Work Plan for Installation of a
Non-Combustible Cover over
Radiologically-lmpacted Material
At or Near the Ground Surface in
Radiological Areas 1 and 2
West Lake Landfill Operable Unit-1
Prepared for
The United States Environmental Protection Agency Region VII
Prepared on behalf of
The West Lake Landfill OU-1 Respondents
Prepared by
Engineering Management Support, Inc.
7220 West Jefferson Avenue, Suite 406
Lakewood, Colorado 80235
In association with
Feezor Engineering, Inc.
406 E. Walnut Street
Chatham, Illinois 62629
and
Auxier & Associates, Inc.
9821 Cogdill Road, Suite 1
Knoxville, Tennessee 37932
January 4, 2016 Revised February 12, 2016 Final March 16, 2016
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Table of Contents
1 Executive Summary 1
2 Work to be Performed 3
2.1 Extent of Surface RIM 4
2.1.1 Surface RIM Extent 4
2.1.2 Vegetation Cover 4
2.1.3 Other Cover Material 5
2.2 Buffer Zone and Crossroads Lot 2A2 Vegetative Areas Investigation 5
2.3 Placement of a Non-Combustible Cover 8
2.4 Vegetation Clearing 10
2.5 Performance Testing 11
2.5.1 Initial Testing Prior to the Start of Construction 11
2.5.2 Additional Testing During Vegetation Clearing 12
2.5.3 Confirmation Testing 12
2.6 Demonstration of No Risk of Release from Remaining Vegetation 13
2.7 Perimeter Air Monitoring 13
2.8 Occupational Monitoring 14
2.9 NCC Inspections and Maintenance 15
3 Anticipated Schedule For NCC Completion 15
4 Project Team 15
5 References 16
Table
1 Area 1 and Area 2 Non-Combustible Cover Installation Schedule - West Lake
Landfill OU-1
Figures
1 Extent of Surface RIM as Defined in the RI - Area 1
2 Extent of Surface RIM as Defined in the RI - Area 2
3 Extent of Surface RIM and Overland Gamma Results from the RI - Area 1
4 Extent of Surface RIM and Overland Gamma Results from the RI - Area 2
5 Extent of Surface RIM and Areas of Existing Cover - Area 1
6 Extent of Surface RIM and Areas of Existing Cover - Area 2
7 Preliminary Extent of Non-Combustible Cover - Area 1
8 Preliminary Extent of Non-Combustible Cover - Area 2
9 Air Quality Monitoring Stations
10 Project Team
Attachments
1 Area 2 Sloped Rock Fill - Plan and Profile View
2 Inspection and Maintenance Plan
ii
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List of Acronyms
Auxier
Auxier & Associates, Inc.
EMSI
Engineering Management Support, Inc.
EPA
United States Environmental Protection Agency
FEI
Feezor Engineering, Inc.
FS
Feasibility Study
GERT
General Employee Radiation Training
GPS
GeoPositioning System
MARS SIM
Multi-Agency Radiation Survey and Site Investigation Manual
MDNR
Missouri Department of Natural Resources
MMP
Materials Management Plan
Nal
Sodium Iodide
NCC
Non-combustible Cover
ou
Operable Unit
oz/sy
ounces per square yard
PPE
personal protective equipment
QA
Quality Assurance
QC
Quality Control
RI
Remedial Investigation
RIM
Radiologically Impacted Material
SAP
Sampling and Analysis Plan
TAT
Turnaround Time
TLD
thermoluminescent dosimetry
UAO
Unilateral Administrative Order
VOCs
Volatile Organic Compounds
iii
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1 EXECUTIVE SUMMARY
The purpose of this project is to install a non-combustible cover ("NCC") over those
portions of OU-1 Areas 1 & 2 where radiologically-impacted material (RIM) is present at
the ground surface, in order to prevent potential surface fires and migration of
contaminants from those Areas, as required by the EPA's December 9, 2015 Unilateral
Administrative Order (UAO) issued to Bridgeton Landfill, LLC, Rock Road Industries,
Inc., and Cotter Corporation (N.S.L.) (the "OU-1 Respondents"). This Work Plan
describes the work to be performed to install the NCC in accordance with the UAO.
The sequence of actions that will occur from the start of the field work until the non-
combustible cover is in place is as follows:
1) Conduct initial overland gamma survey along the outer edges of the extent of
surface RIM/anticipated extent of rock cover (as shown on the figures in the
Work Plan) in those portions of Areas 1 & 2 that are currently accessible, as
well as in the adjacent Buffer Zone and on the adjacent Crossroad Lot 2A2
property (subject to receipt of permission to access that property).
2) Install non-combustible cover in Area 1, which will include the following:
a) Perform air monitoring - both for on-site workers and for the community
1) For on-site workers - portable air sampler on job site
2) For community - use present air monitoring program consisting of 13
air monitoring stations around perimeter of Areas 1 & 2
b) Grub and clear trees and vegetation in the areas of surface RIM
c) Chip the vegetation and place the chips on the ground in the areas to be
covered
d) Install geotextile over the cleared areas with surface RIM including the
areas containing chipped woody vegetation cuttings
e) Install 8 inches of rock over geotextile
f) Perform additional overland gamma surveys as the vegetation is cleared
from areas that were not previously accessible due to vegetation cover to
confirm extent of surface RIM
g) Install additional geotextile and rock cover as necessary to cover any
additional surface RIM that may be identified
3) Install non-combustible cover in Area 2, including the adjacent Buffer Zone,
as needed, which will include the following:
a) Perform air monitoring - both for on-site workers and for the community
3) For on-site workers - portable air sampler on job site
4) For community - use present air monitoring program consisting of 13
air monitoring stations around perimeter of Areas 1 & 2
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b) Grub and clear trees and vegetation in the areas of surface RIM
c) Chip the vegetation and place the chips on the ground in the areas to be
covered
d) Install geotextile over the cleared areas with surface RIM including the
areas containing chipped woody vegetation cuttings
e) Install 8 inches of rock over geotextile
f) Perform additional overland gamma surveys as the vegetation is cleared
from areas that were not previously accessible due to vegetation cover to
confirm extent of surface RIM
g) Install additional geotextile and rock cover as necessary to cover any
additional surface RIM that may be identified
4) Perform additional characterization including overland gamma surveying and
soil sample collection to evaluate the potential presence and if present the
extent of surface RIM that may exist on the uncovered (naturally vegetated)
portions of Crossroads Lot 2A2 {i.e., AAA Trailer property).
5) Install rock buttress in Area 2 in that portion of the berm located above the
southeast corner of the adjacent Buffer Zone (Figure 4)
6) Perform radiological soil sampling around the perimeter on the non-
combustible covers in Areas 1 & 2 (including the Buffer Zone) to confirm all
RIM at or near the surface has been covered.
a) Send soil samples to Eberline Analytical for analysis
a. request quick turnaround time for Thorium-230
b. analyze the samples using standard turn-around times for radium,
thorium and uranium isotopes plus protactimium-231 and lead-210
(i.e., the same radiological parameters that were included in the
analyses of the Phase ID samples and the Additional
Characterization of Areas 1 and 2 samples)
b) Perform additional clearing and covering if and as necessary based on the
initial Thorium-230 results
7) Receive results of standard turn-around time radiological analyses
8) Separately, confirm that remaining trees and vegetation do not present a fire
risk that could result in potential release of RIM into the environment (if
determined necessary by the USEPA). See Sampling and Analysis Plan for
procedures to be followed.
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9) Confirm of completion of project to install non-combustible cover
Please note that many of the above items will occur concurrently, not sequentially. For
example, installation of geotextile and rock will occur concurrently with clearing of
vegetation and performance of overland gamma surveys will occur concurrently with the
vegetation clearing. Similarly, collection of verification samples will occur whenever a
sufficient length of the anticipated final perimeter of the NCC has been installed.
Surveying to provide direction for clearing and construction and to document the
construction will occur concurrently with all of the activities.
For additional information regarding the specific procedures to be followed for this
project, please refer to this Work Plan and the following documents which are an integral
part of this Work Plan:
Health and Safety Plan for Non-Combustible Cover Installation at West Lake
Landfill, Operable Unit 1, Bridgeton, St. Louis County, Missouri dated February
8, 2016.
Radiation Safety Plan for Installation of Non-Combustible Cap, West Lake
Landfill's Operable Unit 1, 13570 St. Charles Rock Road, Bridgeton, Missouri,
63044, dated January 4, 2016
Quality Management Plan dated December 2015
Surface RIM Identification Sampling and Analysis Plan (SAP), West Lake
Superfund Site Operable Unit 1, dated December 2015
2 WORK TO BE PERFORMED
Paragraph 34. a. of the UAO identifies the following specific items to be addressed in this
Work Plan:
1. A current West Lake Landfill map clearly indicating where RIM is located at or
near the surface in OU-1. This map should also indicate which areas with surface
RIM are currently covered by vegetation or other materials and which remain
exposed to the atmosphere.
2. Plans and schedule for placement of a non-combustible cover or barrier as soon as
possible over all exposed areas at OU-1 where RIM is currently known to be
located at or near the surface and is not otherwise covered by vegetation, fill, or
other materials.
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3. Plans for grubbing and clearing all trees and vegetation where RIM is currently
known to be located at or near the surface in OU-1, and placement of a non-
combustible cover or barrier over the cleared areas.
4. Plans and schedule for the performance of testing to confirm that RIM located at
or near the surface in OU-1 has been covered.
5. Plans and schedule for ensuring the remaining trees and vegetation in OU-1 do not
present a fire risk that could result in the potential for release of RIM into the
environment.
6. Plans and schedule for air monitoring for ensuring protection of both on-site
workers and the surrounding community during grubbing and clearing of trees
and vegetation in OU-1, as well as during placement of the cover or barrier.
7. Plans for maintenance of the cover or barrier until a remedial action selected by
EPA that addresses the surficial RIM is implemented at the Site.
The anticipated activities and schedules to complete these seven items are discussed in
the following subsections of this Work Plan.
2.1 Extent of Surface RIM
The first item specified by the UAO for the NCC Work Plan is a map of the extent of
surface RIM that also shows the areas currently covered by vegetation or other materials.
2.1.1 Surface RIM Extent
The approximate extent of surface RIM was previously identified on Figures 6-1 and 6-3
of the OU-1 Remedial Investigation report (EMSI, 2000). These figures were used as the
initial basis for defining the extent of surface RIM (Figures 1 and 2). The results of the
1995 overland gamma survey (McLaren/Hart, 1996) were also reviewed to identify other
areas where surface RIM may potentially be present in Areas 1 and 2. The results of
these evaluations are summarized on Figures 3 and 4.
2.1.2 Vegetation Cover
Over the years since active waste disposal has ceased, extensive vegetative cover has
grown over the surface of Areas 1 and 2. The aerial photography used as the base
drawing for Figures 1 and 2 displays the extent of vegetation cover on Areas 1 and 2. No
survey of the extent of vegetative cover on Areas 1 and 2 has ever been performed.
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Therefore, for purposes of this NCC Work Plan, the extent of vegetative cover is assumed
to extend over all portions of Areas 1 and 2 that are not otherwise covered by inert fill or
asphalt pavement (described below).
2.1.3 Other C over Materi al
A feasibility study (FS) of potential remedial alternatives was completed in 2006 for OU-
1. The FS identified regrading of the surface of Areas 1 and 2 to promote drainage in
conjunction with installation of a new engineered landfill cover as likely components of
remedial action for OU-1. In anticipation of the regrading and landfill cover construction
activities, Bridgeton Landfill prepared a Materials Management Plan (MMP) (EMSI,
2006), which was subsequently approved by the Missouri Department of Natural
Resources (MDNR). The purpose of the MMP was to allow Bridgeton Landfill to accept
for disposal inert fill material that could be placed on the surfaces of Areas 1 and 2 to
assist with the anticipated regrading and cover construction activities. Pursuant to the
MMP, over the period from approximately 2006 through 2008, Bridgeton Landfill
accepted concrete rubble, brick and other inert fill material which was placed in a
topographic low (surface depression) in Area 1 and on the ground surface in Area 2. The
extent of inert fill material on the surface of Areas 1 and 2 is shown on Figures 5 and 6.
In addition to the inert fill material, portions of the surface of Area 1 were historically
covered with asphalt pavement. The extent of the asphalt pavement in Area 1 is shown
on Figure 5. Cracks and other discontinuities exist in the asphalt pavement such that
grasses, weeds and small trees have rooted in the area of the asphalt pavement.
Lastly, as part of recently performed additional investigations in Areas 1 and 2,
vegetation was cleared and geotextile overlain by a nominal 8-inch thick layer of road
base was placed along the roads and drill pads used to access Areas 1 and 2 to perform
additional soil borings. The locations of the various roads in Areas 1 and 2 are shown on
Figures 5 and 6.
2.2 Buffer Zone and Crossroads Lot 2A2 Vegetative Areas Investigation
It should be noted that, based on samples collected by McLaren Hart in 1995 (boreholes
WL-201 through WL-208), EMSI in 1997 (samples designated FP-1 through FP-8), and
Herst & Associates in 2000 (RC-01 through RC-07), the Remedial Investigation (RI)
(EMSI, 2000) also identified occurrences of radionuclides in surface soil in the southern
portion of what at that time was property owned by Ford Motor Credit (referred to in the
RI as the Ford property but after a subsequent parcel division and sales has since been
referred to as the Buffer Zone and Crossroads Lot 2A2), located immediately to the north
and west of Area 2. Reportedly, after completion of landfilling activities in Area 2, but
prior to establishment of a vegetative cover over the landfill berm, erosion of soil from
the landfill berm resulted in the transport of radiologically-impacted materials from Area
2 onto the adjacent Ford property (EMSI, 2000). The landfill berm and the adjacent
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properties were subsequently re-vegetated by natural processes, and no subsequent
erosion or other failures are present.
Ford sold a portion of the property to Crossroad Properties, LLC (Crossroad), and sold
the remaining portion (the Buffer Zone) to Rock Road Industries to provide a buffer
between the landfill and the adjacent properties. In November 1999, third parties scraped
the vegetation and surface soil on Crossroad Lot 2A2 and the Buffer Zone to a depth of
approximately 2 to 6 inches. These activities were unauthorized. The removed materials
were piled in a berm along the southern boundary of the Buffer Zone, adjacent to the
northwestern boundary of the West Lake Landfill. A small amount of removed materials
was also placed in a small pile on the Crossroad property near the base of the landfill
berm along the east side of Lot 2A2.
In February 2000, additional surface soil samples (RC-01 through RC-07) were collected
from the disturbed area and submitted for laboratory testing. Only one sample (RC-02)
obtained from the Buffer Zone, below and adjacent to the toe of the landfill berm,
contained radionuclides (thorium-230) above levels that would allow for unrestricted use.
The remainder of the samples contained either background levels of radionuclides or
levels above background but within levels that would allow for unrestricted use. The
results of the additional soil sampling indicated that most of the radiologically impacted
soil that had previously been present on the Buffer Zone and Lot 2A2 of the Crossroad
property had been removed and placed in the stockpiles. Evaluation of the soil sampling
results obtained prior to and after the 1999 disturbance indicates that approximately one
acre of the Buffer Zone may at that time still have contained some radionuclides above
levels that would allow for unrestricted land use (i.e., combined radium or combined
thorium activities greater than 5 pCi/g plus background which equates to 7.9 pCi/g).
Inspection of the area in May 2000 indicated that native vegetation had been re-
established over both the disturbed area and the stockpiled materials. The sequence of
soil sampling activities and associated results are presented in the RI (EMSI, 2000)
A 2004 inspection of this area indicated that additional soil removal/re-grading had been
performed on the remaining portion of the Crossroad property and the adjacent Buffer
Zone property by third parties. These activities appear to have resulted in removal of the
soil stockpiles created during the previous re-grading activity, removal of any remaining
soil on Lot 2A2 and the Buffer Zone not scraped up during the 1999 event, and
placement of gravel over the entirety of Lot 2A2 and most of the Buffer Zone.
Reportedly, all of the soil removed during the July 1999 grading work and the May 2003
gravel layer installation was placed in the northeastern corner of the Buffer Zone (terra
technologies, 2004).
No sampling has been performed since the most recent (May 2003) grading work
conducted by third parties was performed, and therefore the levels and extent of
radionuclides, if any, that may remain in the soil at the Buffer Zone and Crossroad
Property are unknown. As discussed above, Lot 2A2 and most of the Buffer Zone were
covered with gravel and Lot 2A2 was subsequently paved by AAA Trailer. In addition,
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as discussed in Section 2.2 below, it is anticipated that a temporary rock buttress will be
constructed on the Buffer Zone parcel to provide for an NCC on the landfill slope in this
area. Therefore, based on the historical data, it is expected that all or most any surface
RIM that may still exist on the Buffer Zone property will be covered by the temporary
rock buttress. A MARS SIM final status survey of Crossroad Lot 2A2 and the Buffer
Zone will be conducted as necessary during remedial design activities associated with
implementation of the selected remedy for this area to evaluate compliance with the
cleanup standards selected by EPA.
Additional discussion of the prior sampling and activities relative to the Buffer Zone and
Crossroads Lot 2A2 can be found in the RI (EMSI, 2000), Feasibility Study (EMSI,
2006) and Supplemental Feasibility Study (EMSI, 2010).
The entire Buffer Zone is currently owned by Rock Road Industries, Inc. and is therefore
currently accessible to the Respondents for purposes of performing the required work.
The Buffer Zone will be scanned via overland gamma scan according to the procedures
specified in the Work Plan and associated planning documents (e.g., Sampling and
Analysis Plan). The overland gamma survey will be performed using Ludlum 44-10
(2x2) Sodium Iodide (Nal) detectors coupled to Ludlum 2221 survey meters modified to
integrate and transfer data from the detector at a rate of once per second to a Trimble
GeoPositioning System (GPS) which stores the gamma reading and the location of that
reading. If the scanning procedures indicate the potential for RIM, the affected areas will
be cleared of vegetation followed by placement of a geotextile fabric and a nominal 8-
inches of road base material. After clearing has occurred 10 feet beyond the extent of
surface RIM identified in the Work Plan, or as further defined by the results of the
overland gamma survey to be conducted along the perimeter of the outer boundary of the
extent of surface RIM/outer edge of the NCC, confirmation samples will be collected at
approximately 100 feet spacing along the perimeter except for those areas where the
outer edge of the surface RIM/NCC coincides with the edges of the Buffer Zone. More
frequent biased samples will be obtained from any areas where erosion of the surface or
sediment accrual are identified.
Crossroads Lot 2A2, which is located adjacent to the Buffer Zone, is not owned or
controlled by Respondents. After receipt of EPA approval to do so, the OU-1
Respondents' Project Coordinator will contact the current owner of Crossroads Lot 2A2
to obtain permission to conduct additional characterization via overland gamma scanning
and confirmation testing within all uncovered areas of Lot 2A2 that are contiguous with
the West lake Landfill Area 2 Fence. The same procedures (overland gamma scanning
and confirmation sampling) will be used as described above for the Buffer Zone. Upon
receipt of site access to conduct the additional characterization work on Lot 2A2, such
work will be conducted in accordance with any scheduling and access conditions
imposed by the property owner once access is granted, and as soon as personnel and
equipment can be made available. The results of the additional characterization will be
provided to the USEPA.
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A schedule for the additional characterization of the unpaved portions of Crossroads Lot
2A2 is included in Table 1. It is expected that once sufficient vegetation has been
cleared, it should only take approximately one day to perform the overland gamma
survey of the Buffer Zone. This work will be done once the contractor clears the
vegetation from the Buffer Zone, which will occur after the contractor clears the
vegetation leading to the edge of the top of Area 2 and from the slope of the landfill berm
above the Buffer Zone and builds a ramp from the top of the slope down to the Buffer
Zone. A specific schedule has not been established for these clearing and ramp-building
activities.
It is anticipated that overland gamma surveying of uncovered, natural vegetation areas on
Crossroads Lot 2A2 can be completed in a few hours (provided we receive permission to
do so). Any additional characterization work associated with certain areas of Lot 2A2
will not be contingent on any work which would be performed in the Buffer Zone.
Access to Lot 2A2 will be obtained from the property owner via coordination with EPA,
as needed, and additional characterization of Lot 2A2 will begin as soon as possible.
2.3 Placement of a Non-Combustible Cover
Based on the extent of RIM described in Section 2.1 and shown on Figures 3 and 4, and
also taking into account the extent of inert fill material and road base that currently exists
in Areas 1 and 2 (Figures 5 and 6), the anticipated extent of the NCC has been identified
as shown on Figures 7 and 8. Please note that the extent of asphalt pavement in Area 1 is
not included as part of the extent of existing cover material because as noted above,
vegetation has grown up through cracks and other discontinuities in the asphalt pavement
and asphalt is not considered to be a non-combustible material. By comparison, the inert
fill material and road base that currently exist in Areas 1 and 2 were included as part of
the estimation of existing cover material. The areas of inert fill that are in close
proximity to the proposed extent of new non-combustible cover will need to be visually
inspected to determine if any additional rock cover needs to be place on or adjacent to the
existing inert fill material.
Given that the extent of surface RIM in Areas 1 and 2 is approximately 1.4 acres in Area
1 and 8.74 acres in Area 2 and the extent of existing inert fill and road base cover is
approximately 0.4 acres in Area 1 and 0.79 acres in Area 2, the total area for NCC
construction in Areas 1 and 2 is estimated to be 1.0 and 7.95 acres, respectively. In order
to ensure that the extent of surface RIM in these areas is completely covered, the bid
specifications for the NCC will require the contractor to extend the cover placement
nominally 10 ft beyond the edge of all areas where surface RIM is identified as being
present within Areas 1 and 2; however, the cover will not extend beyond the limits of the
Area 1 or 2 waste disposal units. Therefore, the total extent of the NCC cover is
anticipated to be approximately 1.2 acres in Area 1 and 8.75 acres in Area 2 for a total
area of approximately 10 acres in these two areas.
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Placement of a NCC over these areas will entail cutting/removal of the existing
vegetation in these areas followed by placement of a geotextile fabric and a nominal 8-
inches of road base material. The anticipated profile for the NCC is shown on Figures 7
and 8. If evidence of erosion or sediment deposition are identified outside of the areas to
be covered by the NCC, additional biased samples will be collected from such areas and
tested as part of the confirmation testing (see Confirmation Testing, Section 2.5.3). If the
analytical testing of the additional biased samples indicates the presence of surface RIM,
the area of erosion or sediment accumulation associated with such a sample will be
covered with a geotextile and new rock fill.
The vegetation will be cleared with a forestry mower attached to a low ground pressure
tractor such as a skid steer. The vegetation will be moistened as necessary to minimize
visible dust prior to the forestry mower advancing. Rutting will be minimized by the
equipment selection. Metal items or other debris on the surface of the existing landfill will
be moved to an area or areas within Area 1 or 2 outside of the extent of where surface RIM
exists. The debris will be stockpiled on the existing asphalt pavement in Area 1 and/or on
the existing inert fill in Area 2, or otherwise placed in an area(s) outside of the extent of
surface RIM/non-combustible cover.
Rock stockpiles may be used for temporary storage of rock prior to placement within the
NCC cover area, but it is generally expected the rock material will be delivered to the NCC
cover area via tandem on-road haul trucks, and the trucks will only drive on previously
rocked areas and deposit the rock onto the advancing front of the cleared areas. The
geotextile and rock placement will occur in such a manner that all newly cleared areas will
be covered generally within 24 hours, but not more than 48 hours after clearing.
The source of the rock will be from a local quarry (most likely the Fred Weber quarry in
Maryland Heights, MO). The field engineer will collect load tickets from the drivers to
document that the source of rock was from a commercial quarry.
It is likely that surface RIM is present along a portion of the landfill berm on the north
side of Area 2, specifically in that portion of the berm located above the southeast corner
of the adjacent Buffer Zone (Figure 4). Because of the steep slope (1 5H: IV) associated
with the landfill berm, placement of geotextile with 8-inches of road base is not
anticipated to provide for a stable cover. Therefore, in this area, a temporary rock
buttress will be constructed from the base to near the top of the landfill berm. The rock
buttress will be constructed by clearing vegetation from the Buffer Zone and from the
landfill berm slope to the extent it can be conducted in a safe manner, followed by
placing road base material on the Buffer Zone and extending up the face of the landfill
berm. Attachment 1 presents a drawing of the preliminary design for the rock buttress.
This rock buttress would be temporary, and, if necessary, most of the rock could be
reclaimed during implementation of future remedial actions that may be implemented at
the Site.
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The OU-1 Respondents have employed the procurement services of Bridgeton Landfill,
Inc. and Republic Services, Inc. to procure a contractor to perform the vegetation clearing
and construct the NCC. A bid package was completed and released to the prospective
contractors on January 12, 2016 and that bids were received by January 22, 2016.
Review of the bids and notice of intent to award were completed by February 3, 2016.
The bid package included a sample contract with the West Lake Landfill NPL Site Trust
("the Trust") so the prospective contractors were aware of all contract conditions.
It is anticipated that installation of the NCC will begin on February 15, 2016 subject to
weather conditions and the availability of the contractor personnel, necessary equipment
(e.g., forestry mower) and required materials (e.g., geotextile). Prior to starting any work
on site, the selected contractor personnel will be provided General Employee Radiation
Training (GERT) if they have not already received it, as well as an overall orientation to
Bridgeton Landfill safety procedures and communication of potential hazards associated
with the NCC project. EPA was provided notice of the contractor selected to perform the
work (Kuesel Excavating Co. Inc.) on February 3, 2016 as set forth in Paragraph 30 of
the UAO. EPA was provided notice of the intended start of construction on February 12,
2016, in accordance with Paragraph 36(c) of the UAO.
2.4 Vegetation Clearing
Vegetation removal and construction of the NCC are anticipated to be performed using
procedures similar to those previously employed to construct the access roads and drill
pads during the prior Phase 1, Phase ID, and Additional Characterization of Areas 1 and
2 investigations. Specifically, the vegetation will be cut near but above the ground
surface using a "brush hog", a skid steer with a forestry cutter/grinder attachment, or
equivalent equipment. Such equipment can cut and grind woody vegetation without
disturbing the underlying ground surface or vegetation roots. The vegetation cuttings
will be chipped and placed on the ground surface. Any significantly sized wood
vegetation that needs to be removed will be cut with tree shears and chipped in a wood
chipper. If necessary, the woody vegetation will be moistened with a water cannon prior
to grinding to minimize chipping dust. The chipped woody vegetation will be placed
beneath the extent of the NCC prior to geotextile deployment. Any material that is too
large to chip (such as larger tree limbs or trunk sections) will be cut into 10 foot sections
and placed in low lying areas and covered with geotextile and rock. The goal will be to
minimize any uncovered logs long term. Should this not be possible, the logs will be
neatly placed in an area where there is no RIM at or near the surface.
A geotextile will be laid on top of the cleared area and vegetation chips over which
approximately 8 inches of road base material will be placed. Profile views of the final
NCC are provided on Figures 7 and 8. Based on prior experience with building drill pad
access roads in Areas 1 and 2, it is anticipated that additional road base material will need
to be placed in any depressed areas or at the base of any steep slopes (e.g., steeper than
4H:1V).
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The areas of the inert fill that are in close proximity to the proposed extent of new non-
combustible cover will visually inspected to determine if any additional fill placement is
necessary in the transition area between the new rock cover and the existing inert fill.
It is anticipated that placement of the geotextile and rock cover material will
generally occur the same day as the vegetation removal activities, but in any event
should be completed within 48 hours of the vegetation clearing in any particular
area. Should heavy rain be forecasted and an area cannot be covered the same day,
storm water waddles will be placed on any downslope areas. In addition, vegetation
clearing will not be performed during periods when severe thunderstorms or major
precipitation events (rainfall of a rate of over V2 inch per hour) are forecasted for the
site area or when observations by on-site personnel indicate a potential for a severe
thunderstorm or major precipitation event. Additionally, on days when precipitation
is anticipated to occur, placement of geotextile and rock cover will be coordinated to
closely follow the vegetation clearing activities and the vegetation clearing will be
closely monitored and/or suspended as necessary to ensure that the geotextile and
sufficient cover necessary to anchor the geotextile can be placed prior to the
occurrence of thunderstorms. Please note that monitoring of stormwater during
NCC construction is addressed in a separate document that was submitted to EPA on
February 23, 2016 that was conditionally approved by EPA on March 1, 2016.
NCC construction will only occur during days where the working temperatures will be 25
degrees or higher. The average temperature for February is approximately 35 degrees
and the average temperature for March is above 40 degrees, so this requirement should
generally not limit construction. Should the temperatures drop below freezing, caution
will be used to avoid using too much water (needed for dust suppression) to avoid ice
accumulations to prevent slips, trips or falls.
2.5 Performance Testing
It is anticipated that testing will be conducted in three phases to verify the extent of
surface RIM and to confirm that the NCC extends over the full extent of surface RIM.
2.5.1 Initial Testing Prior to the Start of Construction
Subject to physical access constraints posed by the existing vegetation cover, an initial
overland gamma survey will be performed along the margins of the estimated extent of
surface RIM (Figures 3 and 4) to provide an initial verification of the extent of surface
RIM. Prior to conducting the overland gamma survey, a reference area or areas will be
identified and overland gamma survey background values will be obtained from this
area(s).
NCC Work Plan
1/4/2016 Revised 2-12-16 Final 3-16-16
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The overland gamma survey will be performed using Ludlum 44-10 (2x2) Sodium Iodide
(Nal) detectors coupled to Ludlum 2221 survey meters modified to integrate and transfer
data from the detector at a rate of once per second to a Trimble GeoPositioning System
(GPS) which stores the gamma reading and the location of that reading. The detectors
will be hung approximately six-inches above the ground surface and advanced at a rate of
approximately 0.5 meters per second. Separation between the scanned transit lines will be
approximately 1.5 meters unless influenced by terrain. Stored data will be downloaded
and processed using commercially available software applications and plotted on a map
of the Areas. Individual points will be assigned colors based on the magnitude of
instrument response at that location.
Additional details regarding the data quality objectives and the procedures to be used for
the overland gamma survey can be found in the Sampling and Analysis Plan (SAP)
(Auxier, 2015a).
No problems or issues for performance of the overland gamma survey are expected to be
encountered from vegetation hindrances because the overland gamma survey will be
performed prior to or in conjunction with the clearing of vegetation from the areas
identified as containing, or potentially containing surface RIM.
2.5.2 Additional Testing During Vegetation Clearing
Based on the maps generated from the initial overland gamma survey, remaining
inaccessible areas that may contain surface RIM will be identified for vegetation clearing.
A health physicist will then be assigned to perform additional overland gamma surveys in
conjunction with the vegetation clearing activities to further verify the extent of surface
RIM. These surveys will be conducted using the same techniques described above for
the initial survey. The results of the additional surveys will be added to the map of the
results obtained from the initial survey.
2.5.3 Confirmation Testing
Once the results of the overland gamma surveys described above define the extent of
surface RIM, surface soil samples will be obtained along the perimeter to confirm the
absence of RIM beyond the extent determined by the overland gamma surveys. It is
anticipated that the surface soil sampling will be performed outside the perimeter of the
defined surface RIM/outer extent of the NCC to verify that thorium-230 (which cannot be
detected by the overland gamma survey) is not present outside the outer limit of the new
cover at activity levels greater than the level that would allow for unrestricted land use. It
is anticipated that soil samples will be collected from locations spaced approximately 100
feet apart along the perimeter of the outer boundary of the extent of surface RIM/outer
edge of the NCC except for those areas where the outer edge of the surface RIM
coincides with the edges of the Area 1 or Area 2 waste disposal unit boundaries. More
frequent biased samples will be obtained from any potential sediment depositional areas
that may be identified during the vegetation clearing, overland gamma survey or NCC
NCC Work Plan
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installation activities. This confirmation testing will occur on the edge of the 10-foot
outer clearing limit, so the area will be cleared of vegetation.
Surface soil samples will be submitted to Eberline Analytical Laboratory (Eberline) for
quick turn-around-time (TAT) isotopic thorium analysis. The quick TAT isotopic
thorium analyses will allow for an initial, quick determination as to whether the extent of
NCC is sufficient or if placement of additional NCC may be required while the NCC
contractor is still present at the site. The samples will also be analyzed for isotopic
uranium and gamma spectroscopy in order to provide data comparable to the other
investigatory data obtained from OU-1 areas.
2.6 Demonstration of No Risk of Release from Remaining Vegetation
Vegetation located outside the extent of surface RIM will remain on site. The results of
the previous (2009) collection and analysis of vegetation samples are consistent with the
established site background levels for RIM in soil (T. A. Woodford and Associates, 2009).
The remaining vegetation at the site is not anticipated to pose any risk of release of
radionuclides.
Discussions with EPA have indicated that they are still reviewing the results of the 2009
vegetation sampling event relative to the potential for release of radionuclides in the
event a vegetation fire occurs at the site. If EPA concludes that the existing sample data
provide sufficient basis to demonstrate that the remaining vegetation would not pose a
risk of release in the event of a fire, no additional sampling will be conducted. If EPA
determines that additional sample collection and analyses are required to complete the
specified demonstration, additional samples will be obtained as necessary to demonstrate
that the remaining vegetation does not pose a threat of release of radionuclides in the
event of a fire.
The Sampling and Analysis Plan (Auxier, 2015a) submitted in conjunction with this
Work Plan contains additional details regarding the scope and procedures to be used to
conduct additional vegetation sample collection and analyses. The pertinent sections of
that plan are currently under review by EPA.
2.7 Perimeter Air Monitoring
Pursuant to a prior request from EPA, the OU-1 Respondents previously implemented an
air monitoring program consisting of 13 stations located around the perimeters of Areas 1
and 2 and elsewhere at the West Lake Landfill/Bridgeton Landfill site (Figure 9).
Specifically, an Air Monitoring, Sampling and QA/QC Plan was prepared (Auxier &
Associates, Inc., 2014), and was approved by EPA on December 5, 2014. Installation of
the air monitoring stations was performed in early 2015, and continuous air monitoring
began on May 1, 2015. A report of the results from the first quarter of air monitoring
NCC Work Plan
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activities (May, June and July 2015) was submitted to EPA on December 9, 2015 (Auxier
and EMSI, 2015).
The perimeter air monitoring activities include sampling for airborne radioactive
particulates, radon gas, and volatile organic compounds (VOCs), and measurements of
gamma radiation. Sampling is performed continuously at the perimeters of OU-1 Areas 1
and 2. All 13 monitoring stations include air sampling pumps equipped with air sample
filters for collection of particulate samples for analyses of alpha and beta emitters. The
particulate filters are collected every four weeks (28 days) and sent to Eberline Analytical
for laboratory analyses. One set of the three sets of filter samples obtained during each
calendar quarter are also analyzed for uranium and thorium isotopes and for radium by
gamma spectroscopy. All 13 monitoring points also include radiation dosimeters for
measurement of gamma radiation, and alpha track etch detectors for measurement of
radon emissions that are submitted for laboratory analysis by Mirion Technologies and
AccurStar, respectively, every calendar quarter.
Five of the monitoring stations house continuous passive samplers to monitor for VOCs.
Monitoring of VOCs is performed using the Radiello Code 130 chemical adsorbing
cartridge diffusion samplers that are left in place for periods of 14 days. These sampling
devices are submitted to EuroFins Air Toxics Ltd for VOC analyses.
Data obtained from the ongoing perimeter air monitoring program are expected to be the
primary method for evaluation of protection of the surrounding community during
installation of the NCC over the surface RIM in OU-1.
2.8 Occupational Monitoring
In addition to the continued operation of the perimeter air monitoring program currently
employed for Areas 1 and 2, temporary air monitoring activities will be conducted during
the vegetation clearing and NCC placement activities. Specifically, portable air pumps
equipped with filters will be set up near active work areas and/or installed on equipment
to obtain particulate samples for analysis for alpha and beta emitters.
Ambient radiation levels in work areas will be routinely monitored during NCC
construction. In addition, all workers will wear thermoluminescent dosimetry (TLD)
badges to monitor their exposures to gamma radiation. The data obtained from analysis
of samples collected by the portable air sampling equipment and TLDs will be used to
verify that site workers are not exposed to radiation or radioactive materials above
permissible levels.
In conjunction with use of personal protective equipment (PPE) and adherence to
procedures set forth in the Health and Safety Plan (Auxier, 2015b) and Radiation Safety
Plan (Auxier, 2015c), the results obtained from the perimeter and portable air sampling
points and TLDs will be used to ensure protection of site workers.
NCC Work Plan
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2.9 NCC Inspections and Maintenance
Quarterly inspections will be performed by a designee of the OU-1 Respondents to verify
that the NCC remains intact and that stormwater runoff, burrowing animals or other
activities have not caused any impacts that would affect the performance of the NCC.
Additional inspections will be conducted after major precipitation events of sufficient
intensity and/or duration to potentially impact the integrity of the NCC.
A description of the anticipated NCC inspection and maintenance activities is included as
Attachment 2.
3 ANTICIPATED SCHEDULE FOR NCC COMPLETION
Table 1 presents an anticipated schedule for the various activities to be conducted to
place the NCC over the surface RIM, collect and analyze samples to confirm that the
NCC completely encompasses the surface RIM, and, if necessary, collect and analyze
samples of vegetation obtained from outside the extent of surface RIM to further support
the demonstration that in the event of a fire, the remaining vegetation will not result in a
release of radionuclides. Subject to weather conditions, equipment and material
availability and other factors, the OU-1 Group anticipates installation of the additional
cover material will be completed within approximately 90 days of EPA approval of this
Work Plan and the related project plans.
The status and results of the work performed to plan, construct and inspect/maintain the
NCC cover will be tracked and reported to EPA in monthly status reports, as required by
the UAO. A final report documenting the NCC installation is anticipated to be completed
within 30 days of receipt of the final analytical laboratory report for the confirmation soil
samples.
4 PROJECT TEAM
The project team will consist primarily of contractors that have previously been working
in Areas 1 and 2 along with a construction contractor to be retained to perform the
vegetation clearing and placement of the non-combustible cover.
Engineering Management Support, Inc. (EMSI) will provide overall coordination of the
work including coordination of preparation of project plans, coordination of the various
contractors, and coordination with EPA. Specifically, Paul Rosasco, P.E., the designated
Project Coordinator under the UAO, will serve as the overall Project Coordinator for the
Respondents, with assistance from Robert Jelinek, P.E. EMSI will also be responsible
NCC Work Plan
1/4/2016 Revised 2-12-16 Final 3-16-16
Page 15
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for preparation of monthly progress reports and overall coordination of the final report
for the NCC installation project.
Feezor Engineering, Inc. (FEI) will provide office and field engineering services,
including preparation of design and record drawings, supervision and documentation of
field activities, and collection of confirmation surface soil samples (as necessary). Daniel
Feezor, P.E., will serve as lead Project Engineer and Jonathan Wilkinson, P.E., will be
lead Field Engineer for this project. FEI will also perform post-installation NCC
inspections to verify that the NCC remains intact and identify any maintenance or repair
activities that may be required.
Auxier & Associates, Inc. (Auxier) will provide health physics services including
performance of radiation surveys including but not limited to overland gamma surveys,
perimeter air monitoring, occupational monitoring during NCC construction, and free
release surveys for equipment exiting Area 1 and 2. Michael R. Bollenbacher, CHP will
serve as lead health physicist and radiation safety officer. Mr. Bollenbacher will be
assisted by Cecilia Greene, MPH who will serve as the Health Physics project manager.
Alex Luna will be the on-site health physics technician and site safety officer. Auxier
will be responsible for implementation of the project health and safety and radiation
safety plans for this work.
Weaver Consultants Group (Weaver) will survey the locations where confirmation
surface soil samples are collected, provide survey control during construction, and survey
the outer limits of the final, installed NCC. Collin Carson will serve as lead surveyor for
the NCC installation project.
Eberline Analytical/Oak Ridge Laboratory will perform radionuclide analyses of soil
samples collected to provide confirmation that the NCC extends beyond the extent of
surface RIM.
Kuesel Excavating Co., Inc. was selected as the construction contractor for the vegetation
clearing and installation of the non-combustible cover over areas where RIM is present or
potentially is present at or near the ground surface in Areas 1 and 2 and the Buffer Zone.
Kuesel Excavating Co., Inc., is based in O'Fallon, Missouri and has been performing
demolition, clearing, grading, utility installation, stream back restoration, and soil
stabilization related services in Missouri for over 50 years. Relative to Bridgeton
Landfill, Kuesel recently provided demolition services and sub-grade preparation related
to construction of the leachate pre-treatment system and is currently working on
stormwater drainage improvements for the site.
5 REFERENCES
Auxier & Associates, Inc. (Auxier), 2015a, Surface Rim Identification, Sampling, and
QA/QC Plan, West Lake Landfill Superfund Site Operable Unit-1, December.
NCC Work Plan
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Auxier, 2015b, Draft Health and Safety Plan for Non-combustible Cover Installation at
West Lake Landfill, Operable Unit-1, Bridgeton, St. Louis County, Missouri, December
21.
Auxier, 2015c, "Radiation Safety Plan for Installation of Non-combustible Cap, in
Operable Unit 1 of Westlake Landfill Operable Unit-1, December 21.
Auxier, 2014, Air Monitoring, Sampling and QA/QC Plan, West Lake Landfill
Superfund Site Operable Unit-1.
Auxier and EMSI, 2015, West Lake Landfill Perimeter Air Monitoring Quarterly Report,
December.
Engineering Management Support, Inc. (EMSI), 2016, Letter from Paul Rosasco of
EMSI to Tom Mahler of EPA re: Stormwater Monitoring During Non-Combustible
Cover Construction, West Lake Landfill Operable Unit-1, West Lake Landfill, Bridgeton
Missouri, February 23.
EMSI, 2006, Materials Management Plan, West Lake Landfill Operable Unit 1.
EMSI, 2000, Remedial Investigation Report, West Lake Landfill Operable Unit 1, April
10.
McLaren/Hart, 1996, Overland Gamma Survey Report, West Lake Landfill Radiological
Areas 1 and 2, Bridgeton Missouri, April 30.
T.A. Woodford and Associates, LLC, 2009, Vegetation Sampling Results Summary in
Support of Health and Safety Plan for Vegetation Clearing and Grubbing, March.
terra technologies, 2004, Letter to Ms. Cheryle Micinski, USEPA from David Heinze,
terra technologies re: Clarifications to Information Request, West Lake Landfill Site,
September 10, 2004.
United States Environmental Protection Agency (EPA), 2015, Letter from Alyse Stoy
(EPA) to William Beck, Esq. and Jessica Merrigan, Esq., John McGahren, Esq., Steven
Miller, Esq., and Phil Dupre, Esq. RE: In the Matter of Cotter Corporation (NSL), and
Laidlaw Waste Systems (Bridgeton), Inc. and Rock Road Industries, Inc., and the U.S.
Department of Energy, Administrative Order on Consent, EPA Docket No. VII-93-F-
0005, December 9.
EPA, U.S. Department of Energy, U.S. Nuclear Regulatory Commission, and U.S.
Department of Defense, 2000, Multi-Agency Radiation Survey and Site Investigation
Manual (MARSSIM), NUREG-1575, Rev 1, EPA 402-R-97-016, Rev. 1, DOE/EH-0624,
Rev. 1, August.
NCC Work Plan
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Table
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Table 1 - West Lake Landfill 1 OU-1
Area 1 and Area 2 Non Combustible Cover Installation
ID
Task Name Duration Start
|j
I?/?"
anuary | February | March | April May | June
1/3 h/ioll/l7I1/24I1/31I 2/7 12/14I2/2112/28I 3/6 I3/13I3/20I3/2714/3 k/loU/17^/24 5/1 I 5/8 Is/15I5/22I5/29 6/5 16/12I6/19I&
1
Submit Work Plan to USEPA Odays Mon 1/4/16
#• 1/4
2
USEPA Review and Approval of 4 wks Mon 1/4/16
Work Plan
3
Planning/ Bidding 16 days Fri 1/8/16
4
Send Contractors Bid Package 1 day Fri 1/8/16
Pre Bid Meeting 3 days Mon 1/11/16
1
5
6
Bids Due 2 wks Mon 1/11/16
; I-
7
Award Contract 5 days Mon 1/25/16
. I
8
Field Work 40 days Mon 2/1/16
9
Conduct Overland Gamma Surv4 wks Mon 2/1/16
Install NCC Area 1 1 wk Mon 2/8/16
10
11
Install NCC Area 2 6 wks Mon 2/15/16
1
12
AAA Trailer Survey and Sampling 1 day Tue 3/8/16
11
13
Install Rock Buttress 3 wks Mon 2/22/16
1
1
14
Project Wrap Up 65 days Mon 3/28/16
Radiological sampling around 1 wk Mon 3/28/16
perimeter of NCC
15
1 1
16
Radiological sample testing and 8 wks Mon 4/4/16
data validation
1 1
17
Final Report preparation and 8 wks Mon 5/2/16
submittal
External Tasks
I External Milestone
Deadline
Progress
1 Manual Progress
Page 1
Project: West Lake NCC Constru
Date: Fri 3/11/16
Task
Split
Milestone
Summary
Project Summary
Inactive Task
Inactive Milestone
Inactive Summary
Manual Task
Duration-only
Manual Summary Rollup
Manual Summary
Start-only
Finish-only
-------
Figures
-------
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
(from Figure 6-3 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Notes:
• 2015 Topography And Backround Image Provided By
Cooper aerial Surveys Co. - Dated February 10, 2015
• all Elevations Are Above Mean Sea Level (amsl)
SCALE IN FEET
Figure 1
Extent of Surface RIM as
Defined in the Rl
Area 1
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
-------
LEGEND
Approximate Extent of Radionuclide
— Impacted Materials at the Landfill Surface
Approximately 10.6 Acres
(from Figure 6-5 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Notes:
• 2015 Topography and Backround Image Provided by
Cooper Aerial Surveys Co. - Dated February 10, 2015
• All Elevations are Above Mean Sea Level (amsl)
SCALE IN FEET
Figure 2
Extent of Surface RIM as
Defined in the Rl
Area 2
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
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M:\CUENTS\EMSI\WESTlAKE\2!!1S\RUBBLE-ll«ESTIGMI0N\RUBBLE-PAUL-KJ!LDUP.DWe-iWE* 1-FK3 01/04/2016 4:11PM
LEGEND
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
(from Figure 6-3 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Overland Gamma Reading,
Background or Less
Overland Gamma Reading,
2x Background or Less
Overland Gamma Reading,
More Than 2x Background
Notes:
• 2015 Topography And Backround Image Provided By
Cooper aerial Surveys Co. - Dated February 10, 2015
• all Elevations Are Above Mean Sea Level (amsl)
+
100
100
SCALE IN FEET
Figure 3
Extent of Surface RIM and Overland
Gamma Results from the Rl
Area 1
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
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M:\CUENTS\EWSI\WESTIAKE\2015\RUBBLE—!S"^VEST!GATIOW\RUBBLE—RAUL—BUIIJDUP-OWG—AREA 2 FIG4 02/12/2016 1:17PM
LEGEND
+
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
Approximately 10.6 Acres
(from Figure 6-5 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Potential Additional Areas Where Surface
Radionuclide Impacted Material May be Present
Approximately .74 Acres
Overland Gamma Reading,
Background or Less
Overland Gamma Reading,
2x Background or Less
Overland Gamma Reading,
More Than 2x Background
Notes:
• 2015 Topography and Backround Image Provided by
Cooper Aerial Surveys Co. - Dated February 10, 2015
• All Elevations are Above Mean Sea Level (amsl)
150
150
SCALE IN FEET
Figure 4
Extent of Surface RIM and Overland
Gamma Results from the Rl
Area 2
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
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M:\CUENTS\BMSI\WESTLAKE\2015\RU BBLE- IKVESTnaATION\RUBBLE—PAUL-ajlLDUP.DWG-ARBH 1 FIGS 01/04/2016 4:12PM
LEGEND
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
Approximately 1.4 Acres
(from Figure 6-3 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000 )
Potential Extent of Existing Asphalt Cover
Existing Rock Cover Around Septic Tank
Area Where Inert Fill Exists
Newly Constructed Road
Notes:
• 2015 Topography And Backround Image Provided By
Cooper aerial Surveys Co. - Dated February 10, 2015
• all Elevations Are Above Mean Sea Level (amsl)
120
120
SCALE IN FEET
Figure 5
Extent of Surface RIM and Areas of
Existing Cover
Area 1
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
-------
LEGEND
Approximate Extent of Radionuclide
Impacted Materials at the Landfill Surface
Approximately 10.6 Acres
(from Figure 6-5 of West Lake Landfill OU-1
Remedial Investigation Report, EMSI 2000)
Potential Additional Areas Where Surface
Radionuclide Impacted Materia! May be Present
Approximately .74 Acres
Approximate Limit of Rock Buttress
(See Attachment A for Additional Details)
Area Where Inert Fill Exists
Areas Outside Inert Fill
Where Slope Exceeds 5:1
Newly Constructed Road
Notes:
• 2015 Topography and Backround Image Provided by
Cooper Aerial Surveys Co. - Dated February 10, 2015
• All Elevations are Above Mean Sea Level (amsl)
SCALE IN FEET
Figure 6
Extent of Surface RIM and Areas of
Existing Cover
Area 2
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
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M:\CUENTS\EMSI\WESTLAKE\2015\RUBBLE-INVESTIGATI0N\RUBBLE-PAUL-BUILDUP.BW0-AReA 1 FB7 01/04/2016 4:12PM
LEGEND
Proposed Extent of New Non-Combustib!e Cover
(Approximately ± 1.4 Acres)
NON-COMBUSTIBLE COVER PROFILE
Proposed Extent of New Non-Combustible Cover
10' offset (Approximately ± 1.6 Acres)
8 Inches (nominal) of Rock
10 oz/sy Non-Woven Geotextile
Cut and Chipped Vegetation (if present)
Soil/Waste
Potential Extent of Existing Asphalt Cover
Existing Rock Cover Around Septic Tank
Newly Constructed Road
(Approximately ± .4 Acres
Within Proposed Extent of New
Non-Combustible Cover)
Notes:
• 2015 Topography And Backround Image Provided By
Cooper aerial Surveys Co. - Dated February 10, 2015
• all Elevations Are Above Mean Sea Level (amsl)
100
100
SCALE IN FEET
Figure 7
Preliminary Extent of
Non-Combustible Cover - Area 1
West Lake Landfill Superfund Site
EMS I Engineering Management Support, Inc.
-------
Proposed Extent of New Non-Combustible Cover
10'offset (Approximately ±9.54 Acres)
Limit of Rock Buttress (See Attachment A for
Additional Details)
Area Where Inert Fill Exists
Areas Outside Inert Fill
Where Slope Exceeds 5:1
Newly Constructed Road
(Approximately ± .79 Acres
Within Proposed Extent of New
Non-Combustible Cover)
Notes:
• 2015 Topography and Backround Image Provided by
Cooper Aerial Surveys Co. - Dated February 10, 2015
• All Elevations are Above Mean Sea Level (amsl)
LEGEND
Proposed Extent of New Non-Combustible Cover
(Approximately ±8.74 Acres) NON-COMBUSTIBLE COVER PROFILE
8 Inches (nominal) of Rock
10 oz/sy Non-Woven Geotextile
Cut and Chipped Vegetation (if present)
Soil/Waste
Figure 8
Preliminary Extent of
Non-Combustible Cover - Area 2
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
-------
/ OU-2
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Source: Cooper Aerial Surveys Company (2014)
Legend
A-1
Environmental Monitoring Station
# Meteorological Station
(MET) 0
Figure 9
Air Quality Monitoring Station
Locations
West Lake Landfill OU-1
.. &
SCALE IN FEET
EMSI Engineering Management Support, Inc.
-------
M:\clients\EMSI\westlake\2015\Rubble-lnvestigation\NCC-0rg Chart.dwg plotted: 12/23/2015
Figure 10
Project Team
West Lake Landfill Superfund Site
EMSI Engineering Management Support, Inc.
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Attachments
-------
Attachment 1
Area 2 Sloped Rock Fill - Plan and Profile View
-------
440 4
430
420
-0+50
Profile View of A - A'
0+00
1+00
Station
2+00
4500
2+50
-0+50
Profile View of B - B'
0+00
1+00
Station
2+00
2+50
490
480 4
470
440 4
430
420
-0+50
Profile View of C - C'
0+00
1+00
Station
2+00
490
+480
2+50
Profile View of D - D'
Profile View of E - E'
500 ^ *¦
490
-0+50
0+00
1+00
Station
2+00
2+50
-0+50
0+00
1+00
Station
2+00
2+50
- - % &
\\ *. - ^ k " .. v/V'^-v
/ WESTLAKE "W
/ ™ m ™ I a» W. m , •• • *&•
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-------
Attachment 2
Inspection and Maintenance Plan
-------
Attachment 2
NCC Inspection and Maintenance Plan
This inspection and maintenance plan applies to the non-combustible cover (NCC) to be
constructed over portions of Radiological Areas 1 and 2 at the West Lake Landfill Operable Unit
(OU-1) located in Bridgeton, Missouri.
I. GENERAL INFORMATION:
II. LOCATION INFORMATION:
Site maps for Areas 1 and 2 are provided as Figures 7 and 8 in the NCC Work Plan. The
figures provide topographic contours and the approximate areas of the proposed cover.
III. NON-COMBUSTIBLE COVER DESCRIPTION:
The anticipated cover design consists of the following:
Non-woven geotextile (10-oz/sy) placed over the ground surface (after vegetation
clearing);
8-inch (nominal) thickness of 4" minus rock (pit run/road base material) placed
over the geotextile; and
Upper surface of the rock layer to be graded to provide a relatively smooth
surface.
IV. INSPECTION AND MAINTENANCE PLAN
Described in this section are the inspection, maintenance, and repair activities to be
performed to maintain the integrity and effectiveness of the constructed cover.
Personnel performing inspection, maintenance and repair activities will follow the same
health and safety procedures, work procedures and sampling procedures as used for the
installation of the Non-Combustible Cover Project as follows:
• Health and Safety Plan for Non-Combustible Cover Installation at West Lake
Landfill, Operable Unit 1, Bridgeton, St. Louis County, Missouri dated February 8,
• Radiation Safety Plan for Installation of Non-Combustible Cap, West Lake
Landfill's Operable Unit 1, 13570 St. Charles Rock Road, Bridgeton, Missouri,
63044, dated January 4, 2016
Site Name:
Site Address:
West Lake Landfill - Operable Unit (OU-1)
13570 St. Charles Rock Road
2016
Attachment 2 to
NCC Work Plan
Page A2-1
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• Quality Management Plan dated December 2015
• Surface RIM Identification Sampling and Analysis Plan (SAP), West Lake
Superfund Site Operable Unit 1 dated December 2015
Quarterly inspections will be performed on the constructed cover surface by a designee of
the OU-1 Respondents until the final remedy for OU-1 has been implemented. After five
(5) years, the quarterly inspections may be reduced to annual inspections depending on
the conditions and maintenance requirements experienced (i.e., justified with reduced
maintenance requirements). The inspections referred to above will also be performed
following major precipitation events (with "major precipitation events" defined as greater
than 1" of rainfall over a 24-hour period).
Inspection of the cover will be performed to identify areas of erosion, exposed geotextile,
depressions, and growth of vegetation (brush, weeds, etc.). Maintenance and repair of the
cover will be performed to maintain the thickness of the rock cover material placed on
the landfill. The cover will be repaired in areas where rills, gullies, and crevices six (6)
inches or deeper have been identified. Areas of cover which are identified as being
highly susceptible to erosion will be repaired and/or otherwise protected with erosion
control materials. In addition, any holes or depressions which have been created that may
lead to surface water ponding will be repaired.
The repair of the cover will include adding rock material as necessary. If the geotextile
of the cover is exposed and noted to be deteriorated, it will be replaced.
Removal of excessive amounts of unwanted vegetation (e.g., brush, weeds, trees and
other woody growth) on the cover will be performed on a semi-annual basis as identified
during the inspections. Removal work will consist of, at a minimum, back-dragging the
cover surface. Mowing, clearing, and/or cutting may also be performed as necessary.
The surface of the cover is not to be disturbed by any vegetation removal work and
precautions are to be taken so that no dust is generated. Handling and management of
cleared vegetation is further addressed below.
The surface water control drainage pathways will also be inspected in conjunction with
the cover inspections. The frequency of the surface water system inspections may also be
reduced to annual after five (5) years, along with the cover inspections, depending on the
conditions and maintenance requirements experienced. Any drainage pathways and/or
diversion berms that have become eroded will be regraded, and areas that have developed
build-up of sediment will be cleaned, to restore proper functioning.
Any major access roads will also be inspected during the cover inspections. The
conditions of the road surface and any settlement will be noted. Repairs will be
implemented as necessary.
Attachment 2 to
NCC Work Plan
Page A2-2
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A designee of the OU-1 Respondents will be responsible for performing site inspections
and maintaining corresponding records. Record documentation of inspections will be
maintained on-site, or at the Bridgeton Landfill, LLC offices, along with a record of any
repair actions taken. A summary of the inspection activities follows:
ITEM
FREQUENCY
INSPECTION DESCRIPTION
Cover
Quarterly and
following major
precipitation events
(i.e., > 1" rainfall
over 24-hr period)
Erosion
Exposed geotextile
Settlement/depressions
Vegetative growth
Surface Water
Controls
Quarterly and
following major
precipitation events
(i.e., > 1" rainfall
over 24-hr period
Erosion of drainage pathways and berms
Sediment build-up
Blockage and settlement of drainage
pathways
Adequate surface drainage
Access Roads
Quarterly
Condition of road surface
Settlement
Vegetation
Semiannually
Cutting or removal of any vegetation that
may sprout in the NCC area
V. MANAGEMENT OF REMOVED VEGETATION
Clippings from any cutting or pulling of grass and weeds, as well as any cleared vegetation
(including tree trunks up to 12" in diameter) will be chipped and the chipped material will
be placed in a designated area. Trees too large to chip will be cut with a chain saw and
felled in the immediate area and on the property. Branches from trees will be removed and
chipped. Trunks will be cut into lengths no longer than 10 feet and will be safely and neatly
stacked in the designated tree trunk storage area.
Attachment 2 to
NCC Work Plan
Page A2-3
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TABLE 1A
MAINTENANCE PLAN - INSPECTION ACTIVITIES CHECKLIST
WEST LAKE LANDFILL - OPERABLE UNIT (OU-1)
NON-COMBUSTIBLE COVER CONSTRUCTION AREAS
Name of Inspector: Date:
Signature: Weather:
Company:
ITEM
FREQUENCY
INSPECTION DESCRIPTION
STATUS
COMMENTS
OK
ACTION REQ'D
Cover
Quarterly and
following major
precipitation
events <1)
Erosion
Exposed geotextile
Settlement/depressions
Vegetative growth
Surface Water
Controls
Quarterly and
following major
precipitation
events <1)
Erosion of drainage pathways
and berms
Sediment build-up
Blockage and settlement of
drainage pathways
Adequate surface drainage
Access Roads
Quarterly
Condition of road surface
Settlement
Vegetation Removal
Semi-annually<2)
Vegetation cutting or removal
NOTES:
(1) Major precipitation events are defined as >1" rainfall over 24-hr period
(2) Removal of vegetation will be performed on a semi-annual basis as identified during the quarterly inspections
(3) If follow-up actions are required, see Table 1B for details
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TABLE 1B
MAINTENANCE PLAN - REPAIR CHECKLIST AND RECORD
WEST LAKE LANDFILL - OPERABLE UNIT (OU-1)
NON-COMBUSTIBLE COVER CONSTRUCTION AREAS
Name of Inspector: Date:
Signature: Weather:
Company:
ITEM
REPAIR DESCRIPTION
STATUS
DATE REPAIRED
FURTHER DESCRIPTION / COMMENTS
OK
ACTION REQ'D
Repairs to Cover
Maintain thickness of cover
Repair where rills, gullies, and
crevices (>6") identified
Repair areas highly susceptible to
erosion
Repair holes or depressions
Regrade to promote positive drainage
Add rock material as necessary
Cover exposed geotextile
Replace deteriorated geotextile
Other
Repairs to Surface
Water Controls
Regrade eroded drainage pathways
and berms
Clean areas with sediment build-up
Remove blockages
Repair depressions and settlement
Maintain adequate surface drainage
Other
Repairs to Access
Roads
Repair as necessary
Other
Removal of Vegetation
Cut or remove any excessive
unwanted vegetation that may sprout
in the NCC area (on a semi-annual
basis)
Other
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