email regarding materials management plan · mr. paul rosasco page two 3. prior to use of any coal...

From: Seabaugh, RyanTo: Jump, Christine; Mahler, TomCc: Doster, BrandenSubject: RE: Materials Management PlanDate: Wednesday, October 04, 2017 4:02:49 PMAttachments: 1990 05 31 Miles Stotts laidlaw Waste Systems.pdf

20060728 WLL MMP accept letter with RTCs.pdf20080221 WLL MMP MDNR concerns email.pdf

Attached includes other documentation related to EPA comment #26 as discussed on Monday. Alsoattached is a letter from DNR to Laidlaw Waste Systems in 1990 regarding material placement overareas with known radioactive waste. Thank you

From: Seabaugh, Ryan Sent: Wednesday, August 16, 2017 2:05 PMTo: Jump, Christine ([email protected]); Mahler, TomCc: Doster, BrandenSubject: Materials Management Plan Chris and Tom, I was able to locate a letter from EMSI dated March 24,2006 requesting approval for the MMP, butwas unable to locate any documented response from EPA. Attached is the cover letter from thePRPs. If you are able to locate a response, could you please forward a copy to us for our records? Thank you
mailto:[email protected]:[email protected]:[email protected]

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1 11/26/2014 01:54:50 PM

West Lake Landfill Materials Management PlanWest Lake Landfill Materials Management PlanWest Lake Landfill Materials Management PlanWest Lake Landfill Materials Management Plan ---- DNR concernsDNR concernsDNR concernsDNR concernsShawn MuenksShawn MuenksShawn MuenksShawn Muenks to: rick.walker 02/21/2008 12:32 PM

Cc:larry.erickson, Aaron Schmidt, bob.geller, Andrew.McKinney, Scott

Waltrip, John Boessen, gunn.gene, easley.diane, Wall.Daniel

Bcc: All Message Store

Rick,

Per our conference call 2/8/08, the department is submitting the following list of concerns that

were observed during our site visit on 2/7/08 to the West Lake Landfill. Please provide response

and course of action for each item noted below:

The Materials Management Plan (MMP) notes several requirements for allowable placement of

fill and/or stockpiling activities within the Operable Unit 1, Areas 1 and 2. The conditions

observed in the field that did not meet these requirements are as follows:

The lateral extents of designated areas for stockpiling and/or fill within the radiological areas 1.

(Area 1 and 2) were not surveyed prior to placement per the approved plan.

It was not apparent if the material was placed in 1 to 2 ft. lifts during placement to achieve 2.

proper compaction requirements.

The MMP calls for a maximum height of 5 feet of permanent fill and an additional 5 feet of 3.

stockpiled material on top of the permanent fill for a total of 10 feet. It appeared that this

height had been exceeded within both areas.

The MMP calls for the perimeter of the designated areas for placement to be delineated with 4.

concrete barriers or other physical means to restrict disposal to these areas. No such barriers

were observed.

Signage or other means to identify designated areas for placement were not present as well as 5.

signage to denote radiological areas.

Per the plan, access roads to designated areas for stockpiling should be constructed to a 6.

maximum width of 60 feet. It appeared that the access road to Area 2 exceeded this

requirement.

It was not apparent if dust control measures had been taken such as watering during dry 7.

periods. The MMP also calls for stockpiled or permanent fill to be covered with a minimum

of 12 inches of intermediate soil cover after final placement to prevent wind transport.

A decontamination pad with plastic liner to collect heavy equipment wash water was not 8.

observed.

The following requirements pertain to Health and Safety Plans outlined in the MMP:

A Radiation and Health Safety Officer (RSHO) must be identified, please identify this 1.

person.

The RSHO is responsible for personnel and vehicle screening and decontamination and 2.

maintaining records of these activities. It was not apparent if these practices were followed.

Please provide records of these activities if available.

The MMP calls for at least annual inspections of fill materials, designated stockpile/fill areas, 3.

and records of screening and decontamination activities by a qualified geologist, engineer,

health physicist or safety engineer. Please provide documentation to support this.


2 11/26/2014 01:54:50 PM

The following are other issues noted during the site visit for which the department requests

response:

If any grubbing or tree removal had taken place prior to placement of fill material, please 1.

provide documentation that the material remained on site or was characterized and disposed

of properly.

During the site visit, it was noted that gates on the western perimeter fence were unlocked 2.

and the combination locks were hanging open in the latches.

If you need clarification on any of these items or have questions, please give me a call.

As promised attached is an organizational chart for our section within the Hazardous Waste

Program of the Department of Natural Resources and some contact numbers as follows:

Larry Erickson, Section Chief (573)751-6838

Aaron Schmidt, DOE Unit Chief (573)751-3154

Shawn Muenks, West Lake Project Manager (573)751-3107

Eric Gilstrap, FUSRAP Project Manager (314)877-3250

_____________________________________________

Shawn Muenks, Environmental Engineer

Hazardous Waste Program, Federal Facilities Section

Missouri Department of Natural Resources

PO Box 176, Jefferson City, MO 65102-0176

(573)751-3107

e-mail: [email protected]

JOHN ASHCROFT Gm-cmor

G. TRACY MEHAN III Oirecior STATE OF MISSOURI

DEPARTMENT OF NATURAL RESOURCES

OFFICE OF THE DIRECTOR P.O. Box 176

Jefferson City, MO 65102

May 31, 1990

Mr. Miles Stotts Assistant Regional Engineer Laidlaw Waste Systems, Inc.

314-751-4422

23~0 South Arlington Heights Road Suite 230 Arlington Heights, Illinois 60005

Dear Mr. Stotts:

; . Dhision of Energy Dhi~lon of EnYironmen1al Quality

Dhis_!Jm of Geology and [.and Sun.'C}' Di\ision of Management Sen.ices

Dhision of Parks, Recreation, and Historic Preservation

I have reviewed your letter of April 13, 1990 concerning those areas of West Lake Landfill in which radioactive waste had previously been landfilled. Essentially, your letter correctly depicts the Waste Management Program's IWMP) position on issuance of a solid waste disposal area operating permit for those areas.

In summary, the site in question was placed on the EPA's Comprehensive Environmental Response Compensation Liability Information System ICERCLISI list November 1, 1979. The site was subsequently placed on the State of Missouri's Registry of Abandoned or Uncontrolled Sites February 22, 1985. The WMP's position is that a site that is verified to contain hazardous substances, as in this case, must be evaluated and assessed In accordance with the appropriate federal, state, and local law and rules, and proper corrective action implemented prior to the department evaluating the site for future non-hazardous solid waste deposition or permits. To date, the environmental impact and appropriate closure/remediation of this site have not yet been determined. On October 26, 1989, the USEPA proposed to place the site on the National Priorities List. That proposal has not yet been finalized.

The WMP has held the position that no proposal for a solid waste disposal area permit or permit modification would be considered which would allow the placement of additional non-hazardous solid waste and related soil cover on these portions of the site until the radioactive waste and other possible hazardous

Mr. Miles Stotts May 31 , 1 990 Page 2

substance issues are resolved. Soil cover placement (without placement of additional waste) as a short-term remedial action step would be considered if it were shown to be necessary and effect i ve in minimizing adverse environmental effects of the existing wastes disposed on-site.

If you should have further questions concern i ng this issue, please contact me at (314) 751-3176.

QUALITY

Nicholas Di Pasqua e Director , Waste Management Program

NAO : l tl

cc : Mr . Scott Schreiber, Laidlaw Waste Systems Mr. Jim Belcher, Superfund Section, WMP Mr. Dave Sedan, DEQ Administration Mr. Jim Hull , Sol i d Waste Section, WMP

July 28, 2006

Mr. Paul Rosasco Engineering Management Suppo1i, Inc. 8125 W. Grand Avenue, Suite 100 Lillleton, CO 80123

RE: Materials Ma11age111e111 Planfi,r Wes/ f.ake Lt11ff{/il/ Operable Unit/, Revised June 28, 200(,.

Dear Mr. Rosasco:

The Federal Facilities Scc!ion of the Hazardous Waste Program has reviewed the revised Materials Ma11age111e11t l'/1111.fi,r Wes/ l.alw l.mulfill Operable Unit I, dated June 28, 2006, The department provided comments on the Materials Management Plan (MMP), dated March 24, 2006. Those comments were adequately addressed in the revised document, except for Specific Comment 111 () regarding Section 6.2 l'erso1111el and Vehicle Decontami11atio11. The department docs not agree with allowing soil and water generated during vehicle decontamination to be washed into voids of the concrete rubble decontamination pad and later covered with fill and capped. The purpose ol'thc landfill cover is to prevent additional infiltration of water into the landfill, thus reducing gas generation. Allowing wash water to infiltrate into the landfill goes against all remediation efforts at the site. This section should 1:,e rewritten to include a rinsalc collection system in which all rinsatc from decontamination activities is collected and properly disposed ofor treated.

Based upon a review of the response to comments and the revised plan, the department finds this plan acceptable fbr handling materials for use at the site once the decontamination section is modified as described above and provided that the following stipulations are upheld.

I. The acceptance of the MMP shall not he construed as an approval by the dcpaiimcnt of any material brought on to the site to he suitable for use in the landfill cover. Engineering properties must be tested for prior to use of ce1iain materials in the cover.

2. Concrete rubble brought on to the site may not be of suitable size for use in general fill or construction of the bio-intrusion layer. Additional analysis may be required to determine the optimum gradation at which the concrete rubble can he compacted into competent subsurface hearing strata to support the integrity of the final landfill cover.

ftj Hn1,~·,l l',i·~·,

Mr. Paul Rosasco Page Two

3. Prior to use of any coal combustion by-products (CCB), the department has requested to review pH test results of the CCB.

Ir you have any questions or require any li1rthcr clarification, you may contact me by phone at (573) 751-3107. Direct written correspondence to me al P.O. Box 176, Jefferson City, MO 65l02-0176, or by e-mail to shawn.mucnks(

MISSOURI DEPARTMENT OF NATURAL RESOURCES Comments on the

West Lake Landfill Operable Unit 1 Materials Management Plan

GENERAL COMMENTS:

1. Materials for Use as Final Landfill Cover The cover letter of the Materials Management Plan (MMP) includes the statement "This Plan addresses acceptance and placement of inert fill material in Areas 1 and 2 to fill low-lying areas where runoff accumulates, for use as part of the fill material required to achieve minimum slope angles as part of the final remedy for the Site and as temporary stockpile material for use in constructing the.final lmu(fi/1 cover for OU-I".

The department would like to make clear that the main purpose of this plan is to address the stockpiling of acceptable materials to bring low areas up to grade and stockpiling of acceptable materials for use in the bio-intrusion layer. The department does not see this plan as approval of material for use in the final landfill cover. The final cover requirements will be defined in the remedial design documents. The engineering properties of the final cover must meet certain Solid Waste Regulations (e.g. soil type and low permeability restrictions). We suggest that the engineering properties be tested for and borrow material selected for the final cover prior to transportation to the site to ensure quality control. Stockpiling of materials on site for use in the final landfill cover is acceptable only under the condition that the work would be modified or undone in the event that placement of this material is inconsistent with the selected remedy, e.g., the proposed remedy is changed as a result of public comment. We would also like to see the proposed source(s) of the borrow material for the final cover mentioned in the plan and historical use of these locations. Finally, the department would like to mention that although we are giving our general consent to stockpiling these materials, the state reserves the right to make any final opinion until the remedy is actually selected and work plans are created.

RESPONSE: The text has been clarified to indicate that the clean fill material will primarily be used to fill low areas to promote drainage and to achieve final grades. Concrete or asphaltic concrete material that may be received pursuant to this plan may either be used as inert fill to achieve final grades or fill low areas or alternatively may be stockpiled for later use in construction of the bio-intrusion/marker layer to be placed immediately below the landfill cover. This language was added to Section 2 of the plan. Soil that may be received pursuant to this plan that has a potential to meet engineering requirements for final cover construction may be stockpiled for later testing once final specifications pursuant to a final, agency-approved remedial design have been developed.

2. Concrete and Asphaltic Rubble/Off-Specification Masonry Block The department accepts the stockpiling of concrete for use as a bio-intrusion layer and as clean fill on site, provided that the following stipulations are met. a) Under Section 3. Material Characteristics· page 3 of the plan, it mentions that

material will be accepted to the site provided that it contains "only minimal amounts of reinforcing steel or other construction materials". What constitutes "minimal amounts"? The state would like to see a more detailed description on how these deleterious materials will be limited.

b) What will be the condition of these materials as they arrive on the site? For example, do you plan to stockpile these materials in large chunks or will they be crushedto a specified gradation? In order to use these materials as an effective cover, they should be reduced to a size that is manageable and provides for uniform coverage. More detail on what size of material will be accepted or how the material will be further refined is needed.

c) In addition to specifying gradation of materials, dissimilar materials should be segregated and stored in separate locations so that they are easily accessible when it comes time to begin construction of the engineered cap. A plan for how the materials will be staged should be included in Stockpiling of Clean Fill Material section.

RESPONSE: The text was based on the definition of inert material contained in IO CSR 8-2.010(1 I) which allows for minimal amounts of wood and metal in inert fill. A specific statutory reference to this definition has been added to the text. From a practical standpoint, the material will be visually inspected by Bridgeton Landfill LLC personnel upon arrival at the Site and concrete with reinforcing steel extending more than approximately six inches out of the concrete will be rejected.

Any concrete rubble that may be used in construction of the bio-intrusion/marker layer will be stock-piled on site. Determination of the appropriate size of the material to be used for construction of the bio-intrusion/marker layer will be made in conjunction with development of the remedial design documents. It is anticipated that the material will generally arrive at the site in approximately 6-inch sized or larger pieces but all sizes of concrete rubble may be accepted for use as common fill to achieve final landfill grades. Concrete rubble that may be suitable for use in construction of the biointrusion/marker layer will be stock-piled onsite until a formal specification for this material is developed as pa11 of the remedial design for OU-I.

Any soil material that may be received pursuant to this plan that has the potential to be used for construction of the final cover will be stockpiled for later testing and determination of suitability for use in cover construction. Soil that may potentially be used for cover construction will be stockpiled outside of Areas 1 and 2. The exact locations that these materials may be stockpiled will be determined by Bridgeton Landfill LLC based on the nature and location of other activities occurring at the Site.

3. Coal Combustion Byproducts According to a letter dated April 24, 2006 from Jim Bell of the Solid Waste Management Program, the use of coal combustion by-products (CCB) was given exemption to be used as structural fill, road base construction and soil stabilization at the Bridgeton Landfill. The department concurs with this decision; however, the department believes some additional confirmatory testing of the material is necessary prior to placement. One aspect of this confirmatory analysis would be testing for radionuclides. Reportedly this analysis has already been performed as communicated in a May 25,

2006 teleconference call, and at the time of this comment letter the department is awaiting the results. Secondly, the department requests pH testing of the CCB. The department is concerned that a decrease in the pH of the subsurface may affect the mobility of the radioactive material.

RESPONSE: Radionuclide testing of the ash material was performed and the results were forward to EPA and MDNR via e-mail on June I, 2006. Bridgeton Landfill LLC has also requested pH data for the ash material to address the second part of this comment.

4. St. Louis County Requirements The department requests that the St. Louis County Department of Health be provided a copy of the MMP and offer them the opportunity to comment with any concerns or requirements that they may have on the proposed fill placement.

RESPONSE: A copy of the revised MMP has been provided to St. Louis County Department of Health.

SPECIFIC COMMENTS:

1. Section 2 P111pose and Objectives, page 2 - Define "inert fill". The department requests a listing of all material that is planned to be used as clean fill on the site to eliminate any misinterpretation.

RESPONSE: The sources and types of clean fill materials that have been identified to date were described in the first paragraph of Section 3 of the MMP. The exact type of clean fill material that may be received in the future cannot be predicted at this time. The MMP requires all fill material to meet MDNR's definition of inert fill as specified in IO CSR 8-2.010(11 ).

2. Section 3 Material Characteristics, page 3 - Typographical error: Reference to IO CSR 80

2.0 IO( I 0) should be IO CSR 80-2.0 I 0(11 ).

RESPONSE: Agreed, The text has been revised.

3. Section 3 Material Chamcteristics, page 3 - Second paragraph, first sentence mentions that Bridgeton Landfill intends to utilize long-term contacts with known and reliable sources of clean fill material. The department requests a list of these contacts.

RESPONSE: The sources and types of clean fill materials that have been identified to date were described in the first paragraph of Section 3 of the MMP. At this time, the only identified contacts for inert fill are Kirshner Block and the City of Bridgeton. Amerin is a potential source for the ash material beginning in 2007.

4. Section 4 Material Placement and Stockpile Locations, page 4, Second Paragraph "Placement of materials within the five areas identified on Figure I can be performed

with no effect on the implementability of any of the potential remedial actions that may be selected for OU- I." Suggest adding the following to the end of the sentence, " ... provided that the materials meet the clean fill criteria and are placed such that they will not interfere with the final landfill cover design chosen in the final remedy."

RESPONSE: Agreed. The suggested text has been added to the MMP.

5. Section 4 Material Placeme11t 1111d Stockpile Loc11tio11s, page 4, End of Third Paragraph "Consequently, if additional fill material is available, it could be placed in temporary storage in other portions of Area 2 or possibly in Area I." The department would like to see all "alternative storage areas" identified on a figure.

RESPONSE: Fill material that is intended for use solely to achieve final grades can be stock-piled anywhere within Areas I and 2. Concrete rubble that may be suitable for construction of the bio-intrusion/marker layer and soil that may be suitable for construction of the final landfill cover will be stockpiled outside of Areas 1 and 2. The exact locations of potential stockpiles, if any, will be determined by Bridgeton Landfill LLC based on the nature and location of other activities that may be occurring at the Site. If and when it is determined that material needs to be stockpiled, appropriate locations will be identified and this MMP will be amended to show such locations.

6. Section 5 Materials Ha11dli11g 1111d Placement, pages 4-5 - The department recommends two I-ft thick lifts placed on the road beds to prevent disturbance of subsurface materials. This will provide added insurance to prevent any contact with potentially radiologically impacted soils. In addition to the extra lift, all road beds should be tested for stability by "proof-rolling" with a fully loaded tandem axle dump truck and observe for any "rutting" of the road base. Any soft areas identified should be backfilled with additional material until road bed can suppo11 the weight of the truck. The road beds should be inspected daily for structural integrity under an approved inspection program. Last sentence of the section: Please define "intermediate soil cover".

RESPONSE: Agreed. The text of the MMP has been modified to include this condition. The reference to intermediate soil cover was intended solely to indicate that it is not final cover. In response to the comment, the term "intermediate"has been removed from the discussion.

7. Section 6 Radiological a11d Health Safety, page 6 - This section should have mention of a Health and Safety Plan. It is recommended that site workers wear dosimeter badges.

RESPONSE: The text has been modified to indicate that the existing Bridgeton Landfill LLC Health and Safety Plan for operations at the landfill will be amended to address health and safety issues associated with implementation of this MMP.

8. Section 6.1 Radiatio11 Scree11i11g, page 6 - Middle of first paragraph: "Once a suitable

base layer of clean fill material has been constructed such that all subsequent operations in a given area can be conducted on top of clean fill material without the potential for contact with underlying Area 2 materials, radiological screening should no longer be required; however, the decision to suspend radiological screening will be made by the RSHO." The department feels that radiological screening should take place during all construction activities at the site. The possibility of machinery breaching the cap or erosion due to site work is too great a risk to suspend screening activities completely.

RESPONSE: The text has been modified to indicate that all vehicles will be screened prior to leaving the radiological areas.

9. Section 6.1 Radiation Screening, page 7 - Wipe samples should be taken from all grading equipment that contacts the soil (dozer blades, tracks, etc.), not just vehicle tires, wheel wells and mud flaps.

RESPONSE: The text has been modified to indicate that the tracks, blades, etc. of grading equipment will be screened if and prior to leaving the radiological areas.

10. Section 6.2 Personnel and Vehicle Deco11tami11atio11, page 7 - The depaiiment requests an explanation of how contaminated materials will be disposed of. Also, the plan should contain an expanded discussion on the operation of the decontamination zone, in particular, how the rinsate from the trucks will be collected, characterized and disposed of.

RESPONSE: The MMP calls for placement of concrete rubble over a small area within Area 2 to be used for decontamination of vehicles as necessary prior to egress from Area 2. Any soil or other material removed from vehicles during decontamination of otherwise generated during decontamination will be washed down into the void spaces of the concrete rubble. Any water used to decontaminate the vehicles will also be washed down into the void spaces in the rubble. As part of implementation of the remedial action this area will be covered with additional fill material and capped.


1 11/26/2014 01:54:50 PM

West Lake Landfill Materials Management PlanWest Lake Landfill Materials Management PlanWest Lake Landfill Materials Management PlanWest Lake Landfill Materials Management Plan ---- DNR concernsDNR concernsDNR concernsDNR concernsShawn MuenksShawn MuenksShawn MuenksShawn Muenks to: rick.walker 02/21/2008 12:32 PM

Cc:larry.erickson, Aaron Schmidt, bob.geller, Andrew.McKinney, Scott

Waltrip, John Boessen, gunn.gene, easley.diane, Wall.Daniel

Bcc: All Message Store

Rick,

Per our conference call 2/8/08, the department is submitting the following list of concerns that

were observed during our site visit on 2/7/08 to the West Lake Landfill. Please provide response

and course of action for each item noted below:

The Materials Management Plan (MMP) notes several requirements for allowable placement of

fill and/or stockpiling activities within the Operable Unit 1, Areas 1 and 2. The conditions

observed in the field that did not meet these requirements are as follows:

The lateral extents of designated areas for stockpiling and/or fill within the radiological areas 1.

(Area 1 and 2) were not surveyed prior to placement per the approved plan.

It was not apparent if the material was placed in 1 to 2 ft. lifts during placement to achieve 2.

proper compaction requirements.

The MMP calls for a maximum height of 5 feet of permanent fill and an additional 5 feet of 3.

stockpiled material on top of the permanent fill for a total of 10 feet. It appeared that this

height had been exceeded within both areas.

The MMP calls for the perimeter of the designated areas for placement to be delineated with 4.

concrete barriers or other physical means to restrict disposal to these areas. No such barriers

were observed.

Signage or other means to identify designated areas for placement were not present as well as 5.

signage to denote radiological areas.

Per the plan, access roads to designated areas for stockpiling should be constructed to a 6.

maximum width of 60 feet. It appeared that the access road to Area 2 exceeded this

requirement.

It was not apparent if dust control measures had been taken such as watering during dry 7.

periods. The MMP also calls for stockpiled or permanent fill to be covered with a minimum

of 12 inches of intermediate soil cover after final placement to prevent wind transport.

A decontamination pad with plastic liner to collect heavy equipment wash water was not 8.

observed.

The following requirements pertain to Health and Safety Plans outlined in the MMP:

A Radiation and Health Safety Officer (RSHO) must be identified, please identify this 1.

person.

The RSHO is responsible for personnel and vehicle screening and decontamination and 2.

maintaining records of these activities. It was not apparent if these practices were followed.

Please provide records of these activities if available.

The MMP calls for at least annual inspections of fill materials, designated stockpile/fill areas, 3.

and records of screening and decontamination activities by a qualified geologist, engineer,

health physicist or safety engineer. Please provide documentation to support this.


2 11/26/2014 01:54:50 PM

The following are other issues noted during the site visit for which the department requests

response:

If any grubbing or tree removal had taken place prior to placement of fill material, please 1.

provide documentation that the material remained on site or was characterized and disposed

of properly.

During the site visit, it was noted that gates on the western perimeter fence were unlocked 2.

and the combination locks were hanging open in the latches.

If you need clarification on any of these items or have questions, please give me a call.

As promised attached is an organizational chart for our section within the Hazardous Waste

Program of the Department of Natural Resources and some contact numbers as follows:

Larry Erickson, Section Chief (573)751-6838

Aaron Schmidt, DOE Unit Chief (573)751-3154

Shawn Muenks, West Lake Project Manager (573)751-3107

Eric Gilstrap, FUSRAP Project Manager (314)877-3250

_____________________________________________

Shawn Muenks, Environmental Engineer

Hazardous Waste Program, Federal Facilities Section

Missouri Department of Natural Resources

PO Box 176, Jefferson City, MO 65102-0176

(573)751-3107

e-mail: [email protected]

Federal Facilities Section org chart.pdf

DOC43"Seabaugh, Ryan" 10/4/2017 RE_ Materials Management Plan.pdfDOC44Attachment:11990 05 31 Miles Stotts laidlaw Waste Systems.pdfDOC44Attachment:220060728 WLL MMP accept letter with RTCs.pdfDOC44Attachment:320080221 WLL MMP MDNR concerns email.pdf

barcode: *30325838*barcodetext: 30325838

email regarding materials management plan · mr. paul rosasco page two 3. prior to use of any coal...

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