND RESPONSES ON
THE FEASIBILITY STUDY FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (April 1998) (continued)
Comments received 05/8/98, Mallinckrodt
Comment No.
21
22
23
24
25
26
PP/§^
4-7, 1 6
5-51
5-57,14;
4-10,15
5-9, 1 9
5-15,13
5-15.15
Comment
The containment alternative is not acceptable to Mallinckrodt. Such an alternative would
have significant impact on plant maintenance and development and would significantly
reduce property values.
Public Services. The statement that Alternative 4 has a low impact on utilities is not .
correct. Utilities exist in the soil horizons where residual contamination will remain.
The use of Plant 2 as a location for fill or treatment processing facility is unacceptable to
Mallinckrodt as this area is in the middle of the manufacturing facility. Moreover, as the
Corps notes: "Consolidation at Plant 2 would have an impact ort Mallinckrodl Inc.'s ability
to expand its operations. This could result in reduced employment." FS at 5-23.
Alternative 2 - Institutional Controls And Site Maintenance is not acceptable to Mallinckrodl
as it does not reduce employee exposures or impediments to facility maintenance and
development.
Alternative 3 - Consolidation and Cupping is not acceptable to Mallinckrodl as it docs not
reduce employee exposures or impediments to facility maintenance and development.
Mallinckrodl will not agree to consolidating and capping contaminated materials from
property outside their boundaries.
Response
USACE has selected Alternative 6 % implementation.
The short duration of exposure to contaminants under a
utility worker scenario effectively limits impacts to a utility
worker. However, USACE has selected Alternative 6 after
consideration of public comment.
Alternative 6 has been selected for implementation.
Alternative 6 has been selected for implementation.
Alternative 6 has been selected for implementation.
Alternative 6 has been selected for implementation.
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998)
Comments received 05/05/98, Michael Alesandrini
Comment No.
pp/§/l
Comment
Response
I
Several member companies oflhe St. Louis Regional Commerce & Growth Association have
expressed a great deal of concern over the recently released Feasibility Study/Proposed Plan
(FS/PP) with regard to the Corps' intentions to remediate the St. Louis FUSRAP. We are
concerned because certain elements of the plan do not appear to be consistent with regional
development goals.
Although regional development goals are not among the
CT'RCLA evaluation criteria, these concerns may be
considered under the CERCLA community acceptance
criterion.
Under the previous plan, the contaminated sites were lo be cleaned and made essentially
available for redevelopment. The FS/PP does not provide for such treatment. Much of the
property affected does have local market appeal. Responsible remediation planning would
seek to take advantage of such favorable market conditions. It is not clear why the FS/PP not.
only fails to leverage said conditions, but also effectively removes these properties from the
playing field in the immediate term—contaminated properties are at a distinct competitive
disadvantage in the St. Louis area as available properties can be had readily which are not
contaminated.
It is unclear what previous plan is being referenced. The
Task Force Report recommended commercial and industrial
use for Mallinckrodt, recreational for the Riverfront Trail,
and unrestricted use for the VPs. The levels of cleanup
proposed are consistent with these recommendations.
In addition to the plan's failure to envision new, short term growth on FUSRAP property, the
plan clearly does not recognize (he propensity, given historical tendencies, for near term
expansion onto remediated parcels located on the Mallinckrodt facility.
These concerns have been addressed by the selection of
Alternative 6 in the Record of Decision rather than
Alternative 4 which was favored in the Proposed Plan.
Implementation of Alternative 6 will increase the depth of
complete remediation, providing additional protection
against inadvertent intrusion.
The RCGA established a goal of generating 100,000 net new jobs by the year 2000. One of
our most pressing economic development goals is therefore lo foster expansion of existing
operations and growth of new operations in the immediate term. Clearly, the FS/PP is
inconsistent with that end. We would respectfully request, therefore, that you reconsider
your strategy for remediation of the affected real estate. •
In response to community concerns and other issues,
USACE has changed its selection of alternatives from
Alternative 4 to Alternative 6.
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
Comments received 05/06/98, Senator John Ashcroft
Comment No.
1
2
3
pp/§/H
Comment
1 have reviewed the Army Corps of Engineers' plans for remediation of the Sl.DS under
FUSRAP. 1 commend the Corps for developing these assessments and plans under a
challenging schedule. 1 look forward to the timely completion of the work and elimination of
the burden that resides from early weapons production placed on property owners.
While 1 believe cost should be one factor in deciding which plan should be implemented, it
should not be the only factor. 1 encourage the Corps to select an alternative that will
minimize the future administrative and financial burdens to property owners and minimize
impediments to future development. Please choose an alternative that will best preserve and
enhance the cost-effective development and expansion of SLDS properties and the resulting
economic benefits that flow to the local and regional community.
1 encourage the Corps to resolve the issue of continuing future responsibility for residues
which are not removed under (he current plan. Property owners must not bear a burden that
is the government's responsibility, and it is appropriate and reasonable that the mechanism
for establishing and guaranteeing such responsibility be established prior to issuance of (he
Record of Decision.
Response
USACE appreciates your interest in this project.
i i
Although development and expansion of SLDS properties
and economic benefits to the community are not valid
evaluation criteria under CERCLA, under Final Remedy
Selection the law requires reassessment of the initial
preferred alternative on (he basis of new information or
points of view expressed by the state and community. On
the basis of concerns expressed by the community, USACE
is selecting Alternative 6 in the Record of Decision.
This concern will not be addressed prior lo the issuance of
(he Record of Decision, especially for inaccessible soils.
Inaccessible soils will be addressed as a separate operable
unit in future documentation.
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
Comments received 04/29/98, William L. Clay
Comment No.
1
2
3
pp/§/^
Comment
1 have reviewed ihe Army Corps of Engineers' plans for remediation of ihe Si. Louis
Downtown Site (SLDS) under FUSRAP. 1 commend the Corps for the timely development
of these assessments and plans. I look forward to the expedient completion of this cleanup
project; it is time the St. Louis community is relieved of the burdens brought by early
weapons production.
1 encourage the Corps to select and implement Site-Wide Alternative No. 6, Selective
Excavation and Disposal. This alternative will minimize the future administrative and financial
burdens tc property owners and wiii minimize impediments to future development which
would be created under Alternative 4. Although short-term cost to the federal government will
be higher under Alternative 6, this plan will prevent the need to shin more than $10 million
in costs for the management of soils not removed by Alternative 4 from FUSRAP to property
owners. Alternative 6 will allow the most cost-effective development and expansion of SLDS
properties while spurring economic benefits throughout the community. This alternative will
also reduce the government's continuing obligation for Ihe disposal of soils excavated by
property owners.
1 encourage Ihe Corps to resolve any question of future responsibility for residues which are
not removed under the current plan. Property owners must not bear a burden that is the
government's responsibility; it is both appropriate and reasonable that the mechanism for
establishing and guaranteeing such responsibility be established prior to the issuance of the
Record of Decision.
Response
USAGE appreciates your interest in (his.projecl
i '
USACE has selected Alternative 6 in Ihe Record of
Decision for this site because of the widespread public
support for this alternative.
This concern cannot be addressed prior to (he issuance of
(he Record of Decision, especially for inaccessible soils.
Inaccessible soils will be addressed as a separate operable
unit in future documentation.
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
Comments received 05/06/98, Congressman Jim Talent
Comment No.
2
3
4
pp/§/1
Comment
Upon examining all of the proposed options for the remediation of the SLDS, 1 have decided
to support Alternative 6, which provides for selective excavation and disposal. Under
Alternative 6, all contaminated soils to a depth of 4-6 feet will be removed, and all excavated
areas will be backfilled with clean soil. This recommendation is consistent with the
recommendation of the St. Louis Site Remediation Task Force.
1 support Alternative 6 instead of the preferred alternative of the Corps of Engineers
(Alternative 4) because:
• Under Alternative 4, greater quantities of radioactive contamination will be left in the
soil. This will inhibit further development at SLDS since the ongoing management of
these soils, particularly during site development, is not addressed. Alternative 6 removes
contaminated soil from most areas likely to be involved in future maintenance and
development work.
• Also, if one considers the costs of managing these soils over the long term, there is
essentially very little, if any, difference between Alternatives 4 and 6, and Alternative 6
avoids shifting costs to property owners.
In addition to selecting Alternative 6 for remediation at SLDS, 1 urge the Corps to resolve the
issue of continuing future responsibility for contaminated soils and materials that will not be
removed. Property owners should not be required to bear the burden that is the federal
government's responsibility.
1 would like to congratulate the St. Louis District Corps of Engineers for their commitment to
cleaning up all the FUSRAP sites in the St. Louis area. In less than a year since the Corps
took over (he cleanup responsibilities for all FUSRAP sites, significant progress has been
made in formulating a thorough and acceptable remedy for the St. Louis FUSRAP sites.
Response
Agree. However, the plan is to use clean soil as backfill
only in the lop 4 to 6 feet. Below that depth, excavated
materials below the ALARA criteria may be used as
backfill.
Agree.
This issue must ultimately be resolved, but the resolution is
not a part of this Record of Decision.
USAGE appreciates your support.
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURJ (May 1998) (continued)
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Comments received 05/06/98, John Bratkowski
Comment No.
1
2
3
4
PP/§/^
Comment
After consideration of the alternatives, the Old North St. Louis Restoration Group voted in
favor of Alternative 5, the most complete cleanup. It was fell that the cost of complete
cleanup was not that much greater than Alternatives 4 or 6 and that (he nature of radioactive
waste warranted complete cleanup. It was also noted that a natural disaster such as flooding
or an earthquake in the immediate area could spread the radioactive contamination over a
much wider location than the current site.
The selection of Alternative 5 will not cause the elimination of the Mallinckrodt Company.
So, an added benefit of this alternative is that is will not cause local economic disruption.
Regardless of any short-term economic impact, as neighborhood residents, we want the SLDS
cleaned up completely, for once and for all. The cost of $140 million is reasonable considering
that it will ensure the future viability of this important part of our urban environment.
Our organization has voted unanimously to support Alternative 5. We would like our decision
to be part of the public record and for our comments to be used in guiding the complete
excavation with off site disposal of all of the radioactive waste at the SLUS location.
Response
Alternative 5 is estimated to cost $48 Million dollars more
than Alternative 4, about a 5(1% increase.'. USAGE feels
that is significantly greater cost. In response to community
concerns, USACIi is selecting Alternative 6 which is more
protective than Alternative 4 at an increased cost of $22
Million. As demonstrated by the ALARA analysis in
Appendix C of the FS, little reduction risk is achieved by
more aggressive (and expensive) remediation than is
proposed in Alternative 4. Alternative 6, by excavating to
(he most stringent criteria (o depths of 4 to 6 feet, will
further reduce the chance of inadvertent intrusion into
contaminated materials and will also reduce (he potential
for spreading of contamination through flood or earthquake
since the material will be greater depth than in
Alternative 4.
Alternative 6 also minimizes the potential economic
consequences of post remedial conditions.
Alternative 6 will meet these concerns through minimizing
the opportunity for significant exposure to residual
radioactive materials.
Your comments are part of the public record as a result of
inclusion in this Responsiveness Summary. However,
based on other commentors, support for Alternative 6
appears to be more widespread in the community than
support for Alternative 5.
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
Comments received 05/06/98, N.F. Brewer
Comment No.
PP/§/1
Comment
Response
I
RMI Environmental Services (RMIES) is a remediation company offering expertise and
specialized technologies geared to individual site requirements. We are currently the prime
contractor to DOE for remediation of a uranium extrusion plant in Ashtabula, Ohio. RMIES
is also part of a joint venture team which demonstrated an effective soil treatment pilot plant
at the Ashtabula site. Soil decontamination in the pilot scale plant was proven to be both
fiscally and technically effective, and this success led the DOE to change the baseline
remediation approach to include soil treatment. The change to soil treatment and the
extraction of uranium from the soil is expected to provide a $20 million savings over
standard soil transportation and disposal at Envirocarc. A production scale soil treatment
plant is under construction, and will begin operation this fall.
Alternative technologies which are viable and cost effective
will be fully assessed and implemented at the1 SLDS as an
integral part of remediation. Although such technologies
have not been identified to dale, additional investigations
will be conducted as appropriate to minimize remediation
costs.
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The Feasibility Study for the SLDS states that soil treatment may be a viable alternative for the
downtown site (page 3-31). Soil treatment removes contamination from the soil, substantially
reduces the quantity of soil shipped offsite for disposal, and offers corresponding reductions
in environmental impact and project costs. These potential benefits warrant an amendment to
the Proposed Plan for the SLDS so that it will specifically call for the performance of a
volume reduction via soil treatability study necessary to select and design an e(Teclive soil
treatment process.
Soil treatment is a conditional component of any and all
remedial alternatives and will be used as appropriate based
on viability and cost effectiveness. (SLDS FS para. 5.3.4,
pg 5-58)
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
Comments received 05/08/98, Rev. Richard Creason, Holy Trinity Church
Comment No.
PP/§/1
Comment
Response
I
Pursuant to the public meeting at Clay CEC on Tuesday, April 21. at which I made oral
comments, I am now providing my opinion in writing concerning cleanup of (lie
Mallinckrodl site. My opinion is not a scientific one, rather it is from a pastoral point of
view. I hope that it will be given adequate consideration for it is a holistic view that is being
offered.
USACK appreciates multiple perspectives on the issues
involving SLDS remediation. ' '
When I view the historical development of the Hyde Park community, I see it as always
having been a working class community: factory workers trades people, and shop keepers.
This parish, founded in 1848, has been at the heart of this community seeking to connect
family, faith, and human dignity. In any era, when people launch out on this path, three
elements are important: I) Where will I live? 2) Where will my children go to school?
3) Where will I shop for needed goods and services? Add on to that the larger questions of
meaning: I) Where will I find meaningful employment? 2)Where will faith and spirituality
be nurtured, that is, will there be churches to serve a spectrum of belief?
Now 150 years later, in the Hyde Park community, these concerns are even more critical:
I) 50% of households have an income below $ 15,000 per year (second lowest in St. Louis
City); 2) the unemployment rate is 12.7%; 3) According to Project Respond research (1997),
children in zip code 63107 are more at risk than any other neighborhood in the City of
St. Louis; and 4) The dropout rate for St. Louis City Public Schools is almost 25%, the
highest in the metropolitan area.
Noted.
Mallinckrodl, Inc., has been a corporate citizen in the Hyde Park community as well for over
100 years. I can only speak from a perspective of the last three years that I have been the
pastor of Holy Trinity Church, but my experience is that Mallinckrodl has been very active in
community affairs. Mallinckrodt is an anchor; if we were to lose this plant because of
relocation, it would spell disaster for North St. Louis.
Noted.
Because Mallinckrodt is willing to stay in this community, the issue of remediation of
hazardous soil at their plant site on North Broadway takes on greater importance in terms of
future development. Having heard all of the proposed remedies at the public hearing, I want
to reiterate my support for Alternative 6, that is to remove (he contaminated soil and to
replace the soil in (he near surface of the building zone. This will allow Mallinckrodt to
redevelop this site and enhance their investment.
USACE has selected Alternative 6 in the Record of
Decision in response to community support for Alternative
6.
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COMMENTS. AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
Comments received OS/08/98, Douglass Eller
Comment No.
1
2
3
PP/i/^
Comment
1 attended and testified at the Tuesday, April 21st, public hearing at Clay Elementary School.
1 work in the neighborhood with an environmental project developing the Riverfront Trail
that runs between Mallinckrodl and the river. 1 am also active with neighborhood issues in
Hyde Park and live on North 20th Street with my wife and two children. Our neighborhood
has an annual income averaging $7000 per family. More than 60% of the community does
not hold a high school degree. Little interest or caring exists for the neighborhood outside of
its community borders. Very few "anchors" (neighborhood stabilizing forces) remain. And
business anchors are even rarer.
Mallinckrodt, Inc., has been a real strength to neighborhood improvements, particularly
through the contribution of time and expertise by their staff. Mallinckrodt has brought area
neighborhood organizations together, helped plan events, strategized with residents on political
issues, supported small businesses, encouraged the recovery of chemically addicted parents,
fostered solutions to environmental issues, employed area residents, and revealed its waste
disposal practices in an open manner. The company has also invested funds to strengthen
community efforts. Mallinckrodt is our business anchor that we cannot afford to lose.
As I understand the issues, without the soil contamination removed to a specified level,
Mallinckrodl cannot reinvest with new construction on those sites within its grounds. Our
neighborhood must have Mallinckrodt remain a viable entity. My comments are in vigorous
support of Alternative 6, as described in the Proposed Plan for the St. Louis Downtown Site.
1 feel that if more effective publicity was given within our neighborhood for the public
meeting, a greater showing of support for Alternative 6 would have been demonstrated.
Response
Noted.
USACF. has selected Alternative 6 in the Record of
Decision at this site in response to community concerns.
Noted.
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
Comments received 05/08/98, Melvia J. Forniss
Comment No.
PP/§/1
Comment
Response
I
Mallinckrodt Chemical Company has been very supportive of Grace Hill Family Center
clients, staff, and the community. Mallinckrodt has made many contributions, donations, and
volunteer lime to families of the Family Center for over six years. Grace Hill Family Center
recommends to the Army Corps of Engineers to select Alternative 6 so (hat Mallinckrodt
Chemical can remain in our community.
The Grace Hill Family Center is the only long-term residential treatment program in the State
of Missouri providing services to pregnant and post-partum substance abusing women and
their children. It is also currently the only treatment program of any kind on the north side of
St. Louis. The Grace Hill Family Center opened on March 4, 1994. It has served 148
women and 174 children since it opened. Thirty-two babies have been born drug free since
that time. This fact has saved the state and estimated $900,000 in neonatal medical costs to
dale. The Grace Hill Family Center is a comprehensive program which offers intensive
substance abuse treatment, education, job training, and medical services in the frame of work
of community based self help.
USACI-; has seleclcd Alternative 6 in the Record of
Decision for SLDS in response to community concerns.
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
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Comments received 05/06/98, Hyde Park Eco-Justice Community
Comment No.
pp/§/H
Comment
Response
I
At a recent meeting of the Old North St. Louis Restoration Group, we learned of the effort
being made to clean up the radioactive contamination at the Mallinckrodl Site. Because of
our interest in ecology, we were encouraged to know that the Corps of Engineers was looking
at this dangerous piece of property located so close lo our neighborhood and trying to come
up with some solutions.
Of the six alternatives listed on the Proposed Plan, only Alternative 5 offers any real or
permanent protection to the people who live nearby. To do anything short of complete
excavation with offsite disposal makes no real sense. We would like to encourage you to
choose Alternative 5 which would remove at least one of the many environmental health
risks in this section of St. Louis.
An analysis lo determine the risk from rqsidual materials
for various cleanup levels criteria was petforrned in order to
determine the most cost effective cleanup criteria that
would be protective of human health and me environment.
The results of this analysis, which are published in
Appendix C of the FS, indicate Alternative 4 provides the
best balance between cost and risk. In response to public
comments. USAGE has selected Alternative 6 in this
Record of Decision. Alternative 6 extends the depth of
excavation for the most stringent criteria to a depth of 4 to
6 feel. This will offer both real and permanent protection
to the residents of the community.
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
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Comments received OS/08/98, Donovan Larson
Comment No.
1
PP/§/1
Comment
Since Ihe FUSRAP meeting Ihis morning, certain residents of the neighborhood surrounding
Mallinckrodt have contacted me and expressed unhappiness about their ability (o comment
on Ihe SLDS FS/PP and associated decision. Perhaps an extension of the comment period
would be reasonable to allow these unheard voices to be given a chance to comment.
Response
The USAGE followed applicable CERCLA guidance in
notifying residents about the public medting. We regret
that not all residents received notification in time to attend
the public meeting and comment on the FS/I'P. However,
overwhelming stakeholder response has caused USAGE to
reconsider selection of the preferred alternative.
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
Comments received 05/06/98, St. Louis Sites FUSRAP Oversight Committee
Comment No.
PP/S/1
Comment
Response
I
After reviewing Ihe Feasibility Study and Proposed Plan submitted by the USAGE for
remediation under FUSRAP of the St. Louis Downtown Site, the St. Louis Sites FUSRAP
Oversight Committee unanimously recommends that the USAGE implement Alternative 6,
Selective Excavation and Disposal, rather than Alternative 4 for remediation ofSLDS. The
SLSFOC believes that Alternative 6 is more protective of human health and will be more
conducive to the continued long-term growth and operation of the Mallinckrodt St. Louis Plant.
Agree. USAGE will select Alternative 6 in the Record of
Decision in response lo widespread community support.
The selection of Alternative 4 by the USAGE is not consistent with the recommendations of
Ihe St. Louis Site Remediation Task Force. Alternative 6 appears to best meet the
community's wishes as expressed in Ihe SLSRTF final report submitted to DOE.
USAGE believes both Alternatives 4 and 6 are consistent
with the Task Force recommendations. However,
Alternative 6 has been selected in response to these and
other community comments.
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it also appears that the USAGE has not considered all the costs associated with implementation
of Alternative 4. USAGE has not included the cost of managing, excavation, handling, and
disposal of near-surface soils thai will be removed as a result of ongoing maintenance and/or
development activities at the SLDS. Excavation of soils during maintenance and/or
construction work in Ihe 4-5 foot depths that remain under Alternative 4 could result in (he
unacceptable exposure ofsiic employees or construction workers to residual radiological
contamination. Additionally, the potential for adverse impacts on human health and the
environment is increased as these smaller excavation projects will not be implemented as part
of a single remedial effort.
These costs could not be predetermined because the
volumes of these potential future excavations and the
frequency of such intrusions could not be estimated with
any degree of certainty. The FS does acknowledge the
potential for these additional costs but docs not attempt to
quantify them.
The presence of radioactive contamination which will remain in place under USAGE'S
Alternative 4 and resultant restrictions on development of (hat site will likely have a significant
adverse impact on (he future investments in Ihe SLDS by Mallinckrodt. These future
decisions on investments will also have an adverse economic and social affect on the
community surrounding this site and the Metropolitan S(. Louis area as a whole.
These effects do not fall within the evaluation criteria
required by CERGLA. However, considerations of stale
and community points of view arc required in the final
remedy selection. In response lo these community
concerns USAGE has selected Alternative 6.
The SLSFOC requests that the USAGE revise its proposed plan to recommend the
implementation of alternative 6 for remediation of the SLDS. Additionally, the SLSFOC
reminds the USAGE that the SLSRTF had recommended to Ihe USDOE that Ihe SLDS
Vicinity Properties be cleaned up to standards that provide for unrestricted future use. The
proposed plan should be modified to reflect the community's desire that vicinity properties,
whether in North County or Downtown St. Louis, should be cleaned up to the same
unrestricted standards.
The proposed plan will not be revised. The Record of
Decision has selected Alternative 6 as the preferred
alternative and provided reasons for changing from the
Proposed Plan in the Explanation of Significant Differences
Section. This section also specifies Ihe more stringent
standard for the vicinity properties.
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
Comments received OS/06/98, Nancy Weber
Comment No.
1
2
3
PP/§^
Comment
The proposed plan for (he cleanup of the Mallinckrodl Plant is not consistent with the
recommendations of the Remediation Task Force. The USAGE has not considered all the
costs associated with the implementation. Mallinckrodl is a viable and growing business in
the St. Louis area and any plan that is recommended should have a positive impact on this
facility and the surrounding area.
Please consider alternative plans that would not have an adverse effect. The feasibility and
proposed plans failed to address how the Corps or other government agencies would take
responsibility for long-term management of contaminated soil which are not removed by the
cleanup. Who will take future responsibility for this project?
The presence of radioactive contamination which will remain in place under the
recommendation will have significant impact on Mallickrodt and the surrounding areas.
Please look to an alternative plan that would not have an adverse impact on this area.
Response
USAGE has selected Alternative 6 for implementation
instead of Alternative 4, which was identified as the
preferred alternative in the proposed plan, due to
community concerns such as are expressed by this
comment.
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
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Comments received OS/05/98, R.M. Wester & Associates
Comment No.
Comment
Response
I
1 have only recently received a fax copy of a letter dated April 8, 1998, well afler the public
meeting of April 21, 1998.'which announces a distribution of IheSLDS FS/PP via the Internet
and availability of (he document at several libraries for review. May I point out (hat none of
these libraries are within easy access to those of us interested who reside in St. Charles County.
I have requested a copy be sent to me via the U.S. Mail, and may I also request that I be
maintained on file to receive any and all notices of meetings and document distribution in the
future. I participated in all proceedings and served on subcommittees for the St. l.ouis Task
Force for several years while the remediation programs were under the Department of
Energy, and I feel that with the change in responsibility from DOE to the Corps of Engineers
many of us who are interested have been lost and no longer kept abreast of your plans for
remediating the various affected areas of our region.
USAGE welcomes input from all interested citi/ens.
I understand that people and businesses in the region of the Downtown Site have voiced
concerns about the overall approach, and that the approach in fact deviates significantly from
(hat which was the desire of the participants of the original Task Force. If this is true, then I
am very concerned because it would seem that the Corps of Engineers has taken several steps
backwards. One of the last scries of meetings that I attended included the presentation of a
document which fully described the wishes of the local community to the responsible parties
of the DOE
We believe the approach taken at SLDS is consistent with
that recommended by the Task Force.
It seems to me that the Corps of Engineers could begin making progress in remediating the
sites much sooner, with cost-effective measures, by following the community guidance
documents. After three years of tedious deliberation by the state and local governments,
along with industry and affected private parties, the challenges were successfully overcome,
and this document of recommendations represents the consensus of opinion which provided
solutions to remediate these properties.
The alternative selected recognizes the predicted future use
of the impacted properties recommended by the Task Force
Report.
The National Research Council has recommended that the decision maker incorporate all
relevant stakeholders in the decision-making process from the start. It is further recommended .
that an analytic-deliberative process be employed !o deal with decisions that involve all
stakeholders. The basic premise is that, by employing the analytic-deliberative process with
the participation of the stakeholders, the decision-making process will be enhanced, and the
previous failing and cause for mistrust will be overcome. This basically describes the process
(hat the stakeholders went through to arrive at the unanimous decision for the directives
issued in the report. I further recommend that the document submitted as the final report of
the Si. Louis Task Force be the beginning of your work, and the effort and lime devoted to
develop this report not he discarded or wasted.
We agree that incorporation of stakeholders needs is a
relevant and necessary part of ifie pioccss. On the basis of
that, USAGE has chosen Alternative 6 as the remedy to be
implemented at SLDS
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COMMENTS AND RESPONSES ON THE
FEASIBILITY STUDY AND PROPOSED PLAN FOR THE ST. LOUIS DOWNTOWN SITE
ST. LOUIS, MISSOURI (May 1998) (continued)
Comments received 05/08/98 from Shannon D. Work - Civens, Funke & Work (Attorneys at Law)
Comment No.
PP/H
Comment
Response
Letter
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I am Special Legal Counsel to the Spokane Tribe of Indians on various natural resource
matters. You may recall that last month I submitted to you a letter similar to this
concerning the St. Louis Airport Site and Hazelwood Interim Storage Site EE/CA
documents. You may also recall I explained that one of the matters on which I work for
the Tribe concerns an inactive uranium millsite located just off the Spokane Indian
Reservation, but immediately adjacent to it and to an important Reservation waterway
known as Chamokane Creek. Operated for decades by Dawn Mining Company, (he
miiisiie is known io contaminate both surface and ground waters, including waters to
which the Tribe holds federally protected and adjudicated rights. Sec United States v.
Anderson, 736 F. 2d 1358 (9lh Cir. 1984). Under its off-reservation authority, the State of
Washington in February 199S licensed Dawn to convert a vast open impoundment at the
site into a disposal cell for Atomic Energy Act I le (2) byproduct material. Due to
unresolved concerns for the health and safety of Reservation residents and visitors, as well
as for Tribal trust resources, the Tribe has consistently opposed Dawn's waste and visitors,
as well as for Tribal trust resources, the Tribe has consistently opposed Dawn's waste
importation proposal.
These comments arc submitted on behalf of the Spokane Tribe regarding the USAGE'S
Feasibility Study/Proposed Plan (FS/PP) Documents prepared in support of proposed
actions to remove for off-site disposal radioaclively contaminated soils from the St. Louis
Downtown Site (SLDS). Although these documents do not appear to specifically describe
the presence of I l.e(2) byproduct material, these comments are nonetheless submitted to
raise issues of specific impacts to the Spokane Indian Reservation anticipated to be caused
by alternatives which require off-site disposal, in the event removal of 11 e(2) byproduct
material from the site is contemplated.
The USACE has not yet selected the disposal location for
soils to be removed from SLDS. Only appropriately
licensed or permitted facilities will be considered at the
time of disposal. The disposal facility will be determined
in accordance with all applicable laws and regulations
including federal procurement laws and the EPA
regulations on Federal use of offsite disposal facilities
stated in the NCP, 40 CFR 300.440.
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ATTACHMENT A-l
MDNR Hazardous Waste Program Comments on Mallinckrodt's
RCRA Facility Investigation Work Plan
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STATE OF MJSSOi.K/ •• ........ •••• .......... - -• .......... •••••••» ..... •'••
DEPARTMENT OF NATURAL RESOURCES
DIVISION Of OVIKON.VCNTAL Ol'
FO L^OA i~.'i .K'lTcr.vin i".iiv MO foli
May 7, 1998
CERTIFIED MAIL # Z 290 135 114
RETURN RECEIPT REQUESTED
Mr. Mark Puett
Mallinckrodt Chemical, Inc.
P.O. Box 5439
St. Louis, MO 63147
RE: RCRA Facility Investigation Work Plan, Newly-identified Solid Waste
Management Units Report and Permit Appeal-related Comments for Mallinckrodt
Chemical, Inc , St. Louis, Missouri. Permit #MOD096726484
Dear Mr Puett:
The Missoun Department of Natural Resources' (MDNR) Hazardous Waste Program
(HWP) has completed review of the RCRA Facility Investigation (RFI) Work Plan dated
January 16, 1998. The RFI Work Plan was submitted pursuant to Corrective Action
• Condition V. of Mailinckrodt's Missouri Hazardous Waste Management Facility Permit
(hereafter referred to as the Part I Permit) dated September 19. 1997.
As you are aware, investigations performed pursuant to the RFI Work Plan must
ultimately be sufficient to address the RFI objectives contained in Corrective Action
Condition VI. of the Part I Permit. In general, the RFI Wcrk Plan satisfactorily
addresses the specific elements of investigation as they relate to individual Solid Waste
Management Units (SWMUs) and Areas of Concern (AOCs) identified for furtf-er
investigation in the Part I Permit. There are, however, a few exceptions Comments
concerning specific technical deficiencies in the RFI Work Plan and additional
requirements related to the Newly-Identified SWMUs Report are provided beicw under
the Technical Comments heading. Of greater concern is the broader conceptual
approach to site investigation proposed in the RFI Work Plan. Comments concerning
this approach are also provided below. Based on the HWP's review, Mailinckrodt's RFI
Work Plan is hereby disapproved until all of the following RFI-related comments are
satisfactorily addressed.
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Mr. Mark Puett
May?, 1998
Page 2
As part of the review of the RFI Work Plan, the HWP also reviewed Mallinckrodt's permit
appeal letter of October 20, 1997, and the associated preliminary appeal resolution
proposal dated January 14, 1998. The HWP felt this review was necessary inasmuch
as resolution of the appeal may bear directly on the content of the RFI Work Plan The
HWP believes that the permit appeal may still be resolved via a permit modification,
however, Mallinckrodt's proposed resolution must be rejected in its current form.
Specific discussion of this topic can be found below under the Permit Appeal heading.
GENERAL COMMENTS
The HWP agrees that Mallinck/odt's screening evaluation may be limited to gathering
only the information necessary to determine whether a release of hazardous waste
and/or hazardous constituents has occurred at SWMUs 8, 14, 15, 20, and 27. and
AOCs G and I. The RFI Work Plan must, however, acknowledge the need for further
investigation, including a determination of the nature and extent of contamination at
those SWMUs/AOCs demonstrating confirmed releases as a result of the screening
evaluation. Mallinckrodt may wish to consider incorporation of a step-out contingency in
the RFI Work Plan in the event that obvious contamination is identified in the field during
the screening evaluation. This would provide Mallinckrodt with explicit flexibility, once
the RFI Work Plan is approved, to make field decisions regarding additional
investigation to determine the extent of any release(s) at the time they are discovered,
thus minimizing the scope of further investigation required as part of implementation of
a Phase II RFI Work Plan. The HWP encourages Mallinckrodt to consider establishing
a step-out provision which relies on use of best professional judgement in the Held to
minimize the iterations necessary to complete all necessary site characterization. Once
the RFI Work Plan is approved, the HWP must be consulted, if possible, prior to any
significant deviations from the approved work plan. When contacted, the HWP will
attempt to expedite any regulatory decisions at that time regarding additional field work
proposed by Mallinckrodt.
Regardless of Mallinckrodt's initial investigation methodology, the HWP may determine
that additional investigation is warranted based on the findings and/or quality of the data
gathered dunng the SWMU/AOC screening evaluation. This must be acknowledged in
the revised RFI Work Plan, including the specification that a Phase I'l RFI Work Plan
and investigation performed thereunder may be required to satisfy the RFI objectives
contained in Corrective Action Condition VI. of the Pad I Permit
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Mr. Mark Puett
May 7, 1998
Page 3
TECHNICAL COMMENTS
Section 3.3.2. SWMU 14 and 15. page
This section indicates that in the absence of sensory evidence of contamination from
the soil borings, the soil samples will be collected from a depth of five feet below ground
surface at both boring locations. The HWP concurs with this approach for collecting soil
samples at SWMU 14, only. Given the potential for release of contaminants at or below
this depth at the SWMU 15 wastewater sump, the bottom of which is at a depth of 10
feet below ground surface, soil samples must be collected just below the level of the
bottom of the wastewater sump even in the absence of sensory evidence. If evidence
of a release(s) of hazardous waste or hazardous constituents is detected via field
screening measurements (e.g.. PID or FID readings), samples must be collected for
laboratory analysis to confirm/deny the presence of a release. If the laboratory
analyses confirm a release at any of the SWMUs/AOCs, additional soil and/or
groundwater sampling will be required to define the vertical and horizontal extent of
such contamination. As indicated above. Mallinckrodt may want to consider modifying
the RFI Work Plan to specify a field contingency for further sampling in the event that
obvious contamination is identified during the screening evaluation. The RFI Work Plan
must, in any case, be revised to acknowledge the need for further investigation if a
release(s) is discovered at the referenced SWMUs/AOCs.
Section 3.5. Data Evaluation Protocol, pace 3-8
The last two sentences of this section propose an approach for identifying areas
requiring further action by comparing analytical results to site-specific industrial risk-
based screening levels without identifying those levels and explaining where such levels
came from or how they will be derived. It matters not. as Mallinckrodt cannot predicate
completion of site characterization on industrial risk-based screening levels.
Characterization using such criteria will not meet the RFI objectives contained in
Corrective Action Condition VI. of the Part I Permit.
During the corrective action investigation process, risk-based "point of departure"
concentrations (e.g.. EPA Region III risk-based concentrations. Missouri Department of
Health's proposed Any-use Soil Levels (ASLs). Proposed Subpart S Action Levels,
Superfund Soil Screening Levels (SSLs)) may have utility in defining contamination
"hot-spots," indicating the need for immediate stabilization or interim measures,
triggering further investigation efforts and/or suggesting the need for a Corrective
Measures Study (CMS). These 'point of departure" concentrations should not,
however, be misconstrued as contamination extent investigation criteria or default
clean-up levels. If Mallinckrodt desires to clean-up to industrial levels, justification in the
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Mr. Mark Puett
May?. 1998
Page 4
form of a site-specific risk assessment will be required (o ensure protection of human
health and the environment. This assessment must consider and address, among other
things, the nature, extent and migration potential of any released contaminants, current
and future land use; plausible contaminant exposure routes, exposure scenarios and
contaminant receptors; potential off-site impacts; and long-term institutional and/or
engineering controls. Hence, any site-specific risk assessment will have to be based on
characterization of contaminant releases to levels which are sufficient to address these
issues.
As indicated above, the HWP agrees that potentially applicable "point of departure"
contaminant concentrations must be considered within the context of site
characterization, but not in the manner described by Malhnckrodt. In the HWP's
experience, site-specific risk assessments are often initiated during the RFI; however,
the information necessary to identify actual/potential exposure pathways, concentrations
and receptors is often not available until the RFI is complete or nearly so The
appropriate time to comprehensively address clean-up levels, which can be based on a
site-specific risk assessment, is during the evaluation of corrective measures
alternatives as part of the CMS. In order for this evaluation to be valid, the site has to
have been adequately characterized as to the extent of contamination, thereby enabling
identification of actual/potential contaminant exposure pathways, concentrations and
receptors.
Section 3.3.6 AOC I. page 3-6
This section indicates that the Department of Energy/U.S. Army Corps of Engineers
(DOE/USACE) has investigated groundwater at the facility pursuant to their FUSRAP
obligations and that the need for groundwater corrective action measures at the facility
will also be evaluated under FUSRAP. As discussed previously with Mallinckrodt and
• as referenced in other sections of this letter, the HWP is willing to accept
DOE's/USACE's groundwater-related data in partial satisfaction of the corrective action
requirements of the Part I Permit. It is Mallinckrodt's responsibility to ensure that this
data is integrated into the RFI Report. Mere reference to this information is
unacceptable. Mallinckrodt should also recognize that DOE's/USACE:'s groundwater-
related data, while helpful, is not expected by itself to sufficiently address the RFI
objectives of Corrective Action Condition VI. of the Part I Permit.
The HWP expects Mallinckrodt to take an active role in investigating the extent of
groundwater contamination at the facility outside of the FUSRAP areas (including off-
site if necessary). The HWP also expects Mallinckrodt to take an active role in
investigating the extent of groundwater contamination within the FUSRAP areas to the
extent that chemical or radiological contamination is present which cannot be attributed
to DOE'S historical activities and for which DOE/USACE ultimately assumes no
responsibility
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Mr Mark Puett
May 7, 1998
PageS
At this point, it i§ unclear what the division of responsibility is or will be between
Mallinckrodt and DOE/USACE for chemical and/or radiological contamination of
groundwater both inside and outside the FUSRAP arsas. Based on review of
DOE's/USACE's preliminary Summary and Analysis of the 1997-1998 Baseline
Groundwater Sampling Data for the St Louis Downtown Site dated March 1998, it is
evident that substantial releases of chemical and radiological contaminants to
groundwater have occurred at the facility. It is also evident that additional investigation
is warranted to characterize these releases'and determine whether or not they pose an
actual or potential threat to human health or the environment. The RFI Work Plan must
acknowledge that the groundwater-related information generated by DOE/USACE as a
function of their FUSRAP obligations may be insufficient to assess the presence/
absence and extent of release(s) of hazardous waste and hazardous constituents to the
groundwater across the entire site. This information, at least with respect to the latest
assessment, is limited to the FUSRAP areas. Again, this information may be used by
Mallinckrodt for site characterization purposes and to focus any additional groundwater
investigations consistent with Corrective Action Condition V.D. of the Part I Permit.
Based on review of the above-referenced DOE/USACE Summary Groundwater Report
and considering the basic conceptual model of groundwater flow in similar alluvial
systems, it appears that further investigation of the extent of groundwater
contamination, both inside and outside of the FUSRAP areas, will be required.
Inasmuch as the division of responsibility between Mallinckrodt and DOE/USACE for
such investigation has not yet been fixed, the HWP is willing to defer Mallinckrodt's
active investigation of the groundwater to Phase II of the RFI. The HWP would prefer
that Mallinckrodt take an active role in groundwater investigation at this time including
reconciliation of the division of responsibility with DOE/USACE leading to incorporation
of provisions for such investigation in the revised RFI Work Plan. Mallinckrodt is
advised that submission and implementation of a Phase II RFI Work Plan is a virtual
certainty to the extent that Mallinckrodt chooses not to incorporate groundwater
investigation provisions for non-FUSRAP areas into the revised RFI Work Plan.
To the extent that active groundwater investigation is proposed in the revised RFI Work
Plan, the Health and Safety Plan contained in Volume III of the original RFI Work Plan
must be revised to ensure that groundwater-related RFI activities including, but not
limited to, monitoring well installation, development and sampling are conducted in a
manner that is protective of human health and the environment.
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Mr Mark Puelt
May 7. 1996
PageS
Section 2.6. Potential exposure pathways and receptors, page 2-6
This section indicates that potential exposure pathways are incomplete because the
ground surface at the facility is almost entirely covered by pavement/buildings and the
industrialized setting does not provide habitat for living species It would be much more
appropriate to state that exposure pathways are potentially incomplete versus
potential exposure pathways are incomplete There is no technical foundation or
substantive basis for the latter statement. Adequate site investigation, including
determination of the nature, extent and rate of migration of released contaminants, is
necessary to support any speculation that potential exposure pathways are incomplete
This is an integral part of any effort directed towards site-specific risk assessment to
establish clean-up levels which are protective of human health and the environment
The HWP is aware of and has reviewed information regarding other sites in the
St. Louis downtown area which, despite paving of the facility and current lack of
groundwater use for drinking purposes, demonstrate significant potential for exposure to
contaminants in soil and groundwater via plausible exposure pathways (e.g., subsurface
utility excavations, contaminated groundwatsr and vapor seepage into sewers/subgrade
structures and operation/maintenance of sewer pump stations and associated
dewatering wells).
The HWP acknowledges that the Mallinckrodt facility is located in downtown St. Louis m
an area that has been heavily industrialized for more than a century and as such is rot
in an environmentally "pristine" condition by any definition. Simply determining what a
"naturally-occurring" condition is would be extremely difficult. However, to the extent
that any release of hazardous waste and/or hazardous constituents poses an actual or
potential threat to human health or the environment, it must be addressed by
Mallinckrodt.
With respect to groundwater at the facility. Mallinckrodt is located on the Mississippi
River floodplain. The facility is underlain by a major groundwater aquifer that extends
from the northern reaches of the Mississippi River to the Gulf of Mexico. This aquifer
supplies groundwater for private, public, and commercial uses throughout most of its
extent. The HWP recognizes that the Mississippi River alluvial aquifer in the general
vicinity of the facility is not currently used for public water supply. However, the
potential for future use cannot be discounted. The quantity and general quality of the
water in this aquifer is adequate and suitable for many uses. Protection of the aquifer is
reasonable and must be considered given the volume and reliability of the water
present. The HWP recognizes that, treatment of water obtained from {his alluvial
aquifer may be necessary prior to consumption or other use. The extent of treatment
required may be impacted by man-made influences on the aquifer. However, the fact
that treatment may be necessary or that man-made impacts may have influenced the
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Mr. Mark Puett
May 7. 1998
Page 7
aquifer does not justify ignoring contamination risks that would or could cause
degradation of-water quality beyond reasonable limits for standard treatment by a user
All investigations and corrective measures at the facility must include efforts to identify
and mitigate, to the extent required for human health and environmental protection,
contaminants released to the groundwater including consideration of the alluvial aquifer
as a usable water supply.
Although groundwater may not be currently used as a source of drinking water, its
potential use as a potable or industrial water source must be considered. The quantity
of groundwater needed for public or industrial water supply is available in the alluvium at
the facility. The alluvial groundwater may not be potable, but potential exposure to
contaminated groundwater or contamination derived therefrom is still a real possibility.
Mallinckrodt must demonstrate, through site-specific investigation, risk assessment,
corrective measures and/or implementation of institutional/engineering controls, that the
groundwater pathway is incomplete, the risks to human and environmental receptors
are insignificant and/or that implementation of corrective measures will mitigate any
significant human health and/or environmental risks that are identified
Mallinckrodt's Assessment Report for Newly-Identified SWMUs at the Mallinckrodt
St. Louis Facility dated January 20, 1998, confirms a release(s) of hazardous waste
including hazardous constituents (i.e.. volatile and semi-volatile organic compounds and
metals) to the environment at the former tank car unloading area east of Building 63
(newly-identified SWMU 41). This confirmation is based on voluntary investigation
conducted by Mallinckrodt in 1996. The HWP has determined that further investigation
is warranted to define the nature and extent of releases at SWMU 41. The RFI Work
Plan shall, therefore, be revised to address the nature and scope of investigation at
SWMU 41.
PERMIT APPEAL
As to the language originally proposed in Mallinckrodt's October 20, 1997, appeal letter
to resolve the issue of Mallinckrodt's versus DOE's (now including the USAGE'S)
remediation responsibilities, this language is rejected, primarily due to use of the term
"completion." Mallinckrodt would become responsible only "after completion by DOE of
all remediation activities." There are no criteria to define what constitutes "completion,"
thus rendering this term highly subjective. There is also no discussion or
acknowledgment of who would determine "completion" or how such a determination
would be memorialized.
As to Mallinckrodt's appeal resolution follow-up letter of January 18. 1998, the flow chart
attached to this letter does not accurately represent the HWP's vision of the corrective
action process at the facility (refer to site characterization discussion under General
A-87
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Mr. Mark Puett
May 7, 1998
Page 8
Comments above). Specifically, final corrective action chemical and/or radiological
clean-up standards for contaminated environmental media cannot be established prior
to addressing the RFI objectives (including characterization of the nature, extent, and
rate of contaminant migration) contained in Corrective Action Condition VI. of the Pan I
Permit. During the corrective action investigation process, risk-based "point of
departure" concentrations may be useful as discussed above, but should not be
misconstrued as contamination extent investigation criteria or default clean-up levels.
Again, if Mallinckrodt desires to clean-up to industrial levels, justification in the form of a
site-specific risk assessment will be required to ensure protection of human health and
the environment. This assessment must consider all relevant factors, including those
outlined above.
In addition to the foregoing clean-up standards issue, the flow chart has a decision item
entitled "Was there a SWMU in this area historically?" Whether there was or was not a
SWMU in the area addressed by DOE/USACE is largely irrelevant from a corrective
action standpoint. The Part I Permit can and does require corrective action for both
SWMUs and AOCs If a release of hazardous waste or hazardous constituents is
evident, it does not matter where it came from, if such a release poses an actual or
potential threat to human health or the environment.
The Permits Section understands that discussions are ongoing as to what, if any.
responsibility DOE/USACE will have for sampling, analysis and/or remediation of
chemical versus radiological contamination of environmental media in the FUSRAP
areas. Conversely, the Permits Section understands that discussions are ongoing as
to what, if any, responsibility Mallinckrodt will have for sampling, analysis and/or
remediation of radiological versus chemical contamination in environmental media in the
non-FUSRAP areas. Ultimately, it appears to be in Mallinckrodt's best interest to
communicate with DOE/USACE to work these issues out since Mallinckrodt is liable
pursuant to the Part I Permit for investigation and/or remediation of any and all releases
of hazardous waste and hazardous constituents at the facility, including any which may
have migrated off-site. It is Mallinckrodt's and DOE's/USACE's responsibility to discuss
and come to terms as to which entity will take responsibility for chemical and/or
radiological contamination in specific areas. This includes defining the transition point
for these responsibilities. MDNR is not responsible for defining these responsibilities
nor does MDNR anticipate being the mediator or arbitrator of any disputes between
Mallinckrodt and DOE/USACE in this regard.
As stated herein and in past correspondence, MDNR agrees that there should be
minimal, if any. duplicative regulatory effort in investigating and remediating the
FUSRAP areas. MDNR reiterates its intention to allow DOE/USACE to discharge its
investigation and remediation obligations as fully as possible pursuant to the FFA prior
to requiring any additional corrective action by Mallinckrodt. However, MDNR retains
A-S
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Mr. Mark Puett
May 7. 1998
Page 9
the ability under the Part I Permit to require Mallinckrodt to perform additional corrective
action in the FUSRAP areas at any time for releases of hazardous waste and/or
hazardous constituents as necessary to protect human health and the environment.
MDNR would have no compelling reason for triggering such action on the part of
Mallinckrodt as long as the DOE/USACE effort is sufficient to address substantive
corrective action requirements and the investigation/remediation process under the FFA
proceeds in a timely manner. MDNR cannot stress strongly enough that Mallinckrodt
and DOE/USACE must communicate and work closely to develop criteria for the
transition of environmental responsibilities in the FUSRAP areas and outside of those
areas to the extent that contaminant migration has occurred which could be the
responsibility of DOE/USACE..
f
In order to address the concerns expressed by Mallinckrodt in the Part I Permit appeal
and to try and avoid regulatory gridlock, the MDNR hereby proposes modifying
paragraph C. under Corrective Action Condition I. of the Part I Permit as follows:
"The Permittee shall be responsible for working with the Department of Energy
(DOE) and/or the U.S. Army Corps of Engineers (USAGE) to define the
environmental responsibilities of each agency at the facility including
development of site investigation and remediation criteria. The Permittee shall
be responsible for performing any necessary corrective action for any releases of
hazardous waste, including hazardous constituents, to the environment
attributable to SWMUs or AOCs at the facility which are not explicitly determined
to be the responsibility of DOE/USACE pursuant to the Federal Facilities
Agreement (FFA) between DOE and EPA dated June 26. 1990."
"Further, the Department acknowledges that there should be minimal, if any,
duplicative regulatory effort in investigating and remediating the FUSRAP areas.
The Department intends to allow DOE/USACE to discharge its investigation and
remediation obligations as fully as possible pursuant to the FFA prior to requiring
any additional corrective action in the FUSRAP areas by Mallinckrodt. The
Department would have no compelling reason for triggering early action in the
FUSRAP areas on the part of Mallinckrodt as long as the DOE/USACE effort is
sufficient to address substantive corrective action requirements and the
investigation/remediation process under the FFA proceeds in a timely manner."
A-89
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Mr. Mark Puett
May 7. 1998
Page 10
In closing, Mallinckrodt is hereby directed to submit a revised RFI Work Plan within 45
days of receipt of this letter to address the foregoing comments MDNR also requests
that Mallinckrodt respond to the MDNR's modified permit language proposal within this
time frame If you have any questions concerning this letter, the appropriate response
or wish to schedule a meeting to discuss the issues identified herein, please do not
hesitate to contact Richard A. Nussbaum, P.E , R.G., or Fuad Marmash, of my staff at
(573)751-3553.
Sincerely,
HAZARDOUS WASTE PROGRAM
Cindy Kempe
Director
CK.rnw
c: Ms. Shelley Woods, Attorney General's Office
Mr. Bob Geller. HWP-Federal Facilities
Mr. Scott Honig, HWP-Federal Facilities
Mr. Steve Poplawski, Bryan Cave
Ms. Mimi Garstang. MDNR-Division of Geology & Land Survey
Mr. Joe Gillman. MDNR-Division of Geology & Land Survey
Mr. Bob Boland, Mallmckrodt
Dr. Rob Mullins. USAGE
Mr. Dan Wall, U.S. EPA Region VII
TCTPL P.13
A-90
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ATTACHMENT A-2
Comments from the Spokane Tribe Relating to Offsite Disposal
of Contamination at the Dawn Mining Facility
A-91
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THIS PAGE INTENTIONALLY LEFT BLANK
FUS208P/072398
A-92
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GIVENS, FUNKE & WORK
ATTO*WE*S AT
TOP aOC* • OLD CITY HALL
«J« SHERMAN AVI. t.O BOX M«
C.OILTR 0 AO.ENL IDAHO IJII.-0**
(Ml) 07-felt
FAX CM) »*?-••»)
May8, 1998
Dr. R.L. Mullins, Jr., PE. AICP
U.S. Army Corps of Engineers
St. Louis District
9170 Laoy Avenue
Berkeley. MO 63134
Re: St. Louis Downtown Site Feasibility Study/Proposed Plan
Dear Dr. Mullins:
I am Special Legal Counsel to the Spokane Tribe of Indians on various natural
resource matters. You may recall that last month I submitted to you a letter similar to this
concerning the St. Louis Airport Site and Hazelwood Interim Storage Site EE/CA documents.
You may also recall I explained that one of the matters on which I work for the Tribe
concerns an inactive uranium milisitc located jusi off the Spokane Indian Reservation, but
immediately adjacent to it and to an important Reservation waterway known as Chamokane
Creek. Operated for decades by Dawn Mining Company, the millsite is known to
contaminate both surface and ground waters, including waters to which the Tribe holds
federally protected and adjudicated rights. See United States v. Anderson, 736 F.2d 1358 (9ih
Cir. 1984). Under its off-reservation authority, the State of Washingtou in February 1995
licensed Dawn to convert a vast open impoundment at the site into a disposal cell for Atomic
Energy Act 11 ,e(2) byproduct material. Due to unresolved concerns for the health and safcry
of Reservation residents and visitors, as well as for Tribal trust resources, the Tribe has
consistently opposed Dawn's waste importation proposal.
These comments are submitted on behalf of the Spokane Tribe regarding the L'SACE's
Feasibility Study/Proposed Plan (FS/PP) documents prepared in support of proposed actions
to remove for off-site disposal radioactivcly contaminated soils from the St. Louis Downtown
Site
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Dr. R.L. Mullins, Jr., PE, AICP
U.S. Army Corp of Engineers
St. Louis District
April 3, 1998
Page 2
INTRODUCTION
An Executive Memorandum issued by President Clinton on April 29, 1994 implements
four key guiding principles for federal actions affecting Indian tribes and tribal trust
resources:
1) federal departments and agencies are to "operate[] within a government-to-
government relationship with federally recognized .tribal governments."
2) federal departments and agencies "shall consult. . . with tribal governments ppor
to takinp action?; that affect federally recognized tribal governments,"
3) federal departments and agencies "shall assess the impact of Federal Government
plans, projects, programs, and activities on tribal trust resources and assure {hat tribal
frovernment rights and concerns are considered during the development of such plans,
projects, programs, and activities," and
4) federal departments and agencies "shall take appropriate steps to remove any
procedural impediments to working directly and effectively with tribal governments
on activities that affect the trust property and/or governmental rights of the tribes."
Presidential Memorandum. 59 Fed. Reg. 22951 (1994), reprinted in 25 USCA § 450 noie.
If disposal of ll.e(2) byproduct material from the SLDS at Dawn's site next to die Spokane
Reservation is even a remote possibility, these principles have not been realized.
If such materials might be removed from the SLDS, the FS/PP documents are deficient
because they do not discuss impacts specific to disposal a: facilities licensed to receive such
materials, particularly where tribes and their resources might be negatively impacted. At
present, there are only three facilities in the United States licensed to receive 11 .e(2) material
for disposal: one was licensed in New Mexico last year by the Nuclear Regulatory
Commission, another is located in Utah, and the third is Dawn's facility next to the Spokane
Indian Reservation. To the Tribe's knowledge, the licenses at the Utah and New Mexico
facilities are presently not under legal challenges, but Dawn's license is. Conceivably,
however, administration of federal procurement and contracting laws may lead to an
agreement by USAGE to dispose 11 .e(2) material at the Dawn facility despife the questionable
legal status of the license.
A-94
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Dr. R.L. Mullins, Jr., PE. AICP
U.S. Army Corp of Engineers
St. LouU District
April 3. 1998
Page 3
RISK TO TRIBAL TRUST RESOURCES AND HUMAN HEALTH
The Tri.be questions whether the SLDS and FS/PP alternatives contemplating off-site
disposal can be found to be protective of human health and welfare and the environment when
the potential impacts at the disposal end of the proposal are only briefly discussed. The Tribe
is heavily dependent on the ground and surface waters of the Chamokane Creek Basin. See
United States v. Anderson. In addition to supporting Reservation fish and wildlife, uses of
this basin's waters include domestic, ranching, farming', and a Tribal fish hatchery. At
present, the Dawn site is known to contaminate Chamokane Creek's surface water and an
upper aquifer at the site. Tribal technical staff have determined it likely that the site also
contaminates a deep aquifer from which drinking water is drawn. Further, the High Density
Polyethylene liner in Dawn's disposal cell is only 30 mil, and is over 16 years old. The
manufacturer's warranty for the liner expired more than one year ago. Similar concerns
regarding this disposal cell's integrity have been raised by Department of Energy technical
staff who should be consulted by USAGE before determining to send any FUSRAP waste to
eastern Washington. Beyond this, it is imperative that the Tribe be consulted with concerning
any possible federal action which might threaten its Reservation, and that such consultation
be conducted sufficiently early in the process that it will have a meaningful effect on the
outcome. Sge. U.S. Army Corps of Engineers Tribal Policy Principles (identifying as key
principles Tribal Sovereignty, Trust Responsibility, Government to Government Relations,
Pre-Decisional and Honest Consultation, Self-Reliance, and Natural and Cultural Resources).
In evaluating impacts related to the proposed removals, the FS/PP documents, in
typical fashion, focus on the subject FUSRAP site under the rationale that *[t]he application
of specific environmental regulations to activities being considered for off-site disposal
facilities, such as disposal of waste at a commercial disposal facility, would be addressed by
the respective owners/operators in the environmental compliance documents and activities for
those facilities." Similarly, the Feasibility Study also states that M[e]xis'.ing regulations for
operation of disposal facilities would be protective of groundwater and surface water at the
disposal facility." Such statements lead to the general conclusion that the off-site disposal
alternatives are considered protective of human health. As discussed above, however, this
conclusion when applied to Dawn's facility is highly suspect from a technical standpoint.
Moreover, from a federal Indian policy standpoint, it is wholly unsupported since no effort
has been made by USACE to "assess the impact of Federal Government plans, projects,
programs, and activities on tribal trust resources and assure that tribal government rights and
concerns are considered during the development of such plans, projects, programs and
activities." §ej Presidential Memorandum dated April 29. 1994 See also. Civil Rights Act
A-95
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Dr. R.L. Mullins, Jr., PE. AJCP
U.S. Army Corp of Engineers
Si. Louis District
April 3. 1998
Page 4
of 1964, Title VI (42 USCA 2000d, et seq.) and related regulations. The reason the
principles in the Presidential Memorandum exist is the federal trust responsibility to tribes and
their resources, developed through more than 150 years of jurisprudence. States such as
Washington have no such responsibility, and indeed throughout history have routinely taken
strongly adverse positions to tribes as sovereigns. In fact, this responsibility can be neither
delegated to states nor abdicated by the federal government. Assiniboine and Sioux Tribes
v. Bd. of Oil and Gas, 792 F,2d 782 (9th Cir. 1986). Tbus, when disposal of federal waste
is considered for a state-licensed site like Dawn's it is incumbent upon the responsible federal
agency as trustee to ensure no injury to affected tribes and their resources. While off-site
disposal impacts are often not considered in environmental reviews for reclamation, they must
be where federal trust duties have not been addressed in the process of licensing the disposal
facility. And this must be accomplished before the federal action has proceeded down a path
where federal procurement and contracting laws render it irreversible.
If Dawn's facility is a potential disposal site, the Spokane Tribe's "rights and
concerns" must yet be considered. In the context of trust resources, those "rights and
concerns" include the following. What are the impacts the DMC site and the additional
FUSRAP waste will have on Reservation resources? Will the quality or quantity of these
waters be impacted in any way by the proposed alternative? What impacts will result to
Reservation fish and wildlife? To cultural resources? What socio-economic impacts will be
felt by the Spokane Tribe due to the importation of radioactive waste for disposal next to its
Reservation and adjacent to critical waters? What are the likely human health impacts if the
FUSRAP waste in Dawn's impoundment contaminates the deep aquifer? What will be
required as mitigation should this occur? Shouldn't the condition and integrity of the specific
disposal cell at the facility be taken into account in order to complete this analysis? Have
there been irreversible and irretrievable commitments of Tribal resources'1 How would a
Tribal natural resource damage action under CERCLA for harm to Reservation resources
affect the cost analyses contained in the SLDS and FS.'PP documents? Does the federal
government's trust responsibility over Tribal trust resources permit the disposal of FUSRAP
materials at Dawn's site? These questions must be answered and a more meaningful
opportunity for Tribal consultation presented before USAGE commits 10 a course which may
lead to further injury of Tribal trust resources.
A-96
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Dr. R.L. Mullins, Jr., PE, AICP
U.S. Army Corp of Engineers
St. Louis District
April 3, 1998
Page 5
TRAFFIC SAFETY RISKS TO TRIBE
The route selected by Dawn to transport its waste includes a narrow, winding and hilly
highway which serves as the primary route for Tribal members and employees travelling to
and from the Spokane Indian Reservation. The Tribe presently is contesting selection of this
route, and has submitted to the State of Washington the enclosed document entitled "Traffic
Safety Study, State Route 231, Reardan to Ford, Dawn Mining Mill Site Closure Proposal,"
which are formal comments prepared by a Tribal traffic safety consultant on a State conducted
study, and which are to be considered as additional Tribal comments regarding the proposed
actions at SLDS.
In general, the issues of trust responsibility raised in the above section concerning
threats to human health and natural resources apply equally to the traffic threats Dawn's plan
poses to Tribal membership. Although traffic and transportation impacts are considered in
the FS/PP documents, the guiding principles of the 1994 Executive Memorandum are not
satisfied. The Tribe must be consulted with on a ^overnment-to-goycrnraent basis and
impacts to the Tribe must be assessed prior to implementation of the plan.
In assessing these impacts, the following must be considered. According to
Washington data, nearly one-half of the accidents studied a!ong Dawn's route result in death
or injury. Dawn's proposal will increase large truck traffic on State Route 231 by 400% to
600%. Large trucks, during the period in which the Stat*'* studies provide such statistics.
represented nearly one-sixth of the accidents in this corridor. A particularly winding stretch
of this route is in a canyon adjacent to a stream which flows onto the Spokane reservation.
and represents an area in which nearly one-fourth of Cv* accidents studied along Dawn's
preferred route occurred. Spills of radioactive waste from accidents in either this canyon or
at a dangerous bridge which crosses the Spokane River will result in contamination of critical
Tribal waters and other resources. The terse statement in the FS/PP that "[a]dverse effects
on surface water and groundwater related to transportation are unlikely excepi in the event
of an accident" are far from satisfying. Beyond an assessment of these issues, the Tribe,
consistent with the Presidential Memorandum and th? United States' trust responsibility, is
entitled to consultation.
w
A-97
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Dr. R.L. Mullins, Jr., PE, AICP
U.S. Army Corp of Engineers
St. Louis District
April 3. 1998
Page 6
THE PROPOSED ACTIONS AT SLAPS AND HISS
RAISE ISSUES OF ENVIRONMENTAL JUSTICE
The need to examine the disposal end of the proposed actions at: SLDS is important.
not just to satisfy the guiding principles of the 1994 Presidential Memorandum, but also to
satisfy the mandate of Executive Order 12898. dated February 11. 1994 (59 Fed. Reg. 7629
(1994), 60 Fed. Reg. 6381 (1995), reprinted in 42 USCA § 4321 note) and Title VI of the
1964 Civil Rights Act. The executive order requires agencies of the executive department
to act consistent with the principle of environmental justice and the Civil Rights Act bars
discrimination in federal programs and activities affecting human health and the environment
In other words, federal agencies must consider and address the disproportionate impact their
actions have on minority and low income populations. Clearly, all impacts to the Spokane
Tribe and its Reservation discussed above fall within this mandate. Federal agencies cannot
escape applying this analysis to the disposal end of remediation actions where, as here, the
licensing entity is not required to conduct a similar analysis. In this regard, environmental
justice principles associated with the SLDS proposed plan — as it relates to Dawn's facility
— must be satisfied in addition to meeting the government's trust obligations to the Spokane.
CONCLUSION
The Spokane Tribe appreciates the opportunity to submit these comments and the
attached comments to me US ACE. Please advise at the earliest opportunity whether the
consultation sought in these comments can be arranged. Also, please keep me advised as to
future developments on this and other FUSRAP projects which might affect my client's
interests.
Sincerely,
SHANNON D. WORK
Attorney at Law
SDW.slr
enclosure
A-98
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State Route 231
Reardan to Ford
Dawn Mining Mill Site Closure Proposal
January 1998
William E. Haro and Associates
2111 239th Hac« <>£
Istaquah. WA 98029
425392.7288
A-99
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Table of Contents
Page
Purpose of Report 1
Traffic Conditions - Existing and Proposed 1
Table I -1996 vs. 1999 Average Drily Traffic, Average Daify Trucks,
and Average Daify large Thicks (5 axle or 55' length) 2
Existing Lane and Overall Pavement Widths 3
Figure 1 - Topical shoulder -within SR231 corridor 3
Table 2 - Existing lane and shoulder widths at selected locations 4
Figure 2-Typical Lane Width 5
Horizontal Curves and Off-tracking 5
Ftgurt 3-Off'tracking in horizontal cur* 6
Table 3 - Horizontal curves suspected of having less than 900 foot radius 7
Figure 4 - Northbound at MP 38.8 - crest vertical & small radius
horizontal curve combination 8
Existing Roadway Lighting 8
Little Falls Road Intersection 9
Figure 5 - West leg of the Little Falls Rd&SR 23 J intersection looking north 9
School Bus Stops 10
Figure 6 - School bus stop southbound at MP 38.8 11
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12
Table nfCnntents (conL)
Guardrail, Bridge Rail, and Clear Zone
Figure 7 - High embankment without guar&ail on (he grade south
of AeSpokam River 13
Figure 8 - Spokane River bridge rail that does not meet current WSDOT
performance criteria (Utjt), and an upgraded bridge approach (right) 14
Drainage Crossings < 75
Grades 15
Table 4 - Significant Grades
Figure 9 - Car closely following truck (left) then passing fright) on southbound
grade south of the Spokane River
Table 5 - Large truck v$ passenger car on northbound grade north of
Spokane River 17
Trends 18
Conclusions 19
IS
16
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Purpose of Report
In May of 1997, the Eastern Region of the Washington State Department of Transportation
(WSDOT) completed a safety study entitled *SR 231 - Safety Study for the Closure of the
Dawn Mining Mill Site'. This study analyzed a number of roadway safety related items on
SR 231 between the town of Reardan. WA and the access road to the Dawn Mining Company
site just south of Ford, WA. Upon my review of this study I have found that although most
roadway safety topics have been analyzed and discussed, the study basically serves as an
analysis of existing conditions. The safety related impacts to SR 231 in view of the transport of
hazardous and/or radioactive material with large, 5 axle vehicles on a consistent daily schedule
for a long time period are not specifically discussed.
Enclosed in this report you will find my analysis and professional opinions specifically related
to the transport of hazardous materials with large trucks on this section of SR 231. This
analysis will be made with the existing roadway conditions' as the foundation and the Dawn
Mining Company (DMC) proposal built upon this foundation to give a better picture of the
possible impacts to the safety of persons and the environment if DMC's proposal occurs.
Traffic Conditions - Existing and Proposed
This portico of the SR 231 corridor is the primary commuter route for Spokane Indian
Reservation residents and Tribal employees traveling to and from the Spokane Indian
Reservation. The SR 231 corridor is a rural two lane highway with reported 1996 traffic
volumes of 1400 Average Daily Traffic (ADT) with 13.5 56 trucks just north of Reardan, 900
ADT with 11.6% trucks just south of the Junction with SR 291, and 1100 ADT with 14.9%
trucks just south of Ford. WSDOT reports that at the time of these counts (July 1996),
approximately 1.4% of the total ADT consisted of large trucks, with large trucks defined as
those having 5 axles or a length of at least 55 feet. Annual traffic growth rates of 4% to 5 %
are reported.
The current DMC proposal to import contaminated waste to its facility specifies 38 round trips
per day, or an addition of 76 vehicles per day to the existing ADI'. Table 1 outlines the
impact to existing traffic conditions for total vehicle traffic, general truck traffic, and large
truck traffic (5 axle or > 55' in length) at the three locations on SR 231 where counts were
taken in July of 1996. This table provides a framework for evaluating the increase in traffic
safety concerns due to the DMC proposal. A traffic growth rate of 5% is used and 1999 is
assumed to be the year contaminated material begins being imported to the DMC site.
Again, the assumptions made for Table 1 include an annual traffic growth rate of 5 %. tha: the
percentage of trucks in the traffic stream prior to the hauling of contaminated material to the
DMC site remains constant, that the DMC proposal is implemented in 1999, and that large
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trucb (5 axle or >55" length) are used to transport the contaminated material. All these
assumptions are reasonable based on available information.
As seen in Table 1, overall traffic growth from 1996 to 1999 is a significant but modest 16%.
The largest changes to the traffic stream due to the implementation of the DMC proposal
involve trucks. The percentage increase in overall truck traffic ranges from 55 % just north cf
Reardan to 86% just south of the SR 291 junction.
Table 1 -1996 vs 1999 Average Daily Traffic, Average Daily Trucks, and Average Daily
Large Trucks (5 axle or >55' length)
1996 ADT
1999 ADT
% increase
1996 Tracks
1999 Trucks
% increase
1996 Large Trucks
1999 Large Trucks
% increase
SR 231 north of
Reardan
1419
1643
16%
192
29S
55%
20
99
395%
SR 231 south of
SR 291 Jet
909
1052
16%
105
198
86%
13
91
600%
SR 231 south of
DMC access road
1130
1308
16%
168
. 271
61%
15
93
520%
The percentage increase in large trucks is most significant and alarming. As seen in Table 1,
the percentage increase in large trucks ranges from 395% just north of Reardan to 600% just
south of the junction with SR 291.
The increase in regular and large truck traffic as outlined in Table 1 will serve as the basis for
my analysis of roadway safety concerns based on the DMC proposal. It should be noted that
the Dawn Mining Company estimates that approximately 25 million cubic feet of material will
be hauled at 500 cubic feet per load. They state that this calls for 38 one way trips per day (76
two way trips). 260 days per year for five years. During recent safety mitigation discussions,
Dawn Mining Company has stated a willingness to suspend hauling during rimes school buses
pick up and drop off school children along SR 231. They further stated a willingness to
suspend hauling during periods of poor weather and road conditions. If these rnitigative
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measures are invoked, it seems likely that the estimated number of trips per day would have to
increase in order to end operations in five years, or if daily trips remain constant, hauling
could extend into the sixth or seventh year. Either scenario would increase negative impacts.
Existing Lane and Overall Pavement Widths
The WSDOT safety study states that SR 231 * generally has adequate alignment with one. 11
foot lane in each direction and shoulders ranging from 2 to 4 foot in width". The surfacing
requirements of the shoulder are not mentioned.
Figure 1 - Typical shoulder within SR 231 corridor
Any improvements made to the existing roadway would require an upgrade of existing lane
and shoulder widths to a minimum of 12 foot and 3 foot, respectively (this assumes > 1000
ADT and > 10% trucks, both reasonable assumptions). The existing lane and shoulder widths
dc not meet those required of today's roadway project design standards. In other words, the
increased lane and shoulder widths would be required of any roadway safety or capacity
improvement projects as outlined in the Modified Design Standard requirements.
I am concerned about these lane and shoulder width issues with respect to the huge increase in
Isrge trucks proposed by the DMC. What concerns me more is that I disagree with the
existing lane and shoulder width measurements reported in the WSDOT study. Table 2 below
shows lane and shoulder width measurements taken at a number of locations within the
corridor. It should be noted that in my opinion, die shoulders in this corridor need to be paved
in order to be considered a shoulder due to the generally soft, sandy material found beyond the
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edge of the pavement. Lane widths reported below are measured from the center of the
center!inc stripe to the center of the fogline, and shoulder widths are measured from the center
of the fogline to the edge of the pavement. What is often overlooked is that effective lane
widths are taken from the inside of the centerline stripe to the inside DO the fogline. thus these
effective lane widths are approximately 0.25 feet to 0.75 feet less than those shown in Table 2.
Table 2 - Existing lane and shoulder widths at selected locations
Location
MP34.4
MP 35.5
MP 36.7
MP 38.8
MP 40.7
MP 43.8
MP44.7
(Spokane River Br.)
MP46.4
Lane Width (ft)
10.75
10.25
10.5
10.25
10.25
10.25
10.5
10.25
Shoulder Width (ft)
1.25
1.75
2.5
2.75
1.75
1.75
1.5
1.25
Overall Pvmt Width
(ft)
24
24
26
26
24
24
24
23
As seen in Table 2, typical lane widths for the corridor are just over 10 feet, and typical
shoulder widths are under 2 feet. Overall pavement width is typically 24 feet. These widths
differ significantly from those reported by WSDOT, and differ even more from those required
by the Modified Design Standard.
These travel lane and shoulder widths are of concern considering the proposed increase in
large trucks by the DMC. Large trucks have difficulty remaining in their travel lane on
straight sections of highway at these lane widths. In horizontal curves, particularly in those of
900 foot radius or less, it is unreasonable to expect that large trucks will always remain within
their lane with these typical lane widths. The proposed increase in large tracks will negatively
impact motorists who meet such trucks at highway speeds. In addition, the likelihood that two
trucks will meet on a horizontal curve will significantly increase with the DMC proposal. This
concern will be discussed in more detail in the next section.
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Figure 2 - Typical lane width
Horizontal Curves and Off-tracking
There are a number of horizontal curves of note within the corridor. Particularly noteworthy
are horizontal curves of less than 900 foot radius. Horizontal curves with short radii present
tracking concerns for large trucks on roadways with narrow lane and overall pavement widths
such as SR 231. Due to the greater width and length of large vehicles, the wheel path can be
wider than the lane of travel within the horizontal curve due to the rear wheels of the large
vehicle tracking inside the front wheels. This is referred to as off-tracking.
The off-tracking phenomenon in curves with narrow roadway width conditions can cause the
large vehicle to cross the ccnterline when negotiating the horizontal curve. This concern is
often compounded by the tact that the forward sight line between the large vehicle and a
vehicle approaching in the opposite direction is often limited by the horizontal curve itself.
1 believe that off-tracking is of significant concern in this corridor, particularly if the current
DMC proposal is implemented. Six main factors constitute the majority of my concern:
1) Overall lane and pavement widths are too narrow at certain horizontal curves within
this corridor which will often result in large trucks off-tracking within these curves.
2) Sight distance is limited at certain horizontal curves, giving motorists less time to
react to an approaching large vehicle that has crossed the centerline due to 1 above.
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3) If the DMC proposal is implemented, there will be a 395 % to (500% increase in
large vehicles on SR 231, resulting in many more instances where large vehicles
could cross the centerline at certain horizontal curves, particularly those listed in
Table 3.
4) If the DMC proposal is implemented, there will be many more occurrences of two
large vehicles approaching from opposite directions meeting within the smaller
radius horizontal curve. Also of significant note is the increase in chance of a large
vehicle and a school bus meeting per above, because it is unclear whether the OMC
would cease operations only during normal morning and afternoon bus transport
times or during all times of school bus operations (extracurricular).
5) There will be a significant increase in the chance that two large vehicles will meet
while a pedestrian is standing or walking along the roadway or a cyclists is riding
along the roadway if the DMC proposal is implemented. Should this happen in a
roadway section with a steep embankment or guardrail, there could be no place for
a pedestrian or cyclist to shy away from the roadway edge.
6) The huge increase in large vehicles will cause a proportionate increase in off-
tracking in the small radius horizontal curves. This in turn will likely break down
the shoulder areas adding to maintenance and safety concerns. The existing
shoulders are typically narrow and soft beyond the pavement edige. If the shoulders
lose width due to off-tracking, the concerns in the small radius curves will increase
as the overall pavement width decreases.
Figure 3 - Off-tracking in horizontal curve
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In my opinion, the chance for a head on or run off the road collision at the less than 900 foot
radius curve* will significantly increase if the DMC proposal is implemented unless mitigative
action is taken. The WSDOT safety report agrees that pavement widening is needed on certain
curves due to targe vehicle off-tracking.
The only fatality reported in this corridor by the WSDOT safety study appears to have
occulted at the crest vertical/horizontal curve combination at MP 38.8. This was reported as a
head on accident (two vehicles colliding head oo from opposite directions). Because
information on this accident is limited in the WSDOT study, further investigation into the
specifics of this accident are needed, but it seems likely that the accident occurred in the
horizontal curve. The probability of occurrence of this type of collision will increase if the
DMC proposal is implemented and the < 900 foot horizontal curves are not improved.
From my field review of the corridor, I am listing below in Table 3 a number of curves that I
suspect to be less than 900 foot in radius. Horizontal and vertical stopping sight distance (SSD)
measurements are also included at certain curves. It should be noted that GaQmenic Design-of
Highway* and SIMM* by the American Association of State Highway and Transportation
Officials (AASHTO) recommends 450 feet to 550 feet of stopping sight distance (SSD) for 55
mile per hour design speeds on level ground, and an additional 65 feet for 4% to 5%
downgrades.
Table 3 - Horizontal curves suspected to have less than 900 foot radius
Location of Suspected
<900' Radius
Horizontal Curve
MP34.5
(rock cut)
• MP 35.5
• MP 36.7
MP 38.8
MP43.8
MP44.5
MP44.8
Lane
Width (ft)
10.5
10.25
10.5
10.5
-
—
-
Overall
Pavement
Width (ft)
24
24
26
24
24
24
24
Horizontal
Stopping
Sight D:st. (ft)
—
—
430
395
.
—
—
Vertical
Stopping
Sight Dist. (ft)
—
—
--
285
--
--
—
* There are a series of curves from MP 35.5 to MP 37.0 that need to be further investigated.
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The minimum lane width and minimum total roadway width for a 900 foot radius horizontal
curve per the Modified Design Level is 11 feet and 26 fleet, respectively. However, wider
minimum lane widths and total pavement widths are required as the horizontal curve radius
becomes less than 900 feet. For instance, a 500 foot radius horizontal curve requires a
minimum 12 foot lane width and 28 foot total pavement width.
Figure 4 - Northbound at MP 38.8 - crest vertical & small radius horizontal curve combination
Before the current DMC proposal were to be implemented, I highly recommend that the exact
radius of each suspect curve be determined and die curve widened to at least the minimum
widths outlined in the Modified Design Level. Action should be taken to mitigate the large
increase in likelihood of head on and run off the road collisions in these curve area*. Further
shcu!der widening should be considered beyond these minimums in arsas where pedestrians
are likely to be walking and no refuge area exists for their safety.
Existing Roadway Lighting
There is currently no roadway lighting along mis corridor. Roadway lighting at selected
locations, including the intersections of SR 231 at Little Falls Rd, SR291, Corkscrew Canyon
Rd. and the DMC access Rd, could help improve motorist safety during dark conditions. The
WSDOT safety study specifically mentions that increasing driver awareness ray help to
reduce accidents at the Little Falls Rd intersection. Roadway lighting at this intersection
would help better identify this intersection to motorists at night, dawn, and dusk.
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Roadway lighting should certainly be included in any intersection improvement projects,
including the addition of turn lanes on SR 231 at the DMC access Rd. Turn lanes require a
driver decision approaching an intersection, and during darkness, dawn, or dusk, roadway
lighting can help better define die lane choice decision faced by the motorist.
It should be noted that during late fall and early winter, dawn, dusk, and darkness extend into
typical truck hauling houn and school bus pickup times. The use of roadway lighting at
. intersections and school bus pick up zones can help mitigate vehicle and pedestrian visibility
concerns.
Little Falls Road Intersection
Of the twelve intersection collisions reported in the WSDOT safety study, eight occurred at the
Little Falls Rd intersection. This constitutes 6756 of all intersection collisions. Seven of these
eight collisions were at right angle, indicating vehicles from Little Falls Rd turning into
vehicles on SR 231.
Little Falls Rd via this intersection is a main access point to and from the state highway system
and the Spokane Indian Reservation. The increase in large trucks proposed by the DMC will
likely increase the severity of the angle accidents at this intersection due to the increased
likelihood of any angle accident occurring involving a large truck on SR 231 (recall that
general trucks will increase as much as 8655 and large trucks will increase as much as 600 %
with the DMC proposal).
Figure 5 • West leg of Little Falls Rd & SR 231 intersection looking north
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The WSDOT safety study states that increasing driver awareness at this intersection could
lessen the possibility of accidents occurring.
To address collisions at this intersection, I recommend the following actions:
1) The installation of left turn channelization on SR 231 at the intersection. Although
not readily warranted based on accident type, this improvement would do three
things to decrease accident potential in my opinion. First, it would provide a
refuge area on SR 231 for left turning vehicles from Little Falls Rd. Second, it
would provide vehicles on SR 231 additional avoidance maneuver space. Third, it
provides vehicles on SR 231 a visual queue that an intersection is approaching.
2) The installation of roadway lighting at the intersection. This improvement would
also provide increased intersection awareness for vehicles on both SR 231 and on
Little Falls Rd. Due to the lane choice decision, intersection lighting should be
part of implementing recommendation 1 above.
3) Installation of highly reflective intersection warning signs on SR 23! in both
directions approaching the interjection. Supplemental "Little Falls Rd" street names
signs should be included as well, I recommend Diamond Grade VIP sheeting be
used on these signs foe enhanced nighttime performance.
4) The angle accidents should be studied to determine if any were mused due to
vehicles on Little Falls Rd running the stop signs. If so, correctable measures in
addition to roadway lighting could be implemented. Such measures include stop
ahead signs, stop bars, and possibly a flashing beacon atop the stop signs.
School Bus Stops
School bus stops present a concern mainly due to the potential for conflict between the stopped
school bus with its entering and/or existing school age passengers, and traffic on the highway.
This concern is compounded by four main factors in highway situations. First, if there are a
significant amount of trucks, especially large trucks, there can be increased likelihood for a
collision because of the increased braking time that is required of such vehicles and their
decreased maneuverability. Second, poor sight distance from highway traffic to the bus slop
leaves less time for a motorist, especially the operator of a large vehicle, to r&c: to the
situation ahead. Third, the younger the child using the bus, the Jess capable die child is of
dealing with the complexities of a highway school bus stop. Fourth, should buses pull over to
allow vehicles to pass, large trucks will have difficulty accelerating to prevailing highway
speeds, especially on grades, and a greater frequency of passing large trucks will occur.
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As a pedestrian required to stand and walk aside highway traffic, school aged children are at
significant risk as outlined above. In my opinion, elementary school children arc at most risk.
These young, inexperienced pedestrians have less experience in negotiating highway traffic.
They are more apt to dart into traffic for no apparent reason. Until the age of approximately
twelve, their depth perception and peripheral vision is not yet fully developed, leaving them
less equipped to deal with bus stops beside high speed highways. Of course, as with most of
the safety situations analyzed in view of a proposal like the DMC proposal, increasing truck
traffic on the highway, particularly large truck traffic, increases the concern significantly due
to vehicle size and width, increase in braking time, and decrease in maneuverability.
Per my field observations, school buses do regularly use SR 231 in this corridor. There are a
number of "School Bus Stop Ahead" signs (S3-1) posted along the corridor. The presence of
this type of signing alerts me to sight distance concerns between highway traffic and the bus
stops. Per the Manual of Uniform Traffic Control Devices (MUTCD), which is the WSDOT
standard for signing and striping roadways, this type of signing is intended for use where sight
distance to the school bus stop is 500 feet or less, not just everywhere a school bus stop exists.
For 55 mph. minimum stopping sight distance (SSD) requirements are 450 to 550 feet as
reported by the American Association of State Highway and Transportation Officials
(AASHTO). AASHTO also dearly states that these minimum SSD requirement, are for
passenger car operation and that "trucks as a whole, especially larger and heavier units, require
longer stopping distance from a given speed than passenger vehicles do". Thus my concern
over sight distance to these bus stop locations, particularly considering the DMC proposal.
Figure 6 - School bus southbound at MP 38.8
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If the current DMC proposal is implemented, I recommend three actions to address school bus
stop concerns:
1} Construct bus pullouts at each bus stop location capable of removing the school bus
from the highway completely.
2) Restrict the transport of hazardous materials during the school bus pickup and drop
off times.
3) Review the location of bus stops and consider elimination or relocation of those
located on upgrades or in areas of limited sight distance. Resulting pedestrian
facility needs have to be considered for relocated stops.
A question may arise to the need for implementation of both recommendations one and two
above. I feel that both should be implemented together ay follows. First, it may be difficult to
enforce the transport restriction during school bus pick up and drop off times. Thus, these
restrictions may not always be observed. At the risk of making judgments without knowing
the specifics on tfce contractor that will be transporting the hazardous materials, it has been my
experience that in general, permit requirements for hauling are not always followed unless
these requirements are strictly and regularly enforced. Second, school bus pick up and drop
off times are not always restricted to the morning and afternoon. For instance, kindergarten
classes are often half day and thus can have pick up and drop off around noon.
It has been reported to me that the current DMC proposal includes a provision for not
transporting hazardous material during school bus pick up and drop off times. I highly
recommend follow up on two issues prior to implementing this provision. First, have the local
school districts provide a complete drop off and pick up schedule. Note the times outside the
typical morning and afternoon routes. Will transport of hazardous materials be suspended
during all times school buses use the highway? Last, design an enforcement plan including a
schedule of penalties. Due to the lack of a weigh station on SR 231 within this corridor,
enforcement could be difficult to implement. Suggestions for enforcement include regularly
scheduled spot checks by the Washington State Patrol (WSP) or a commissioned private
contractor.
Guardrail, Bridge Rail, and Clear Zone
Guardrail is a mitigative measure that can be employed to address hazards such as side slopes,
fixed objects, and water in the event of a vehicle leaving the roadway. At bridges, bridge rail
and bridge approach rail can be used to prevent errant vehicles from going over the side of the
bridge structure, or striking the end of the structure. A clear rone is an unobstructed area
beyond the edge of the roadway shoulder for the recovery of vehicles that leave the roadway.
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My field investigation showed thai there art many locations within this corridor where
guardrail is warranted by current WSDOT standards, but no guardrail is provided. In
addition, there are many existing locations of substandard guardrail including concrete post
and post and cable types.
Figure 7 - High embankment without guardrail on the grade south of the Spokane River
The need and justification for mitigating the hazards presented by the existing side slope,
water, and fixed object hazards along the SR 231 corridor in my opinion will increase if the
current DMC proposal b implemented. More large trucks within the corridor will present
increased opportunities for conflicts resulting in run off the road types of accidents as these
trucks travel through and interact with other vehicles.
It is interesting to note that in the 52 non-intersection accidents reported in this corridor, it is
likely that at least 43 involve vehicles leaving the roadway. If the two accidents that hit
guardrail but did not break through are included, approximately & % of all non intersection
accidents involve vehicles that either left the roadway or would have hzd guardrail not been
present. It is my opinion that this percentage will likely remain the same if the DMC proposal
is implemented, however the number of total accidents will likely increase. One can conclude
from this accident data that vehicles leaving the road is a main concern and thus guardrail
where warranted could be used to attempt to address this.
It should be noted that there are locations of water adjacent to the roadway in this corridor, as
well as drainage and river crossings. It b reasonable to say that most of the streams and
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drainage courses empty into the Spokane River, which forms the south border of most of the
Spokane Indian Reservation. If a large truck transporting hazardous material were to leave the
road and spill hazardous material into a stream or drainage course, the impact to the
environment, particularly the Spokane River, could be significant Again, barrier protection
such a* guardrail is one measure that can address this.
The WSDOT safety study states that further evaluation of approximately 15.000 feet of
guardrail installation will be required if the ADT on SR 231 continues to grow. This
statement likely reflects that for locations where guardrail is warranted for installation, it may
not be recommended if the embankment is not high enough or steep enough for a given
roadway ADT. This cost/benefit approach to installing guardrail does not appear to take in'.o
account the types of vehicles using the road, the likelihood that those vehicles may leave the
roadway, roadway surface conditions (% time ice and sno\*/ on road), roadway grades, and
perhaps most importantly in this case, the type of cargo being regularly transported on the
road. Could die dally transport of hazardous material have an impact on the cost effectiveness
of guardrail installation? I think so.
The WSDOT safety study also states that approximately 20.000 lineal feet of existing guardrail
should be replaced to meet current standards. However, my field observations showed only
about a
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At the Spokane River bridge, bridge rail and bridge end protection do not meet current
standards. The installation of flared guardrail on the bridge approaches and thrie beam rail on
the inside of the existing concrete bridge rail is recommended. These measures will help
prevent vehicles, especially large trucks carrying hazardous material, from entering the
Spokane River. Because of the possible terrible consequences of such an event to the motorist
as well as the environment, the needed upgrades to the bridge rail and bridge end protection
are highly recommended if the DMC proposal goes forward.
There are many locations adjacent to SR 231 where the clear zone area could be cleared of
obstructions to improve safety. Areas with trees in the clear zone can be mitigated at a very
reasonable cost. The rode cuts at MP 34.7 present a significant clear zone obstruction.
Drainage Crossings
The drainage crossing at MP 40.7 is of concern because at times the existing 24" diameter
corrugated metal drain pipe is overwhelmed by storm water flow and siltation. This results in
a flow of water over SR 231 and this presents a hazard to all vehicles on the highway. Large
trucks transporting hazardous materials per the current DMC proposal may have difficulty
negotiating the flooded roadway if the water over the roadway is not identified by the vehicle
operator in time. Depending on the depth of water, this could cause the vehicle to lose control
and overturn and/or leave the roadway. This presents the potential for hazardous material to
enter the drainage stream and be carried to the Spokane River.
Due to the above mentioned concerns, I recommend that if the DMC proposal is implemented,
the drainage crossing at MP 40.7 be improved so that water and mud flow across the highway
is eliminated.
Grades
My field investigation revealed that there are a number of grades that would affect the speed of
fully loaded large trucks on SR 231 within this corridor. However, three grades stand out as
most significant due to their length. These three grades are shown in Table 4.
Of the three grades listed iin Table 4. the last grade from MP 44.8 to MP 45.9 is of most
concern to me if the current DMC proposal is implemented. The upgrade is in the northbound
direction, which is the direction the large trucks transporting materiai to the DMC site will be
fully loaded. In addition, this is the longest and steepest grade, with a maximum grade of
approximately 1% at MP 45.7. Also, a major intersection with SR 291 is located within this
grade.
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Table 4 • Significant grades
Location of Grade
MP 35.5 to MP 38.4
MP 43.6 to MP 44.5
MP 44.8 to MP 45.9
Length (miles)
2.9
0.9
1.1
Approx. Avg. Grade
4.5*
5.5%
*6*
Direction of Upgrade
Southbound
Southbound
Northbound
Maximum grade of 7% at MP 45.7
Assuming the large trucks in the current DMC proposal begin this grade at MP 44.8 at the
speed limit of 55 miles per hour, truck speed will steadily decrease to approximately 17 miles
per hour at MP 45.4, and then decrease further to approximately 14 mph at the 7% grade at
MP 45.7. These speeds will continue to the crest of the grade at MP 45.9. Heavy truck
acceleration tables show that h can take just under 2 miles' for these vehicle to reach the speed
limit after the upgrade has ended (assuming flat road after the grade). This means these
vehicles may not reach the speed limit again until approximately MP 47.8. It should be noted
that it may be very difficult for large vehicles to actually begin this grade at the speed limit of
55 miles per hour as assumed above due to the horizontal curve at the beginning of the grade.
If large vehicles actually begin the grade at a speed that is lower than the 5:5 miles per hour
speed limit, the large vehicle will reach its lowest speed even sooner, increasing the time that
it could delay the progress of the normal traffic stream.
1 have two main concerns with this grade if many additional large trucks use it on a daily
basis. First, the faster a heavy truck can travel at the beginning of the upgrade, the longer it
can maintain its speed. Thus, there will be an incentive for truck operators to speed or. the
downgrade and horizontal curve approaching the Spokane River bridge in order to hit the
beginning of the upgrade at as great of speed as possible. The horizontal curve just to the
south of the Spokane River bridge is suspected to have less than a 900 foot radius, thus off-
tracking in this curve is already of concern. Speeding through the curve compounds this
concern. This of course will increase the accident potential northbound on SR 231 through the
village and curve area south of the bridge, and on the approach to the bridge itself. Second.
•J>« huge speed differential between regular traffic on the grade and the large trucks destined
for die DMC site will tend to cause motorist frustration and will encourage passing. This
concern is magnified by the presence of no passing zones on the grade and ;u the intersection
with SR 291.
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Figure 9 - Car closely following truck (left) then passing (right)
on southbound grade south of the Spokane River
As shown in Table 5, this speed differential is estimated to be at least 41 mph at some points
of the grade. The time differentia] between a passenger car and a large truck to negotiate the
three miles that the large track will be traveling at reduced speeds is approximately 142
seconds.
Table 5 - Large truck vs. passenger car on northbound grade north of the Spokane River
Location
MP 44.8 (Stan
of Grade)
MP 45.0
MP 45.4
MP 45.7
MP 45.9
MP46.3
MP46.9
MP 47.8
Approx.
Car Speed
(mph)
55
55
55
55
55
55
55
55
Approx.
Large Truck
Speed (mph)
55
40
17
14
17
42
50
55
Approx.
Speed
Differential
(mph)
0
15
38
41
38
13
5
0
Elapsed
Time for
Car Since
Stan of
Grade (sec)
0
13
39
59
72
98
137
196
Elapsed Time
for Large
Truck Since
Start of
Grade (sec)
0
15
65
135
181
230
277
338
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There are many locations within the three grades listed in Table 5 that warrant guardrail
installation. The proposed increase in large vehicles on these grades increases the justification
and cost effectiveness of guardrail installation, particularly considering the high, steep
embankments, and the significant amount of time ice and snow is on the road surface.
The Dawn Mining Company has stated they would suspend operations during inclement
weather conditions, however, roadway surface conditions, not weather, is the main concern.
Unfortunately, it is difficult to predict roadway surface conditions from forecasted weather.
For example, during my field study on December 5th, 1997, conditions were cool and dry
with clear skies, and the high temperature in Reardan in the middle thirties. These are typical
conditions for late fall and early spring. Frost was on the roadway during the morning hours
with a considerable amount remaining throughout the day on the grade approaching and to the
south of the Spokane River (MP 43.6 to MP 44.5). This downgrade is on a oorth facing slope
and is shaded for most of the day. It had frost on the roadway surface the entire day I visited
this corridor. I anticipate that this section of roadway with,its nearly 6% ijrade for downhill
trucks will have reduced traction roadway conditions with frost or snow for considerable
amounts of time during late fall and winter. As previously mentioned, this section contains
non standard barrier protection, an embankment of approximately 100 feel: in heigh:, and a
horizontal curve of less than 900 foot radius just prior to the Spokane River bridge.
Trends
Based on accident Information contained in the 1991 FE1S, 1994 FSE1S, and the 1997
WSDOT safety study, there is a trend of increasing accidents on SR 231 within the corridor
between the years of 1983 and 1995. Average total yearly accidents within the corridor are as
follows for the given time period: '83 to '86 = 7.8 accidents/year, '87 to '89 = 10
accidents/year, '90 to '92 = 10 accidents/year, '93 to '95 = 12.3 accidenits/year. Based on
the proceeding data, there has been a steady increase in accidents in the SFl 231 corridor from
the early eighties to the middle nineties. It is also seen that over half (52 %) of the reported
accidents in the WSDOT safety study involved injury or death, with a total! of 58 injuries and
one fatality occurring m the 60 accidents reported in the study. If the current DMC proposal
is implemented, it is more likely that this trend of increasing accidents will continue.
The 1991 FBIS shows specific data on accidents involving large trucks. It is seen that between
the years of 1983 and 1987, nine accidents involving large trucks occurred within the corridor.
There were 39 total accidents during this time period, thus 23% of these accidents involved
large trucks. Because the accident data reported in the 1997 WSDOT safety study did not
include a key for rhe vehicle type code, it is difficult to readily determine the amount of large
vehicles involved in the accidents reported in this study. However, it is very likely tna:
whatever the percentage of accidents involving large trucks in the WSDOT safety study is. this
percentage would significantly increase if the current DMC proposal is implemented.
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Conclusion
This report and the engineering analysis contained herein is intended to serve as more than
simply an analysis of existing roadway conditions within the SR 231 corridor between the
towns of Reardan, WA and Ford, WA. Rather, this report is intended to analyze the safety
related impacts to SR 231 witfa respect to the consistent transport of hazardous material with
large trucks over a long period of time.
Based on my analysis, it is my opinion that if the current DMC proposal is implemented.
roadway safety in a number areas will be negatively and significantly impacted. The 395% to
600% increase in large trucks will compound the safety concerns in a number of small (<900
foot) radius horizontal curves that have lane and shoulder widths that do not meet the Modified
Design Level. The most significant of these concerns include large trucks off-tracking and
crossing the roadway centcrline. Existing lane and shoulder widths within the corridor were
found to be significantly narrower than those reported hi the WSDOT safety study, and the
introduction of a 395% to 600% increase in the wide large vehicles is a concern considering
the lane and shoulder widths found.
The impact to safety at school bus stops within the SR 231 corridor was also found to be
significant, especially for elementary school students. These concerns are based on a number
of factors, including the increased braking time required by large vehicles, especially at bus
stops where braking sight distance between highway traffic and stopped buses is limited. Also
of concern is introducing « significant increase in large trucks on the highway to young,
inexperienced pedestrian school children, many of whom are at an age where depth perception
and peripheral vision are not yet fully developed. Any proposal to restrict large trucks during
school pick up and drop off times should be met with scrutiny as school children are often
transported outside the nonnal morning and afternoon times and enforcement and
implementation of such large truck transport restrictions can be difficult.
Miu'gative measures that can be helpful in addressing "leave the highway" types of accidents
ere not present at many locations within the corridor. Field investigation showed that many
locations within the corridor where these types of accidents are of concern could benefit from
guardrail installation or hazard removal from clear zones. Approximately 87% of all non
intersection accidents reported in the WSDOT safety study involve vehicles that either left the
highway or likely would have had guardrail not been present. In addition, nearly a mile of
existing guardrail within the corridor does not meet current WSDOT standards. Large trucks
that in an accident could leave the roadway and spill their loud of hazardous materials present a
significant environmental concern as well, particularly if the spill occurs at the Spokane River
or one of its tributaries.
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The introduction of a huge increase in large trucks would significantly impact overall traffic
operations on the many grades within the corridor, particularly the over mile long northbound
grade situated just north of the Spokane River. There will be an incentive for the operators of
large trucks to speed on the approaches to upgrades in order to maintain their speed for longer
distances. The huge speed differential between the normal traffic stream and large trucks on
significant upgrades will tend to increase motorist frustration and encourage passing although a
significant amount of no passing zones are present of these grades. In addition, large trucks
within the corridor will have to negotiate frost, ice, and snow roadway conditions for
considerable amounts of time during the late fall and winter.
As outlined above, the DMC proposal will negatively impact roadway safety' in a number of
areas. As these negative impacts are realized, so typically are an increase in traffic accidents
due to the increase likelihood for accidents these negative impacts create. I am of the opinion
that the accident rate within the SR 231 corridor will increase if the current DMC proposal is
implemented. I would also expect that due to the type of vehicle that would most significantly
increase within the corridor, namely large trucks, the severity of accidents will also likely
increase due to vehicle size and associated concerns such as increased linear momentum and
braking time.
Since SR 231 is the primary commuter route for the Spokane Indian Reservation residents and
Tribal employees, the Tribe will be particularly affected by the impacts of the current DMC
proposal and the probable increase in total accidents and accident severity.
20
A-121
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